LESSONS LEARNED FROM POP CULTURE AND QUESTIONS CANADIAN PHARMA MARKETERS SHOULD ASK THEMSELVES BEFORE TAKING THE MIC
Remember the 2009 Video Music Awards when Kanye West walked on stage and grabbed the microphone from Taylor Swift’s hand as she was giving her acceptance speech for winning the best music video award?
People always say “there’s a time and place for everything,” but I would argue that doesn’t take it far enough. In addition to the time and place, we should also take into account the rest of the context:
What actually is the message?
Who is delivering the message?
Who is receiving the message?
Why is the message being shared?
How is the message being shared?
WHAT DOES THIS HAVE TO DO WITH PHARMACEUTICAL MARKETING IN CANADA?
When I’m writing marketing copy (one aspect of my profession as a medical writer), I ask myself these questions on behalf of my clients all of the time; however, it applies to more than just advertising. Medicine is a fascinating, complex industry that is constantly evolving, so it is a challenge for medical professionals to keep on top of all of the recent advancements in research. In addition to writing advertising copy, I write educational content to help medical professionals keep abreast of the changes in their industry.
Health Canada recognizes the importance to the pharmaceutical industry to be able to disseminate non-promotional information. What is non-promotional information? It can be anything that is not primarily intended to promote the sale of a drug, including educational content. That seems straightforward, but in actuality the line marking that distinction gets blurry when information that is supposed to be educational is also indirectly promotional.
TAKE THIS EXAMPLE:
A brand manager at a pharmaceutical company wants to produce a brochure on the long-term consequences of a disease when patients are left untreated. On the surface, the brochure seems like it’s educational information about the disease, but the underlying take-away is that patients with this disease should be treated, and preferably sooner rather than later if they would like to avoid the long-term consequences. The outcome, whether or not it is intentional, is that the reader wonders: should I ensure all of my patients with this disease are treated, and if so, which drug should I prescribe?
What if the company that produced this brochure provides the only available treatment for this disease?
As you can see, information distributed by a company that has something to gain by distributing that information can indirectly be promotional. If the communication conflicts with the Food and Drugs Act and Food and Drugs Regulations, you may find you have to explain yourself, just like Kanye did the day after his awards show outburst.
Fortunately, there is a policy that provides guidance called The Distinction Between Advertising and Other Activities. In this policy, there is a list of questions to consider to determine if the purpose of a message is to promote the sale of a drug. The PAAB also has this great flow diagram, which helps you decide if you should get your message reviewed by the PAAB. You can also consult an experienced medical writer if you have any further questions!
It’s important to take the time to think carefully about where, when, why, how, by whom and to whom you want to share your message.