Updated deck with 2018 ABPI data on UK breaches to the code of practice by Pharma and how much of role did digital play? One of Pharma's biggest fears when it comes to adopting digital and new technology, is fear of regulations and compliance. To see how much of an issue this really is, breaches of the ABPI code of practice were analyzed over 2017 & 2016, across all channels. The results are interesting...

1. Its 2018…Should Pharma
still be scared of Digital?
Gary Monk
January 16th 2018
2019
(Short Answer=NO)
February 1st 2019
Annotated to include 2018 ABPI data

2. Introduction
• The biggest barrier to digital adoption in Pharma is
‘Regulatory, legal and health care compliance
issues'
• How grounded in reality is this fear? When Pharma
'do digital' do things go wrong? And if so why?
• To answer the above I analyzed almost 80 breaches of
the UK ABPI code of practice, adjudicated by the
PMCPA over the last 2 years, identifying the type of
breach and the ‘guilty’ marketing channel
*
*80 in 2016 & 2017. In 2018 there were only 17 recorded breaches

3. Number of breaches
11
2
3
2
8
22
During 2016 and 2017
39 Pharma companies breached the code.
Most companies had only one breach but
there are a few ‘repeat offenders’ with one
company having seven
One
Two
Three
Four
Five
Six
Seven
Number of companies per volume of breaches
In 2018, 14 companies breached the code
Multiple offenders were Astra Zeneca (3) and Daiichi-Sankyo (2)

4. Email
30%
Website
30%
Online Journal
13%
Online Advert
13%
Ipad Detail
3%
Social Media
7%
Electronic Exhibition advert
3%
Sales Management
22%
Sales Force
20%
Representative item
2%
Printed Promo Materials
20%
Print Magazine
2%
Print Journal
15%
Patient Leaflet
2%
Letter
4%
Meeting
13%
Of all cases 61% were Non-Digital versus
39% Digital
Digital (39%) Non-Digital (61%)
60% of all digital cases were related to
either Email or Website breaches
55% of all non-digital cases were related to
the sales or in person meeting channels
In 2018, 75% were Non-Digital versus 25% Digital
100% of 2018 Digital Breaches (4) related to websites
combined 2016 & 2017

5. Representative conduct
3%
Promotion to the public
5%
Promotion outside of licence
3%
Poor Quality
1%
No email permissions
1%
Not correctly certified
4%
Outdated Information
5%
Missing information
5%
Misleading information
58%
High call rate targets
5%
Excessive Hospitality
4%
Disparaging competitor
3%
Behaviour of 3rd party consultant
3%
Regardless of channel, digital or non-digital
the biggest issue was misleading information
58% of all cases were related to the provision of
misleading information, when adding outdated
or not correctly certified information this number
hits 72%
A similar picture in 2018: 88% of cases
were related to misleading information

6. Other Reasons
33%
Misleading information
67%
Misleading information is a major issue
across digital and non-digital
There was no evidence in the case reports that
the higher percentage of misleading information
in ‘digital’ breaches is to do with the complexity
of digital, e.g. less space, differing formats etc
Digital Non-Digital
Other Reasons
48%
Misleading information
52%
83% of Non-Digital
cases were for
misleading
information in 2018
100% of Digital cases
were for misleading
information in 2018
2016 & 2017

7. All Other Channels
97%
Social Media
3%
Social Media breaches have almost
unicorn status
Social media is one of the most feared digital channels yet there were
minimal breaches related to it over the time period. These breaches were
not even due to active use, rather a 3rd party placing assets without
permission on video sharing sites
Breaches related to social media
Yep in 2018 ZERO
breaches related to
Social Media

8. Non-Digital Breaches
69%
Digital Breaches
31%
The % of digital breaches almost doubled in
2017 vs 2016
This is interesting but probably not that relevant or statistically
significant. Again the biggest issue Pharma face is not Digital
versus Non-Digital but ensuring their internal processes and
culture lead to the right information being shared!
2016 2017
Non-Digital Breaches
41%
Digital Breaches
59%
2 data points don’t make a trend - only 25% of breaches were digital in 2018
Yep - I am
standing by this!

9. Summary
• Digital channels are not the problem, it is Pharma
internal processes and culture that lead to the
dissemination of misinformation, regardless of the
medium used.
Ditto this year! (for 2018) Interesting all Digital Breaches were for plain ole websites.
Often Pharma ties itself in knots when innovating, with fear of non-compliance. There is
zero evidence, from this data anyway, that increased innovation increases risk of non-
compliance

10. Don’t be scared, say hello!
@garymonk
linkedin.com/in/garywmonk/