Keeping council

Digital and social media don’t fit neatly into one discipline – and this has become a real headache for many companies. As social media evolves, PR, marketing, corporate communications, and public affairs roles continue to blur. To achieve consensus, many companies have created internal councils to address key digital and social media issues. 

The role of digital and social media in healthcare marketing and communications is rapidly evolving.  With the advent of self-publishing technologies and the expansion of mobile connectivity, digital and social media have empowered the masses to communicate around the globe within seconds. Healthcare providers, patients, caregivers, advocacy groups, pharmaceutical, biotech, and medical device companies have become increasingly active in emerging digital channels such as social networks, online communities, blogs, and various audio/video sharing sites. 

As a result of this transformation PR, marketing, corporate communication, and public affairs roles are beginning to blur, causing a need for a redefinition of roles, responsibilities and accountability. As such, what companies need most of all is a framework for communicating in the digital age, from establishing guidance and educating employees, to assigning responsibilities and addressing legal issues.
 
Creating a council
The first challenge in developing guidance and evolving current policies for digital and social media programming is determining who is the “go to” person in the PR, marketing, and corporate communications departments who will help define who owns what when it comes to communicating in the digital channels. Once this role is identified, there should be agreement on the digital landscape so that when programs are presented to legal there is consistency in how each communications and marketing discipline will work within US Food and Drug Administration (FDA) regulatory guidelines. 

In order to achieve consensus, many companies create internal councils to address questions regarding digital and social media activities. These councils often include key representatives from regulatory, legal, safety, marketing, and corporate relations to develop standard operating procedures and policies.

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 (eg, creating internal Wikis or social networks) or external (eg, podcasting, outreach to digital media influencers or launching social network pages). 

Having a clear picture of what digital initiatives are taking place within the company can help shape the council’s perspective on policies and procedures, especially if legal or regulatory have already approved some programs.

Who owns what?
We’re all bewildered by the many terms used in the online world including: “social media,” “digital media,” “Web 2.0,” and/or “social networking”. It would be great if there was one term that could extend the current definition of “online” or “interactive” communications, such as “new media”, but that doesn’t help to clarify who owns what and what the barriers are from an FDA standpoint. For example, does e-marketing own all “online” or does PR and corporate communications have a responsibility? What are the legal and regulatory guidelines for each?

Here’s a general example on how to bucket digital and social media. Digital media influencers fall into five categories: blogs and online news (CNN.com); search and reference (Google,  Wikipedia, Yahoo!); online communities (Sermo, AskMen.com, iVillage); social networks (Facebook, YouTube, flickr), mobile (iPhone).

Social media applications too fall into five categories: widgets; syndication and micro blogging (RSS); ranking (recommendations, comments, active tags); mash ups, chat and networking;  audio/video/images (slideshare).

Digital and social media don’t fit neatly into one discipline, and this has proven to be a roadblock for many companies.  Is it PR/corporate communications, marketing, advertising, customer service or IT?  In some organizations, everyone is doing it, and there is no integrated strategy.  In other organizations, no one is doing it, because of perceived “legal” ramifications or lack of clarity as to who is responsible.  Additionally, many companies that are ready to get started still struggle with fundamental resource issues, such as sufficient “head count” to drive social media programs, the right kind of talent, and the appropriate role for agency partners.

The council can help to reorganize and align internal disciplines to implement digital and social media programs successfully. In general, PR, corporate communications and public affairs professionals are responsible for building relationships with digital media influencers and may engage with influencers to correct inaccurate information, generate awareness, build community, increase thought leadership, prepare for a crisis, and/or communicate news that will result in earned media placements.

Marketing professionals are creating content using social media applications for the purpose of brand and/or company communications, targeting and aggregating key audiences around a brand or disease awareness. This activity is usually done using paid media and requires a greater level of direct-to-consumer (DTC) scrutiny.

Policies and procedures
Once the landscape is defined, the council will evaluate, update or create policies and procedures, and disseminate insights to each of the brand’s communications groups (PR, branding, online marketing, etc…). Understanding official corporate digital and social media policies will help the review process for any new program.

Below are several US examples:

Adverse events – The number-one concern among pharma companies are the complexities involved with discovering adverse events (AEs) and reporting them to the FDA. There are many tools and methodologies for monitoring digital channels, but about 90 percent of the time adverse events discovered online do not meet the FDA’s criteria for a “reportable adverse event”, including:

• an identifiable reporter
• identifiable patient
• identifiable drug
• an identifiable adverse event.

The reality is most pharma companies are monitoring for market intelligence, issues management and media relations purposes.

Fair balance – The FDA has established clear guidance for DTC promotion and applying fair balance to marketing and advertising programs to ensure the public receives information about a drug’s safety and efficacy profile and not off-label uses. Even non-branded activities could easily be perceived as branded by the FDA, especially if the drug is the only one on the market.

Privacy – Fair balance and AEs are often the first roadblocks to digital health initiatives, but privacy is actually a bigger concern. Many PR and marketing professionals, as well as consumers, ignore the “terms and conditions” of a public website. More often than not, those terms clearly state manufacturers are not allowed to engage in community forums, chats or discussion boards. But what about monitoring? Consumer/patient privacy is less of an issue if the site is a public forum where members voluntarily provide their private information, but not on closed or password-protected sites.

Trademark and copyright protection – This is one of the most basic legal issues associated with online content, but it is often forgotten or unclear as to who owns consumer-generated media. The definition of what exactly “fair use” means is hotly debated and remains a poignant issue in a digital age where takedown notices and copyright infringement may discourage creativity. When using existing online content, there are rules that companies must adhere to per Fair Use legislation and other copyright statutes. In the meantime, always remember trademarks and copyright on images, photos, music, and art must be licensed or pre-authorized by the owner.

Transparency – Practices designed to deceive people about the involvement of marketers via online communication call into question the issue of transparency. This includes paying key opinion leaders or patient advocates to promote therapies online without disclosing that they have been asked to represent the company, using fake identities to impersonate consumers, anonymously posting information on blogs and message boards, disobeying rules established by individual communities, spam link-building, etc.  Many marketers have attempted stealth marketing in the past and have been caught. Aspects of transparent communications include:

• Clearly identifying who you represent
• Being truthful and non-misleading
• Responding based on factual data or an established point of view consistent with approved labeling.

Ongoing participation
While establishing policies and procedures is critical to the success of pharma companies moving forward, it is equally important for a council to meet on a regular basis (monthly or quarterly) to re-evaluate the current environment and determine if policy and procedure updates are needed. These ongoing meetings will also provide the council with the opportunity to review newly developed and implemented initiatives related to digital and social media communications. This allows all council members and their respective departments to be aware of what others in the company are doing.

Continued participation by the council in managing digital and social media policies and procedures will help ensure (1) that the company has its finger on the pulse of the rapidly evolving digital and social media environment, and (2) it is potentially ahead of its competition regarding how it manages communications efforts in this space.

Similarly, the Federal Healthcare Reform Law includes “Sunshine Reporting Provisions” which apply to payments or gifts to physicians valued over $10. Reports are due in March 2013: it will be interesting to see how lessons learned at state level – and communications challenges, perhaps even scandals – will be reconciled on a more national scale later on.  At issue are once-common business relationships that will now face close scrutiny in their public perceptions.

With all these initiatives, medtech companies will need to be prepared with communications strategies focused on growth drivers as well as being armed with strong messaging against potential business problems should there be pitfalls that lay ahead. 

The Author
Cohne & Wolfe Digital Team – a dedicated  global team of experts who develop award-winning social media programs