“Digital governance has reached a critical tipping point,” said Zoe Dunn of Hale Advisors, launching the discussion at last month’s MM&M roundtable on this pivotal topic. “It has become crucial for pharma, biotech and medical device companies to have this kind of governance system in place in order to do more and better integrated multichannel digital programs,” she said, emphasizing that “digital has become not just an afterthought, but the glue that binds many companies’ promotional and communication initiatives together.”
Roundtable participants included marketers and counsel from top-tier pharma companies to legal experts specializing in FDA regulations. The group gathered to discuss digital governance and current challenges faced by the life sciences industry with regard to adopting and adhering to a successful company strategy.
- Zoe Dunn, president and CEO Hale Advisors
- Dale Cooke, president, PhillyCooke Consulting
- Ami Patel, senior counsel, Johnson & Johnson
- Glenn Butcher, senior director, Vertex Pharmaceuticals
- Gaetan Akinrolabu, associate director, paid media and social strategy, Bristol-Myers Squibb
- Stefanie Doebler, special counsel, Covington & Burling
Between constantly evolving legislation and state-mandated privacy, (case in point the recently adopted California Consumer Privacy Act, which goes into effect January 2020), the discussion at the roundtable couldn’t have been timelier. Participants agreed that while it can be very difficult to keep employees informed on company policy, a structured set of guidelines that is easily accessible at the earliest stage possible is paramount to educating and empowering staff.
Dunn said her company is often tapped to help clients come up with a “road map” to help ensure that marketers avoid legal backlash when they share content on social.
“With governance, essentially the more structure you have in place, the more clarity there is around a specific channel, and the easier it is for employees to follow,” she said.
Dale Cooke, president of PhillyCooke Consulting, observed that what his clients usually find most challenging is the frequency with which they must update their policies in order to stay relevant in the digital realm, which can sometimes deter them from implementing any policies at all.
“I have clients who literally have nothing in place,” he reported. “And that lack of structure is a real hindrance when you walk into a company and they don’t know what kind of policy they have.”
To get the ball rolling, a “down and dirty doc” can be an easy and effective first step in establishing company guidelines, noted Cooke. “Sometimes you just need a simple document to help keep things clear,” he said. “Not a formal, controlled document. It doesn’t reside in your review and approval system, so it doesn’t get all the layers of sign up, but that also means someone can update it on the fly.”
Ami Patel of Johnson & Johnson agreed that keeping the process of governance as simple as possible is a valuable approach. She noted that when marketers and promotional review teams grow frustrated, it’s important to remind them that they don’t have to “recreate the wheel” when it comes to applying their digital governance strategy across multiple platforms.
“Sometimes you can say, ‘OK, in this small area we’ve done this,’ and then apply it across the board instead of keeping ideas in silos,” she said. “That’s where a governance board can be so important, because they can see across all brands and can give teams feedback on that kind of cross-sector, cross-cutting and cross-brand view.”
Dunn pointed out that while developing governance guidelines has its challenges, communicating them to employees and ensuring companywide compliance can present a greater hurdle.
“We’ve seen fewer issues with the outside public engaging with content in an appropriate manner and way more challenges with our clients’ own employees,” she said. “That’s why it’s so important to ensure that we’re helping our clients develop a very clear framework to make sure they’re protecting themselves, but also encouraging internal sharing.”
Many in the group acknowledged they’ve encountered challenges in educating employees about the potential pitfalls in sharing a particular post and its possible impact on the company.
“It’s tough because you’ve got this scientist who’s been working on a drug for years and years, and they’re so proud as it gets to a certain milestone that they want to just share it with their whole network,” said Glenn Butcher of Vertex Pharmaceuticals. “Then we have to step in and say, ‘Sorry, you can’t put that up,’ so it can definitely create some issues internally.”
Gaetan Akinrolabu of Bristol-Myers Squibb said one safeguard his company has put into place is the use of LinkedIn Elevate, an employee advocacy tool, where individuals can log in, create and upload content, have it approved right there on the platform and then with the click of a button, safely share it with their network.
“We’ve found this to be an incredibly useful tool in the way of governance,” he said. “We launch an annual campaign where we have select BMS employees going on a countrywide bike ride on behalf of BMS in support of patients living with cancer, and a lot of them wanted to share their journey on social, rightfully so. We are exploring the use of LinkedIn Elevate to create a pre-made, pre-approved, unified message that they can link to their account, allowing them to easily snap a picture and connect it to the BMS platform without any worry about repercussion. This would be a great example of safely driving traffic from their profiles to our site, while showing that kind of employee advocacy we’re also looking for.”
Akinrolabu also pointed out how vital it is to make sure employees truly understand why certain best practices in social media are important, as no legal team can effectively govern if employees don’t understand the reasoning behind why certain regulations need to be in place.
“We have quarterly learning sessions within Corporate Affairs, centered around best practices and the latest and greatest in social media, where we encourage our legal colleagues to attend,” he explained. “There’s this learning curve where if you don’t understand the implications of why having a hashtag for a certain campaign is important in specific posts, then you have to ask yourself, are you really going to be able to monitor those things effectively?”
Stefanie Doebler of Covington & Burling echoed that sentiment, noting that educating a company’s legal team is essential, as every decision it’s faced with is looked at from a “risk-benefit” standpoint.
“When you’re able to go to your legal team and say, ‘Here’s the benefit we get out of this,’ as opposed to just ‘We think this is a cool idea,’ that makes a huge difference in terms of the way they consider it,” she explained. “Obviously, it’s not going to make something that’s illegal all of a sudden legal, but it might make them more willing to push the envelope where they might not have been willing to when they couldn’t see the actual benefits.”
Cooke revealed that he often educates himself on the pros and cons of a platform before advising clients on best practices.
“The first time I truly understood how Facebook worked was when I went through and tried all the different features I never had before and was then able to explain their purpose to my legal team,” Cooke said. “I’m constantly playing around with the apps of these different platforms to learn what they’re about.”
Patel noted this tactic is useful in evaluating which platforms to eliminate from a company’s marketing plan.
“The concept of failing fast in digital seems to be everywhere but pharma,” she said. “Having the metrics to figure out quickly which platforms are not providing any true benefits helps make the decision of what to keep and what to lose that much easier and allows you as a company to pivot in the right direction.”
Doebler said she finds that spending time with the junior associates (i.e. the millennials) at her firm is helpful when she’s trying to learn about a new social platform a client may be using.
“Let’s face it, unlike me, they grew up on a computer, so they’re digital natives,” she explained. “They speak the language in a way that I don’t, so just talking to them is a good way to learn what’s going on, what people are interested in and how a platform works in practice.”
That comprehensive understanding can help establish trust among employees in the course of implementing a digital governance strategy, noted Dunn. “Often when employees hear the word ‘governance’ it evokes visions of policing and restricting workflow, when in fact, putting a clear structure in place can allow employees more freedom to get their content out faster without having to stop at every ‘mile marker,’” she added.
Butcher agreed noting that companies can help to alleviate employees’ concerns by presenting governance regulations as more of “an incubator or an accelerator” that will allow them to connect to the right resources and continue moving forward, rather than something that will squash their creativity.
“That’s where the role of governance becomes so important because it presents an opportunity for companies to instill a sense of trust in its employees that they are doing things in an ethical and compliant way that will add value to the community,” he said.
“The value of good governance can actually be measured in opportunity as well,” added Dunn. “A company that makes an investment in digital governance will increase speed to market in these channels, drive more lasting connections with their audience and ultimately increase the ROI of digital programs all while reducing liability and exposure. I think that is a concept we can all get behind.”