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Establishing                           networks) or external (e.g.
                                       podcasting, building relationships
                                                                                within the company can help
                                                                                shape the council’s perspective on

Guidance
                                       with digital media influencers           what policies and procedures need
                                       through media outreach, YouTube          to be developed and where there
                                       channels, etc.). Representatives of      are opportunities to be more
                                       the council will also learn that there   efficient and save money.
Early adopters tend to “own” digital   may be a number of areas overlap.
and social media and are usually       For example, marketing, corporate
the first to launch pilot programs     communications and public                Finally, there should be
that are based on trial and error.     relations are all conducting monitor     agreement on the digital
Successful companies work to           audits to capture conversations          landscape so that when programs
develop a cross-functional digital     online and there are multiple            are presented to legal, there is
media council that establishes one     agencies conducting the same             consistency in how each
set of policies and standards that     audits with different outcomes.          communications and marketing
are based on innovative best                                                    discipline will work within U.S.
practices and the law.                 Having a clear picture of what           Federal Drug Administration (FDA)
                                       digital initiatives are taking place     regulatory guidelines.
In order to achieve consensus on
policies and best practices, the
first objective is to appoint a key
representative from each
discipline to be a member of the
                                       Defining the Landscape
council. There should be at least
one representative from
regulatory, legal, safety,             It’s easy to become bewildered by the many terms used in the
marketing, public relations,           online world including: “social media,” “digital media,” “Web
human resources and corporate          2.0,” and/or “social networking.” It would be great if there was
communications involved in the         one term that could extend the current definition of “online”
council. The representative is
                                       or “interactive” communications, such as “new media.”Here’s
usually a person who is
passionate about the company           a general example on how to bucket digital and social media.
and its products; knowledgeable
about the company’s internal
culture, structure and politics;                          Digital Media Channels
and is a senior executive.

The purpose of the council is to
evaluate current digital and social
media policies, procedures,
responsibilities and programming,
with the end goal of identifying
gaps and creating a plan of action
that will evolve over time.
                                                        Social Media Applications
Council meetings are usually the
first opportunity for each
department representative to learn
what others are doing. More often
than not, companies as a whole are
doing more than they would have
anticipated, be it internal (e.g.
creating internal Wikis or social



                                                        [2]
Clarifying Roles &                         and social media programs
                                           successfully. In general, public
                                                                                 leader in a specific disease
                                                                                 category who has very little traffic,

Responsibilities
                                           relations, corporate                  inbound/outbound links, or views
                                           communications and public affairs     to his or her site, but recognized by
                                           professionals are responsible for     the industry as influential.
Digital and social media doesn’t fit       building relationships with digital
neatly into one discipline, and this       media influencers and may engage      Marketing professionals are creating
has proven to be a roadblock for           with influencers to correct           content using social media
many companies. Is it                      inaccurate information, generate      applications for the purpose of brand
PR/corporate communications,               awareness, build community,           and/or company communications,
marketing, advertising, customer           increase thought leadership,          targeting and aggregating key
service or IT? In some                     prepare for a crisis, and/or          audiences around a brand or disease
organizations, everyone is doing it,       communicate news that will result     awareness. This activity is usually
and there is no integrated strategy.       in earned media placements.           done using unearned media and
In other organizations, no one is                                                requires a greater level of Direct to
doing it because of perceived              Prior to engaging a digital           Consumer (DTC) regulatory scrutiny.
“legal” ramifications or lack of           influencer, most pharmaceutical
clarity as to who is responsible.          companies understand they need        There are many areas where all
Additionally, many companies that          to establish qualitative and          disciplines collide. One of the most
are ready to get started still             quantitative metrics to determine     important is search. According to
struggle with fundamental                  influence. For example, a reporter    Forrester, 81 percent of the people
resource issues, such as sufficient        such as Tara Parker-Pope with         going online for healthcare
“head count” to drive social media         The New York Times is a journalist    information are starting their
programs, the right kind of talent,        with the necessary credentials,       experience at a search engine.
and the appropriate role for               and understanding the editorial       Influencer sites often appear in the
agency partners.                           process, she also meets the           top organic search results of sites
                                           quantitative influencer metrics       such as Google, Yahoo and Live
The council can help with                  established by sites like the         Search and that is why it’s
reorganizing and aligning internal         Healthcare 100. A qualitative         important to be part of the
disciplines to implement digital           influencer may be a key opinion       editorial content. What’s equally
                                                                                 important is how your brand or
                                                                                 company appears in the vertical
                                                                                 search results on reference sites
                                                                                 such as Wikipedia and WebMD.

                                                                                 There are many ways public
                                                                                 relations, corporate
                                                                                 communications and marketing
                                                                                 can collaborate by sharing search
                                                                                 activities such as:
                                                                                   • Monthly rankings report
                                                                                   • Trends for all key phrases on
                                                                                     the top search engines
                                                                                   • Search engine listing
                                                                                     significant gains and losses
                                                                                   • Search engine optimization
                                                                                     and marketing initiatives
                                                                                   • Keywords for messaging
        Tara Parker-Pope’s Well Blog within the New York Times website.            • Multimedia press releases
                                                                                   • Social media tagging




                                                              [3]
Addressing                             about a drug’s safety and efficacy
                                       profile and not off-label uses. It’s
                                                                               infringement may discourage
                                                                               creativity. When using existing

Legal Issues                           important to remember that even
                                       non-branded activities could
                                                                               online content, there are several
                                                                               rules that companies must
                                       easily be perceived as branded by       adhere to per Fair Use
Understanding the official             the FDA, especially if the drug is      legislation and other copyright
corporate digital and social media     the only one on the market for a
policies will help the review                                                  statutes. In the meantime,
                                       very specific treatment.
process for any new program.                                                   always remember trademarks
Below are several U.S. examples                                                and copyright on images, photos,
                                      • Privacy – AEs are often the first
that guidance should address.           roadblocks to digital health           music, and art must be licensed
                                        initiatives, but privacy should        or pre-authorized by the owner.
• Adverse Events – The                  actually be a bigger concern.
  number one concern among              Many PR and marketing                 • Transparency – Practices
  pharmaceutical companies are          professionals, as well as               designed to deceive people about
  the complexities involved with        consumers, ignore the “terms            the involvement of marketers via
  discovering adverse events            and conditions” of a public Web         online communication calls into
  (AEs) and reporting them to the       site. More often than not, those        question the issue of transparency.
  FDA. There are many tools and         terms clearly state                     This includes paying key opinion
  methodologies for monitoring          manufacturers are not allowed           leaders or patient advocates to
  the digital channels, but about       to engage in community forums,          promote therapies online without
  90% of the time adverse               chats or discussion boards. But         disclosing that they have been
  events discovered online do           what about monitoring?                  asked to represent the company,
  not meet the FDA’s criteria           Consumer/patient privacy is less        using fake identities to
  for a “reportable adverse             of an issue if the site is a public     impersonate consumers,
  event,” including:                    forum where members                     anonymously posting information
  - An identifiable reporter            voluntarily provide their private       on blogs and message boards,
  - Identifiable patient                information, but not on closed or       disobeying rules established by
  - Identifiable drug                   password-protected sites.               individual communities, spam
  - An identifiable adverse event                                               link-building, etc. Many marketers
The reality is most pharmaceutical    • Trademark and Copyright                 have attempted stealth marketing
companies are successfully              Protection – This is one of the         in the past and have been caught.
monitoring for market intelligence,     most basic legal issues                 Aspects of transparent
issues management and media             associated with online content,         communications include:
relations purposes.                     but it is often forgotten or             - Clearly identifying who
                                        unclear as to who owns                     you represent
• Fair Balance – The FDA has            consumer-generated media. The            - Being truthful and
  established clear guidance for        definition of what exactly “Fair           non-misleading
  DTC promotion and applying fair       Use” means is hotly debated and          - Responding based on factual
  balance to marketing and              remains a poignant issue in a              data or an established point of
  advertising programs to ensure        digital age where takedown                 view that is consistent with the
  the public receives information       notices and copyright                      products approved labeling




                                                      [4]
Best Practices
Pharmaceutical companies are
actively engaging in healthy
communications and marketing
activities that include reaching out
to digital media influencers and
using social media applications. In
fact, the FDA now recognizes the
value of social media applications
for sharing information quickly in
times of crisis. The FDA’s             A number of pharmaceutical              decline and layoffs increase as a
communication office, in               companies are also increasingly         result of the recession. There are
collaboration with the Centers for     warming up to the idea of sharing       many examples of influential
                                       information with influential            health bloggers who were affected
Disease Control (CDC), created a
                                       bloggers who are specifically           by the transformation of media
blog to jointly address the peanut
                                       associated with mainstream media        including Ed Silverman, who made
product recall. In addition, the FDA
                                       publications. Approaching a             his mark on the pharmaceutical
developed a widget so that             blogger who is not part of a            industry by sharing whistle blower
consumers could syndicate news         mainstream publishing company           stories submitted to his Pharmalot
to their own sites. Finally, the FDA   delivers less of a feeling of control   blog, formerly owned by The Star-
created a Twitter profile to keep      for pharmaceutical companies            Ledger of New Jersey.
consumers up-to-date on the            since the blogger is not
Salmonella crisis.                     as likely to have an
                                       understanding of the
Pharmaceutical companies are           legal issues associated
also recognizing the value of social   with healthcare
media applications such as RSS         communications or any
(Real Simple Syndication), tagging,    kind of an editorial filter.
mobile and Twitter. For example,       There are, however, more
AstraZeneca and Novartis have          and more mainstream
                                       media reporters who are
Twitter profiles, GSK includes
                                       making their way to the
tagging and syndication on its
                                       blogosphere. This trend
corporate site, and Bayer offers its
                                       is only going to increase
corporate communications news          as the publishing
in mobile format.                      industry continues to


                                                                               These “independent” influencers
                                                                               are credible and carry weight, and
                                                                               as a consequence, the public
                                                                               relations and corporate
                                                                               communications executive shouldn’t
                                                                               rule them out just because they
                                                                               aren’t employed by a mainstream
                                                                               publication. Instead, each
                                                                               influencer needs to be assessed on
                                                                               a case by case basis to determine if
                                                                               engagement is possible.



                                                       [5]
Public relations and corporate         blog by establishing policies for      support consumers using its weight
communications professionals are       accepting and posting comments,        loss product, alli. In this case, the
also becoming more engaged in          addressing the rules about no          effort was lead by marketing and
responding to inquiries from blog      product mentions on the blog, and      they were able to gain approval by
reporters and correcting               by creating an accelerated internal    demonstrating small success over
inaccurate blog posts. The key to      process for issues management.         many pilot programs. In addition,
doing this most effectively is to      Motivated by the success of its        they established a process for
focus on those blogs deemed to be      parent company’s endeavor, J&J         monitoring and managing
the most influential and relevant to   subsidiary Centocor has also begun     potential issues, such as adverse
their disease category. Lilly, for     its own corporate blog, nto411.com.    events, on the community forums.
instance, has been quite active in
sharing product news with              Contrary to popular belief, J&J        More and more pharmaceutical
influential diabetes patient           was not the first healthcare           companies are creating groups in
bloggers like Amy Tenderich of         company to establish a blog. GSK’s     social networks for human
diabetesmine.com. In fact, the         corporate communications in            resources and recruiting purposes,
Diabetes Mine blog is no longer        France actually launched a blog        as well as for disease awareness
feared by pharmaceutical               back in 2006. Since then, GSK has      and branding. For example,
companies and everyone from            launched multiple digital and          Merck created a cervical cancer
Merck to GSK is advertising their      social media activities including an   group in Facebook, while
diabetes treatments on her blog.       online community and blog to           AstraZeneca created a branded
                                                                              SYMBICORT channel on YouTube
                                                                              for asthma sufferers.

                                                                              Mainstream media has recognized
                                                                              that if you can’t beat them, join
                                                                              them. For example, The New York
                                                                              Times has a presence in social
                                                                              networks such as YouTube, Facebook,
                                                                              and iTunes. By working with The New
                                                                              York Times editorial within their
                                                                              social networking presence,
                                                                              pharmaceutical companies have a
                                                                              more controlled environment for
                                                                              engaging. An example would be
                                                                              reaching reporters on The New York
                                                                              Times channel on YouTube rather
                                                                              than posting video on YouTube alone.

Finally, some companies are
venturing into the space in a more
aggressive way and creating their
own corporate communication(s)
blogs. Johnson & Johnson has
received a great deal of attention
for JNJ BTW, a corporate blog in
which there is “talk about Johnson
& Johnson — what we are doing,
how we are doing it and why.”
Mark Monseau, Director of JNJ
corporate communications, spoke
at the Health 2.0 conference about
how J&J was able to deploy the



                                                       [6]

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Diagnosing Digital White Paper

  • 1. Establishing networks) or external (e.g. podcasting, building relationships within the company can help shape the council’s perspective on Guidance with digital media influencers what policies and procedures need through media outreach, YouTube to be developed and where there channels, etc.). Representatives of are opportunities to be more the council will also learn that there efficient and save money. Early adopters tend to “own” digital may be a number of areas overlap. and social media and are usually For example, marketing, corporate the first to launch pilot programs communications and public Finally, there should be that are based on trial and error. relations are all conducting monitor agreement on the digital Successful companies work to audits to capture conversations landscape so that when programs develop a cross-functional digital online and there are multiple are presented to legal, there is media council that establishes one agencies conducting the same consistency in how each set of policies and standards that audits with different outcomes. communications and marketing are based on innovative best discipline will work within U.S. practices and the law. Having a clear picture of what Federal Drug Administration (FDA) digital initiatives are taking place regulatory guidelines. In order to achieve consensus on policies and best practices, the first objective is to appoint a key representative from each discipline to be a member of the Defining the Landscape council. There should be at least one representative from regulatory, legal, safety, It’s easy to become bewildered by the many terms used in the marketing, public relations, online world including: “social media,” “digital media,” “Web human resources and corporate 2.0,” and/or “social networking.” It would be great if there was communications involved in the one term that could extend the current definition of “online” council. The representative is or “interactive” communications, such as “new media.”Here’s usually a person who is passionate about the company a general example on how to bucket digital and social media. and its products; knowledgeable about the company’s internal culture, structure and politics; Digital Media Channels and is a senior executive. The purpose of the council is to evaluate current digital and social media policies, procedures, responsibilities and programming, with the end goal of identifying gaps and creating a plan of action that will evolve over time. Social Media Applications Council meetings are usually the first opportunity for each department representative to learn what others are doing. More often than not, companies as a whole are doing more than they would have anticipated, be it internal (e.g. creating internal Wikis or social [2]
  • 2. Clarifying Roles & and social media programs successfully. In general, public leader in a specific disease category who has very little traffic, Responsibilities relations, corporate inbound/outbound links, or views communications and public affairs to his or her site, but recognized by professionals are responsible for the industry as influential. Digital and social media doesn’t fit building relationships with digital neatly into one discipline, and this media influencers and may engage Marketing professionals are creating has proven to be a roadblock for with influencers to correct content using social media many companies. Is it inaccurate information, generate applications for the purpose of brand PR/corporate communications, awareness, build community, and/or company communications, marketing, advertising, customer increase thought leadership, targeting and aggregating key service or IT? In some prepare for a crisis, and/or audiences around a brand or disease organizations, everyone is doing it, communicate news that will result awareness. This activity is usually and there is no integrated strategy. in earned media placements. done using unearned media and In other organizations, no one is requires a greater level of Direct to doing it because of perceived Prior to engaging a digital Consumer (DTC) regulatory scrutiny. “legal” ramifications or lack of influencer, most pharmaceutical clarity as to who is responsible. companies understand they need There are many areas where all Additionally, many companies that to establish qualitative and disciplines collide. One of the most are ready to get started still quantitative metrics to determine important is search. According to struggle with fundamental influence. For example, a reporter Forrester, 81 percent of the people resource issues, such as sufficient such as Tara Parker-Pope with going online for healthcare “head count” to drive social media The New York Times is a journalist information are starting their programs, the right kind of talent, with the necessary credentials, experience at a search engine. and the appropriate role for and understanding the editorial Influencer sites often appear in the agency partners. process, she also meets the top organic search results of sites quantitative influencer metrics such as Google, Yahoo and Live The council can help with established by sites like the Search and that is why it’s reorganizing and aligning internal Healthcare 100. A qualitative important to be part of the disciplines to implement digital influencer may be a key opinion editorial content. What’s equally important is how your brand or company appears in the vertical search results on reference sites such as Wikipedia and WebMD. There are many ways public relations, corporate communications and marketing can collaborate by sharing search activities such as: • Monthly rankings report • Trends for all key phrases on the top search engines • Search engine listing significant gains and losses • Search engine optimization and marketing initiatives • Keywords for messaging Tara Parker-Pope’s Well Blog within the New York Times website. • Multimedia press releases • Social media tagging [3]
  • 3. Addressing about a drug’s safety and efficacy profile and not off-label uses. It’s infringement may discourage creativity. When using existing Legal Issues important to remember that even non-branded activities could online content, there are several rules that companies must easily be perceived as branded by adhere to per Fair Use Understanding the official the FDA, especially if the drug is legislation and other copyright corporate digital and social media the only one on the market for a policies will help the review statutes. In the meantime, very specific treatment. process for any new program. always remember trademarks Below are several U.S. examples and copyright on images, photos, • Privacy – AEs are often the first that guidance should address. roadblocks to digital health music, and art must be licensed initiatives, but privacy should or pre-authorized by the owner. • Adverse Events – The actually be a bigger concern. number one concern among Many PR and marketing • Transparency – Practices pharmaceutical companies are professionals, as well as designed to deceive people about the complexities involved with consumers, ignore the “terms the involvement of marketers via discovering adverse events and conditions” of a public Web online communication calls into (AEs) and reporting them to the site. More often than not, those question the issue of transparency. FDA. There are many tools and terms clearly state This includes paying key opinion methodologies for monitoring manufacturers are not allowed leaders or patient advocates to the digital channels, but about to engage in community forums, promote therapies online without 90% of the time adverse chats or discussion boards. But disclosing that they have been events discovered online do what about monitoring? asked to represent the company, not meet the FDA’s criteria Consumer/patient privacy is less using fake identities to for a “reportable adverse of an issue if the site is a public impersonate consumers, event,” including: forum where members anonymously posting information - An identifiable reporter voluntarily provide their private on blogs and message boards, - Identifiable patient information, but not on closed or disobeying rules established by - Identifiable drug password-protected sites. individual communities, spam - An identifiable adverse event link-building, etc. Many marketers The reality is most pharmaceutical • Trademark and Copyright have attempted stealth marketing companies are successfully Protection – This is one of the in the past and have been caught. monitoring for market intelligence, most basic legal issues Aspects of transparent issues management and media associated with online content, communications include: relations purposes. but it is often forgotten or - Clearly identifying who unclear as to who owns you represent • Fair Balance – The FDA has consumer-generated media. The - Being truthful and established clear guidance for definition of what exactly “Fair non-misleading DTC promotion and applying fair Use” means is hotly debated and - Responding based on factual balance to marketing and remains a poignant issue in a data or an established point of advertising programs to ensure digital age where takedown view that is consistent with the the public receives information notices and copyright products approved labeling [4]
  • 4. Best Practices Pharmaceutical companies are actively engaging in healthy communications and marketing activities that include reaching out to digital media influencers and using social media applications. In fact, the FDA now recognizes the value of social media applications for sharing information quickly in times of crisis. The FDA’s A number of pharmaceutical decline and layoffs increase as a communication office, in companies are also increasingly result of the recession. There are collaboration with the Centers for warming up to the idea of sharing many examples of influential information with influential health bloggers who were affected Disease Control (CDC), created a bloggers who are specifically by the transformation of media blog to jointly address the peanut associated with mainstream media including Ed Silverman, who made product recall. In addition, the FDA publications. Approaching a his mark on the pharmaceutical developed a widget so that blogger who is not part of a industry by sharing whistle blower consumers could syndicate news mainstream publishing company stories submitted to his Pharmalot to their own sites. Finally, the FDA delivers less of a feeling of control blog, formerly owned by The Star- created a Twitter profile to keep for pharmaceutical companies Ledger of New Jersey. consumers up-to-date on the since the blogger is not Salmonella crisis. as likely to have an understanding of the Pharmaceutical companies are legal issues associated also recognizing the value of social with healthcare media applications such as RSS communications or any (Real Simple Syndication), tagging, kind of an editorial filter. mobile and Twitter. For example, There are, however, more AstraZeneca and Novartis have and more mainstream media reporters who are Twitter profiles, GSK includes making their way to the tagging and syndication on its blogosphere. This trend corporate site, and Bayer offers its is only going to increase corporate communications news as the publishing in mobile format. industry continues to These “independent” influencers are credible and carry weight, and as a consequence, the public relations and corporate communications executive shouldn’t rule them out just because they aren’t employed by a mainstream publication. Instead, each influencer needs to be assessed on a case by case basis to determine if engagement is possible. [5]
  • 5. Public relations and corporate blog by establishing policies for support consumers using its weight communications professionals are accepting and posting comments, loss product, alli. In this case, the also becoming more engaged in addressing the rules about no effort was lead by marketing and responding to inquiries from blog product mentions on the blog, and they were able to gain approval by reporters and correcting by creating an accelerated internal demonstrating small success over inaccurate blog posts. The key to process for issues management. many pilot programs. In addition, doing this most effectively is to Motivated by the success of its they established a process for focus on those blogs deemed to be parent company’s endeavor, J&J monitoring and managing the most influential and relevant to subsidiary Centocor has also begun potential issues, such as adverse their disease category. Lilly, for its own corporate blog, nto411.com. events, on the community forums. instance, has been quite active in sharing product news with Contrary to popular belief, J&J More and more pharmaceutical influential diabetes patient was not the first healthcare companies are creating groups in bloggers like Amy Tenderich of company to establish a blog. GSK’s social networks for human diabetesmine.com. In fact, the corporate communications in resources and recruiting purposes, Diabetes Mine blog is no longer France actually launched a blog as well as for disease awareness feared by pharmaceutical back in 2006. Since then, GSK has and branding. For example, companies and everyone from launched multiple digital and Merck created a cervical cancer Merck to GSK is advertising their social media activities including an group in Facebook, while diabetes treatments on her blog. online community and blog to AstraZeneca created a branded SYMBICORT channel on YouTube for asthma sufferers. Mainstream media has recognized that if you can’t beat them, join them. For example, The New York Times has a presence in social networks such as YouTube, Facebook, and iTunes. By working with The New York Times editorial within their social networking presence, pharmaceutical companies have a more controlled environment for engaging. An example would be reaching reporters on The New York Times channel on YouTube rather than posting video on YouTube alone. Finally, some companies are venturing into the space in a more aggressive way and creating their own corporate communication(s) blogs. Johnson & Johnson has received a great deal of attention for JNJ BTW, a corporate blog in which there is “talk about Johnson & Johnson — what we are doing, how we are doing it and why.” Mark Monseau, Director of JNJ corporate communications, spoke at the Health 2.0 conference about how J&J was able to deploy the [6]