fda presentation: how pharma marketers should use social media

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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

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

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Page 1: FDA Presentation: How Pharma Marketers Should Use Social Media

How Marketers Should Use The Internet & Social Media For PromotionComments At The FDA Hearing

Ogilvy 360 Digital InfluenceRohit Bhargava, SVPhttp://blog.ogilvypr.com/tag/pharma

November 12, 2009

Page 2: FDA Presentation: How Pharma Marketers Should Use Social Media

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

Page 3: FDA Presentation: How Pharma Marketers Should Use Social Media

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

HealthEngagementThe 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

Page 4: FDA Presentation: How Pharma Marketers Should Use Social Media

Social media content done right empowers patients to work with their treatment providers in an informed manner.

Page 5: FDA Presentation: How Pharma Marketers Should Use Social Media

It can provide resources for patients with infrequently discussed rare conditions (as well as all others).

Page 6: FDA Presentation: How Pharma Marketers Should Use Social Media

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 InfluenceNovember 12, 2009

Page 7: FDA Presentation: How Pharma Marketers Should Use Social Media

CompensationDid 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 1THEN THEY SHOULD BE

ACCOUNTABLE.

The 3 C’s Rule:What Messages Posted Online

Should Marketers Be Accountable For?

Presentation By Ogilvy PR 360 Digital InfluenceNovember 12, 2009

Page 8: FDA Presentation: How Pharma Marketers Should Use Social Media

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 InfluenceNovember 12, 2009

Page 9: FDA Presentation: How Pharma Marketers Should Use Social Media

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 InfluenceNovember 12, 2009

Page 10: FDA Presentation: How Pharma Marketers Should Use Social Media

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 InfluenceNovember 12, 2009

Page 11: FDA Presentation: How Pharma Marketers Should Use Social Media

How Marketers Should Use The Internet & Social Media For PromotionComments At The FDA Hearing

Ogilvy 360 Digital InfluenceRohit Bhargava, SVPhttp://blog.ogilvypr.com/tag/pharma

November 12, 2009

Page 12: FDA Presentation: How Pharma Marketers Should Use Social Media

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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.

Page 13: FDA Presentation: How Pharma Marketers Should Use Social Media

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/pharmahttp://www.twitter.com/ogilvyprhttp://www.influentialmarketingblog.comhttp://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 BhargavaSVP, Strategy & Planning | Ogilvy PR 360 Digital Influence