Today, I’m reporting some official, final statements that we received today (and that many others are likely receiving right now) from Facebook about changes to commenting policies. This is in advance of any formal announcement. I’d expect the formal announcement soon, but my information comes directly from our Facebook reps for some key clients. This information is different than what some other sources have reported recently.

A few different sources have reported on some potentially upcoming changes to the way Facebook works that could affect not only pharma brands, but brands in every other industry as well. The first of these came from Jim Dayton at InTouch Solutions who reported on an upcoming change to pharma pages regarding “whitelisting.” What Jim reported on was the special exception that some pharma (and OTC brands) pages have been given by Facebook that turns off not only people’s ability to post on a page’s Wall, but also to prevent them commenting or Liking anything that the brand posts on the page. This latter setting isn’t something available to most pages, as it is functionality that Facebook could turn on as a case by case basis. To see what a page with this functionality looks like, check out the Epilepsy Advocate page, which is sponsored by UCB pharma. As Jim reported, this is going away. Jim pretty much hit everything right on the head, except for one point. He reported the following: “First, the change in policy will not be retroactive. Pages that have been approved for whitelisting will continue to be whitelisted.” From the information we received, this appears to not be the case. Based on information from Facebook, all pages will lose this ability effective August 15. That is, there is no “grandfathering.” In addition, no new pages will be granted this functionality. Kudos to Jim for getting this information out as soon as he did (about a month before the official Facebook announcement) and having it almost 100% correct.

Here’s the Epilepsy Advocate page. You can see where I drew the box that there’s no option to Like the post and no box to leave a comment. This is what you get with the special Facebook “whitelisting”. [Click to enlarge]

There is one important exception to this new rule. From Facebook: “Subject to Facebook’s approval, branded Pages solely dedicated to a prescription drug may (continue to) have commenting functionality removed. Pages representing a prescription drug must have the drug name explicitly in the Page name.” So, it seems like pharma might not be that affected in cases where someone want to create a branded page (something I’m generally not a fan of and that is very rare at this point). A very key phrase in that statement is “prescription drug.” This exception therefore will not be granted to the many OTC brands that currently take advantage of this whitelisting feature.

The second report of these changes came from WCG. It’s a post that has been cited numerous times in different blog posts and at conferences since it was published. I’ve been a little skeptical of some of the claims in this post since the beginning (and posted a lot of comments all over the place about it) and it appears that my skepticism was justified. WCG had some of the main idea correct, but included some additional details that turn out to not be correct. Specifically, the key piece they mentioned is that ALL pages (not just pharma) would lose the ability to control whether or not someone posted on the Wall. This is very different than what Jim reported. Essentially, there are two different “settings” here. One only Facebook can enable. This “setting” allows Pages to block people not only from posting on the Wall, but also prevents them from commenting on or Liking posts made by the page. The other “setting” is something available to all Page admins. This allows the admin to prevent people from posting onto the Wall, but allows them to comment or Like posts made by the Page. So, if you don’t want people posting random things on your Page, you can prevent people from doing so, but they’ll always be allowed to comment on what you post. This cannot be turned off unless Facebook did it for you as a special exception. This is the setting that controls this permission: [Click to enlarge]

What WCG claims (and even has a screenshot illustrating the point in the presentation embedded in their post) is that the controls I highlighted in the screenshot above will disappear for ALL brands (i.e., not just pharma). This would represent a huge fundamental change to the way Facebook works, which is what I was skeptical about. This feature is NOT going away according to Facebook. This means that the feature that WCG reported as being disabled will, in fact, NOT be disabled. You can still control whether people post on your Wall, but can’t control whether they can comment on a post made by the Page. Of course, the page admin can remove these posts after the fact. Some images may make this clearer.

First, on the Dose of Digital Wall, anyone can post whatever they want. That’s what the top red box is highlighting below. I’ve left all the boxes checked from the settings seen in the screenshot above, which is what allows people to do this. The second box shows that they can comment on posts I’ve made as well. Admins can control (and will continue to be allowed to control) what happens in that top red box, but they won’t be able to control what you see happening in the bottom box. [Click to enlarge]

In this next image, the red box shows that I’ve disabled the ability for people to post on the Wall, but you’ll notice that people can still comment or Like posts that made by the Page. [Click to enlarge]

We expect Facebook to announce these changes to the general public today or tomorrow, so look out for that.

So, what is a pharma brand to do? Here’s my take on it:

• If you have a Page that has all commenting blocked, you need to evaluate how important this is. How much risk do the comments others leave on your posts incur? I’d argue that they produce very little risk. If someone posts something inappropriate, you still have the ability to delete it. You cannot review comments before they are posted on the page (like you can with a blog), but you can delete them right away. You can receive notifications whenever a post is made and review it immediately. If you use a service like Buddy Media or Vitrue to publish your Wall posts and moderate comments, you have the ability to flag comments with certain words and can get notification only when certain words appear (like your drug name). You can also use the feature built into Facebook that allows you to create a “moderation blocklist”. If a comment contains any of the words in your list, they will be marked as spam and won’t appear on your Page. You can then review all comments marked as spam and decide which to keep. More details on this moderation feature can be found in this post.
• Many others have recommended disabling the Wall and using a “custom” Wall that would allow for moderation before the posts are live. I’d recommend against that. If Facebook is such a risk to your company that you cannot allow people to comment (which you can delete later), then maybe Facebook isn’t for you. In order to use a custom Wall, it needs to be created as an application. This application will require people to give you permissions in order for them to use it (you’ve seen this before with other Facebook apps). People don’t want to have to do this to comment on your page. In addition, you’ll lose the ability for people to like your posts. Part of the benefit of Facebook is that you can reach a lot of people because others share your content with others. If you disable the Wall, you lose a simple way for people to Like your content, which shares it with all of their friends. Again, maybe you shouldn’t be on Facebook.
• Branded pharma pages can still get the special feature that allows them to block all commenting on the page. I’m not sure if this is good or bad. No one wants to Like a pharma brand mainly because they don’t want to broadcast it to their friends. Here’s my somewhat extreme example:

Whether you continue to use Facebook if your page is losing its special features is up to you. If it’s a major problem, then that might be a good indication that Facebook isn’t a fit for your brand or your company’s risk tolerance. That’s okay. You’d be in good company. I personally do not believe there is any risk in allowing commenting assuming that they are properly moderated after the fact, but I don’t have any formal guidelines that tell me that. Each company needs to decide if the risk and rewards are worth it for their brands and their company. Of course, there are more and more brands with open commenting right now. You can see all the pharma and healthcare brands on Facebook on the Pharma and Healthcare Social Media Wiki. Use them as some precedent setters with your legal and regulatory teams if that helps you prove your case.

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