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FDA Presentation: How Pharma Marketers Should Use Social Media

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Presentation to the FDA Public Hearing on November 12, 2009 by Rohit Bhargava.

Presentation to the FDA Public Hearing on November 12, 2009 by Rohit Bhargava.


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  • 1. How Marketers Should Use The Internet & Social Media For Promotion Comments At The FDA Hearing Ogilvy 360 Digital Influence Rohit Bhargava, SVP http://blog.ogilvypr.com/tag/pharma November 12, 2009
  • 2.
    • One of the largest marketing and communications agencies in the world, with over 60 global offices
    • A leading social media specialty practice called 360 Digital Influence working with dozens of clients in the healthcare industry
    • Actively engaged today in helping many large and small pharmaceutical and medical device companies use social media for effective communications to patients and healthcare professionals.
    A Very Short Introduction to Ogilvy
  • 3. SEARCH Symptom & Condition Treatment Options Healthcare Providers CONVERSATION Message boards Forums Commenting COLLABORATION Bookmarking + Tagging Rating + Sharing PARTICIPATION Joining Community Online Profile/Story Answering FAQ CONTENT CREATION Blogs & Vlogs PGM (Patient Generated Media) COMMUNITY CREATION Niche Disease Communities New Social Networks Affinity Groups E-ADVOCACY Partnering New causes Health Engagement The Ogilvy point of view on how people are engaging with health information online. HEALTH SEEKERS > HEALTH SHARERS > HEALTH CHRONICLERS HEALTH PORTAL General Info Lifestyle + Disease Treatment Options
  • 4. Social media content done right empowers patients to work with their treatment providers in an informed manner.
  • 5. It can provide resources for patients with infrequently discussed rare conditions (as well as all others).
  • 6.
    • Our Point Of View:
      • There should be a simple and consistent way for determining accountability for any content online.
      • Marketers should not be held accountable for content that is not under their control or influence.
    • Our Suggested Solution:
      • Implement “The 3 C’s Rule” (details on next page)
        • Creation
        • Collaboration
        • Compensation
    What online communications should marketers be accountable for? #1 Presentation By Ogilvy PR 360 Digital Influence November 12, 2009
  • 7. The 3 C’s Rule: What Messages Posted Online Should Marketers Be Accountable For? Compensation Did the marketer fund the creation of the message or compensate the creator in any way? Collaboration Did the marketer work directly or indirectly with any third party to create the message? Creation Did the marketer create the content and has it not been altered or excerpted in any way by a third party? IF YES TO ANY 1 THEN THEY SHOULD BE ACCOUNTABLE. Presentation By Ogilvy PR 360 Digital Influence November 12, 2009
  • 8.
    • Our Point Of View:
    • The space and real time limitations of social media make it unreasonable in some online communications such as Twitter to include full fair balance, Important Safety Information alongside any branded message.
    • Including fair balance, Important Safety Information that is the online equivalent of a “turn of a page” is reasonable.
    • Our Suggested Solution:
    • The FDA should enforce the “1-click rule” – in effect ensuring the full fair balance, Important Safety Information is AT MOST one click away from any branded message.
    How can marketers fulfill regulatory requirements with space-limited social media? #2 Presentation By Ogilvy PR 360 Digital Influence November 12, 2009
  • 9.
    • Our Point Of View:
      • Marketers should not be responsible for policing any content that anyone posts online that relates to their products or brand that has not been developed by company.
      • The exception to this rule is if the content meets any of the “3 C’s Rule” explained earlier.
    • Our Suggested Solution:
      • Marketers are not responsible for posting corrective information unless they are deemed accountable for that content under the “3 C’s Rule.”
    What parameters should apply to posting corrective information on 3rd party sites? #3 Presentation By Ogilvy PR 360 Digital Influence November 12, 2009
  • 10.
    • Our Point Of View:
      • Links are the lifeblood of the Internet and brands must be allowed to link to third-party content.
      • Marketers should transparently disclose to web browsers any time they are about to leave the branded site and visit third-party content.
    • Our Suggested Solution:
      • The FDA implements a process that requires pharma brands to offer a disclaimer to third-party links and always have them open in a new browser window or tab.
    When is the use of links appropriate? #4 Presentation By Ogilvy PR 360 Digital Influence November 12, 2009
  • 11. How Marketers Should Use The Internet & Social Media For Promotion Comments At The FDA Hearing Ogilvy 360 Digital Influence Rohit Bhargava, SVP http://blog.ogilvypr.com/tag/pharma November 12, 2009
  • 12.
    • We identify and engage influencers and affinity groups to spark word of mouth about a brand or issue. We drive a new form of “earned media” by using social media strategically and adding scale and volume through integrated marketing and communications programs.
    • We use social content to change perceptions and influence behavior , telling the real story behind a brand in a complex legal and regulatory environment.
  • 13. Rohit is also the author of the best selling marketing book Personality Not Included , a guide for brands on using their personality for marketing, which is available in more than 50 countries around the world in 8 languages. For five years, he has also published the Influential Marketing blog, which is currently ranked among the top 50 marketing blogs in the world by AdAge magazine and was called "intellectual and educational" by the Wall Street Journal. Rohit teaches marketing and communications at Georgetown University in the Center for Social Impact and has been featured on the covers of PR Week UK and MarketingChina and been interviewed or featured in BusinessWeek, Inc Magazine, and Fast Company. He was also recently named one of the most influential South Asians working in media & marketing. LINKS: http://blog.ogilvypr.com/tag/pharma http://www.twitter.com/ogilvypr http://www.influentialmarketingblog.com http://www.twitter.com/rohitbhargava Rohit is a founding member of the pioneering 360 Digital Influence team at Ogilvy, and a member of the Strategy & Planning Group. He specializes in crafting social media & word of mouth marketing strategy for clients and has led recent work within the agency for some of Ogilvy’s largest healthcare and pharma clients. He is leads the Digital Health team within Ogilvy PR, a group focused on explaining and recommending the strategic use of social media for Ogilvy PR’s pharmaceutical clients. This includes defining conversation analysis tools that account for the specific consideration of adverse events, engagement strategies in a highly regulated environment and counseling brands on managing crisis with social media. Rohit Bhargava SVP, Strategy & Planning | Ogilvy PR 360 Digital Influence