Just last month the FDA released their latest Internet and Social Media Guidance for Pharma and Med-tech companies. If you haven’t read it yet, have a look here.
With the rise and use of social media across all industries, Med-Tech was bound to adopt social media at some point, especially given the prevalence of customer usage and relatively cheap way of reaching customers and/or offering customer service via electronic means. The introduction of this document points out that its purpose is to illustrate the agency’s current thinking regarding communication of benefits and risks through social and online media. The hearing aid industry generally does not fall under the exact guidelines as indicated in the latest draft, however the overall suggestions and illustration of what the FDA lays out is obviously food for thought for any health care organization marketing to customers online.
In the U.S. the FDA generally recognizes two types of labeling; that which is required labeling (think approval labeling) and the second which is promotional labeling (subsequent marketing materials/labeling). They recommend considering the following when promoting products on social media and online mediums:
- Be truthful and non-misleading,
- If making a claim about a product, indicate the use and risk of that product.
- Required information from the labeling must be easily available when discussed.
- Advertising of any drug must include risk info and intended use. If the name of the product is mentioned as a promotional “reminder”, but not for the purpose of how the product is used, it’s then excluded from this rule.
- Drug advertisements must present benefits and risk information fairly.
- Risk information of suggested uses must be presented individually or have a prominent reference.
The FDA asks firms to consider carefully whether or not they can accurately meet the guidelines when promoting products and making product claims on social media. The document then subsequently goes through each of the guidelines above with some generic examples of how to disclose risk information within brackets [ ], including how to incorporate URLs for additional product information. The main takeaway here is to be succinct, truthful and informational with your product promotions when a claim is being marketed. Nothing that professional social media marketers cannot handle. After all, being truthful and transparent is the essence of social media communication, especially for corporations who cannot afford to be misguiding to their customers without risking serious backlash.
At Sonova the culture of putting customers first is in the lifeblood of our company and at Phonak we have a 3-part, public social media governance which embodies our stance on how we interact with our customers and professionals: Community Disclaimer, Engagement and Our Responsibility.
For us, we make it very clear that the information posted on our pages, by us or customers, is not intended as medical advice. Individuals should always consult their medical practitioner for medical related inquiries. We also clearly state to community participants that we reserve the right to remove abusive language or information not pertaining to the community. Lastly, as part of the Sonova Group, Phonak expects employees to act truthfully when on social media and while engaging with employees, fellow colleagues, clients, business partners, and the general public.