The document discusses the establishment of a cross-functional digital media council within companies to develop policies and best practices for digital and social media engagement. It emphasizes the importance of collaboration among various departments such as marketing, legal, and public relations to create a cohesive digital strategy while addressing regulatory guidelines. Additionally, it highlights the growing role of digital media influencers and social media applications in pharmaceutical communications and marketing strategies.

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
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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
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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
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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.
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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
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