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An Eye On Google, Executive Summary Presentation

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Executive summary presentation I developed for the RTCRM whitepaper of the same name written by Sara Weiner, Croom Lawrence, and Carlen Lea Lesser that provides guidance for digital marketing after ...

Executive summary presentation I developed for the RTCRM whitepaper of the same name written by Sara Weiner, Croom Lawrence, and Carlen Lea Lesser that provides guidance for digital marketing after the 14 simultaneous warning letters the FDA issued in April 2009 to pharmaceutical companies in regards to their Google Ads. The impact of these warning letters goes far beyond PPC ads, and ideas on how to deal with this new regulation are outlined in the presentation and more deeply in the whitepaper (http://www.rtcrm.com/whitepapers).

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An Eye On Google, Executive Summary Presentation An Eye On Google, Executive Summary Presentation Presentation Transcript

  • Executive Summary An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 5/5/2009
  • Agenda  Overview  14 Warning Letters Issued by FDA in One Day  What the FDA Said  Black Box vs. Non–Black Box  Google Search Ad Specifications  One-Click Rule  Search Ad Copy Risk Evaluation  Google Exception to Avoid  Implications Beyond Search Ads  Why Invest in Rich Media?  Summary  More Information proprietary and confidential 2
  • Overview  The FDA has warned that paid search copy without safety information creates a misleading experience for patients, establishing a precedent of concern about all digital tactics  For paid search, the issue is primarily in the functionality and logistics of the search engine technology  There are best practices in paid search that can protect your pharmaceutical brand from noncompliance  The One-Click Rule may still apply in some scenarios  Rich media banners are the best approach for materializing a patient’s digital experience alongside safety information proprietary and confidential 3
  • 14 Warning Letters Issued by FDA in One Day “Fail to communicate any risk” Source: U.S. Food and Drug Administration, Center for Drug Evaluation and Research. “Warning Letters and Untitled Letters to Pharmaceutical Companies 2009.” (April 2009) http://www.fda.gov/cder/warn/warn2009.htm proprietary and confidential 4
  • What the FDA Said For promotional materials to be truthful and non- misleading, they must contain risk information in each part as necessary to qualify any representations and/or suggestions made in that part about the drug. (Biogen/Tysabri letter) Source: U.S. Food and Drug Administration, Center for Drug Evaluation and Research. “Warning Letters and Untitled Letters to Pharmaceutical Companies 2009.” (April 2009) http://www.fda.gov/cder/warn/warn2009.htm proprietary and confidential 5
  • Black Box vs. Non-Black Box Boxed Warning No Boxed Warning Source: U.S. Food and Drug Administration, Center for Drug Evaluation and Research. “Warning Letters and Untitled Letters to Pharmaceutical Companies 2009.” (April 2009) http://www.fda.gov/cder/warn/warn2009.htm proprietary and confidential 6
  • Google Search Ad Specifications  Text only  Total of 95 characters maximum, including spaces  Headline: maximum of 25 characters, including spaces  2 description lines: maximum of 35 characters, including spaces  Destination URL 25 Character Headline 35 Characters for the second line 35 Characters for the third line www.DestinationURL.com Sample Character Counts: 1st line is 22 chars, 2nd line is 33 chars, 3rd line is 32 chars No Ability to Include Fair Balance in Ad proprietary and confidential 7
  • One-Click Rule  General “rule” is to provide safety information within one click from the ad  Interpretted for text ads as allowing Fair Balance to reside on destination website  No formal FDA guidance until April 2009  Guidance appears to state Fair Balance must appear in actual branded ad  One click to website for Fair Balance no longer acceptable proprietary and confidential 8
  • Search Ad Copy Risk Evaluation Search Ad Copy Risk Evaluation Risk Keyword Query Sample Ad Copy Landing Page Issue • Similar to accepted reminder ads Brand Official Site • Not permitted for Black Box brands Full Generic Molecule. Low Brand www.brand.com • Safety information should be on landing page (one click) Safety Information Here. • Requires legal approval on case-by-case basis www.Brand.com Osteoporosis Management • Similar to accepted help-seeking ads Osteorporosis Learn Tips and Get Support to Help • Requires legal approval on case-by-case basis Low www.unbranded.com Manage Your Osteoporosis management • No safety information needed www.unbranded.com Brand Official Site • Acknowledges risks, but doesn’t provide material up front Learn About Benefits and Risks of • Safety information should be on landing page (one click) Mid Brand www.brand.com Treating Osteoporosis with Brand • Requires legal approval on case-by-case basis www.Brand.com • Unbranded to branded material, similar to regulated product Brand Official Site claim ads • Misleading indication experience for unbranded keyword Osteorporosis Full Generic Molecule High www.brand.com Safety Information Here search management • Need safety information available www.Brand.com • FDA letters warned against this Osteoporosis Management • Unbranded to branded material, similar to regulated Learn Tips and Get Support to Osteorporosis product claim ads High Help www.brand.com • Misleading landing page for unbranded keyword search management Manage Your Osteoporosis • FDA letters warned against this www.Brand.com • Unbranded to branded material, similar to regulated Osteoporosis Management Osteorporosis Learn Tips and Get Support to Help product claim ads High www.brand.com • Misleading display URL for unbranded keyword search Manage Your Osteoporosis management • FDA likely to warn against in future www.healthybones.com proprietary and confidential 9
  • The Google Exception to Avoid  Pharma is the only industry allowed to have “deceptive” domain name in an ad  All other industries are required to show actual destination domain name. Osteoporosis Learn about healthy bones www.brand.com and understanding your risks www.healthybones.com Unbranded Ad  Branded Landing Page = Non-Compliant proprietary and confidential 10
  • Implications Beyond Search Ads Digital Media Risk Evaluation Risk Tactic Issue Recommendation Revisit idea of including “risks” in titles and descriptions to Technical function of organic Low Organic Search search leaves some copy out of meet FDA compliance. Work closely with SEO agency to marketer’s control. implement pharmaceutical principles. Best option for creating Follow best copy practices and include safety information comprehensive and explanatory in its own panel. Use rich media as a microsite Low Rich Media Banners patient experience. Plenty of room experience to promote both branded and unbranded to include safety information upon content. first exposure. Short ad copy requirements result Continue with unbranded search keywords and copy, but Mid Paid Search in mandatory click-through to view maintain best practices. Review branded copy on case- safety information. by-case basis with legal team. Similar to paid search. Lack of Follow similar best practices for paid search and space for safety information in concentrate on unbranded copy to unbranded website. High Banners banner creates need for click- Option to include multiple click tags within banners to through to website. provide safety information upon exposure. Inability for proactive control of Continue with content targeting, but actively monitor contextual material that appears distribution reports. Use very generic and conservative High Contextual Targeting next to your ad may create copy. Unbranded would be best approach. Branded not misleading experience for patient. generally recommended. No Black Box. proprietary and confidential 11
  • Why Invest in Rich Media?  Better engagement opportunities  Better ad awareness  Immediate data capture  Better message recall  Integrated Fair Balance Rich media increases ad awareness Rich media increases message for all industries association for many industries Message Association Online Ad Awareness 13.5 GIF/JPG 11.2 10.1 9.4 9.5 Rich Media Above Control Above Control 8.5 Average Delta Average Delta 7.7 7.4 7.1 7.0 6.5 6.9 6.1 6.3 6.2 5.5 5.4 5.5 5.1 4.9 4.6 4.9 4.8 3.9 3.7 4.1 4.4 4.2 4.3 3.8 3.5 1.0 Auto CPG Elec. Ent. Fin. Pharma Tech Trav. Auto CPG Elec. Ent. Fin. Pharma Tech Trav. Svcs. . Svcs. . Source: Dynamic Logic MarketNorms, Q2 2005; Delta equals Exposed minus Control; Note – Electronics and Travel contain fewer than 30 campaigns for GIF/JPG proprietary and confidential 12
  • Summary 1. FDA warned 14 pharmaceutical companies in one day that dozens of brands’ PPC ads were “misleading” and lacked “risk” information 2. Majority of brands implicated did not have Boxed Warnings 3. Risk information must be included in search ads, One-Click Rule is no longer operative 4. Google’s “pharma exception” is to be avoided, as it is not in compliance with unbranded-to-branded regulations 5. Implications are beyond text ads. New guidance must be considered with banner ads and organic search 6. Rich Media offers the best branded opportunity for digital media both in ROI and compliance with FDA regulations proprietary and confidential 13
  • More Information  This presentation is a summary of the RTCRM white paper An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings written by Sara Weiner with contributions from Croom Lawrence and Carlen Lea Lesser.  Download the complete white paper at www.rtcrm.com/whitepapers or request a copy from your RTCRM account manager. proprietary and confidential 14