1. a legal decision or form of proceeding serving as an authoritative rule or pattern in future similar or analogous cases.
2. any act, decision, or case that serves as a guide orjustification for subsequent situations.
When it comes time to get your social media idea approved within your company, you’ve got a lot of people who need to sign off. It starts with your boss and probably department or brand head. Then you move to legal and regulatory folks and, ultimately, maybe even senior executives all the way up to the CEO (yes, I’ve seen this required). When you go to those conversations, you’re going to need three pieces of information that will help sell your case. Each group is going to want something a little different, so here’s what you need. You’re going to need to prove that your program:
- will have some positive impact on the brand or company
- is a better option than some other tactics you can employ
- won’t cause legal issues later on
For the sake of this post, you’re on your own for the first two and, of course, for any of these, “proving” these facts is going to be tricky if not impossible. But as you’ve probably experienced, you need to get as close to “proof” as is possible without a time machine. Depending on whose approve you seek, they’ll be interested in one or more of these three areas, so be prepared with each. For today’s post, I’m going to help you with number three (and feel free to check out my presentation “6 Steps to Getting Your Healthcare Social Media Idea Approved” for some more details).
While I can’t tell you for certain what is legal and what’s not in social media, I am going to help you by showing you a bunch of examples of companies that have come before you and haven’t gotten in trouble (yet). Of course, as investment product fine print states, past performance does not indicate future results. In other words, just because there hasn’t been any legal or regulatory issues with these programs yet, I can’t promise that there won’t ever be. Regulators can be tough to predict, as you probably know.
For the sake of this list, I figured I’d take one of the most heavily regulated and conservative industries out there and use their programs as examples to show you what precedent exists for different types of social media programs. That industry? Pharmaceuticals. Having worked with clients in financial services, spirits, and many other regulated industries, no one has quite the complex regulatory rules and systems as pharma. So, if they can do it, you should be able to as well. Your industry might be as regulated as pharma, but probably isn’t more regulated. So, this seemed like a good industry to use as the precedent.
Browse the list and look for the social media program you want to do and I’ll give you several examples and links for each where a pharma company is already doing it. If you’re looking for even more examples after you get through this, then try out the Pharma and Healthcare Social Media Wiki where you’ll find around 350 pharma and healthcare industry social media examples.
Let’s start off slow. A good place to start is with a blog. It’s a great way to create quality content that people are looking for, does wonders for search engine optimization, and is a good first step to opening a discussion with your customers. Since you can control who comments and what they comment about by pre-moderating comments before publishing, you control all the risk. Getting approval for the posts before they go live and, if necessary (but not recommended), for each comment that is published is a sure-fire way to cut your risk to almost zero. Here are a few pharma companies that are currently blogging:
JNJ BTW – Johnson & Johnson’s corporate blog
AZ Health Connections – AstraZeneca’s corporate blog
More than Medicine – GSK’s corporate blog
Think Science Now – Pfizer’s company blog focused on research and development
Okay, getting a bit more adventurous, let’s move onto YouTube. For this one, I’m talking about posting videos and having a channel. The next question is whether or not you’ll allow comments and Likes and Dislikes (yes, you should allow all of this). So, each of the precedent examples here are cases where the company allows commenting and rating AND also responds to comments. You can choose to allow less, but this is the “best case” scenario, so anything less should be less risky. If you’re looking for some advice on how to manage this channel, then check out my recent post: How One Pharma Company Successfully Manages YouTube.
Johnson & Johnson Health Channel – This is the channel housing all of J&J’s videos (which altogether have more than 2.3 million views). To get an idea of how J&J interacts with commenters, take a look at the comments and responses from J&J (jnjhealth) on this video.
Novartis Flu Flix – The J&J example should be all the precedent you need, but here’s another approach. Novartis ran a contest back in 2007 (yes, way back then) inviting people to submit their videos about the flu. The content intro video alone has had nearly 800,000 views. So, yes, you can have a user-generated video contest or program. This doesn’t mean that you necessarily should, but it’s possible. This precedent extends beyond just YouTube and shows how you can run a program like this in a compliant way.
Maybe I should have put this one first since Facebook seems to be what everyone is talking about and seems to be the place to be for brands these days. In any event, pharma has been on Facebook for a while going back to 2007 with Merck’s Take a Step Against Cervical Cancer Facebook page for Gardasil. Most pharma efforts on Facebook are very conservative, which means nearly every one has a Wall that is closed for commenting (and, therefore, Likes as well). Of course, as the page admin you can post-moderate comments and user posts on the Wall in Facebook. That is, you can remove them after they are published. This is different than blogs and YouTube where you can pre-moderate comments, so some companies are a bit nervous about this. There are a bunch of examples of pharma using Facebook on the Pharma and Healthcare Social Media Wiki so I won’t duplicate them here except to point out one example that go farther than most.
The Coalition to Prevent Deep Vein Thrombosis (DVT) – One of only a handful of pharma Facebook Pages (though this is actually a group technically) that allows members to post on the Wall and comment on posts made by the company. Perhaps not surprisingly, this group took the silver Dosie Award in 2010 in the Facebook category.
What’s a discussion about social media without Twitter? It seems like nearly every company has jumped onto Twitter either as a way to further disseminate their content or to engage directly with customers. Pharma companies have done both. Once again, you’ll find a ton of examples on the Pharma and Healthcare Social Media Wiki (almost 60 in fact). The majority of these are corporate level accounts of which my favorites include: @jnjcomm, @boehringer, @roche_com, and @pfizer_news.
There are also a handful of brand-level Twitter accounts with the most well-known being @racewithinsulin from Novo Nordisk, which is a branded account for their insulin product Levemir. Here’s the first branded tweet from a pharma company:
It’s more than a year old now and no Warning Letter from the FDA, so they must be doing it right. One other interesting use of Twitter from pharma comes from AstraZeneca who is responding to people on Twitter who either have concerns about the cost of their products or are mentioning adverse events. Take a look at @azhelps and to get an idea of how they’re doing this. I think it’s a simple solution with low risk, but potentially big impact.
Rather than use someone else’s platform, why not just create your own place for discussions about your brand? Is this possible in a highly regulated environment? The answer is apparently “yes” based on a number of examples that are out there. In the pharma industry, the two that leap to mind for me are Children with Diabetes and PKU.com. Both are what you might call “unbranded,” as they aren’t based around a specific product (i.e., hosted on a product website). These two sites work well for two reasons. First, they are almost completely unmoderated. That is, people can say what they want and talk about what they want without being restricted. If you are going to try to host your own community, you have to allow this otherwise people will go somewhere that they can do this. Second, is that both of these sites create a valuable resource that isn’t (or wasn’t) available elsewhere. There isn’t another place online to talk just with other parents of kids with diabetes. There isn’t another definitive source for information about PKU.
So, if you’re thinking about creating a community, make sure that it satisfies both of these conditions otherwise you should forget about it. If you want some more rationale why check out my post: Crushing Pharma’s Digital Marketing Dreams–Part 1.
There are your precedent setters. Take those with you next time you have to head upstairs to the CEO’s office then take a look at my “9 Simple Steps to Getting Started in Social Media” once they sign off on your idea.
If you’re looking for more about social media in pharma, register for the 2010 E-patient Connections Conference. This year’s conference features three different tracks: mobile, gaming, and, yes, social. I’m co-chairing the Social Pharmer track, so expect a different approach compared to the regular conferences you’re used to.
I’m also teaching a tutorial the day before the conference called “Social Media Accelerator.” This will be an interactive workshop that will provide a quick way to catch up on social media in healthcare, including a review of the most and least effective social media marketing programs across industries. You’ll learn about the social media platforms used by patients and physicians and discuss opportunities and challenges of social media marketing, including within the context of DDMAC regulations. You’ll leave with a “best practice” process for creating and approving social media programs within your organization. Bring your questions, as there will be some good discussion time.
Register for the conference and use code “rx2010” (no quotes) and you’ll get $300 off. Sign up before August 31 when the price goes up again. As a further incentive (as if you need one), everyone who registers gets a free Zeo Personal Sleep Coach system and some other great gifts too. Special offer: register this week for the conference using this code and I’ll give you one hour of one-on-one consulting on your brand. Just let me know via the contact page that you registered and we can schedule the hour.