Upload
scott-phelps
View
213
Download
0
Tags:
Embed Size (px)
Citation preview
New Facebook Rules: A Challenge and an
Opportunity for Pharma
Summary: A new Facebook policy will require all
pharmaceutical companies to leave wall comments enabled
on their Facebook pages. The rule not only leaves pharma
companies open to public criticism, it also complicates
federal rules requiring companies to report all stated drug
side effects to the relevant authorities, a rule set in 1993,
long before the advent of social media. However, Facebook
is an opportunity for pharma - not an obstacle. The key is to
embrace, rather than fight, its open features.
Like many pharmaceutical companies, Johnson & Johnson has tip-toed into
Facebook with a careful step. With over 15,000 likes and a constant stream of
consumer-friendly company news bulletins and heart-warming links, J&J’s
Facebook page almost seems a success. But despite their best efforts, the
page is under constant flak from consumers, with numerous negative
comments littering otherwise thoughtful posts.
The comments stem from several issues. In particular, campaigners have
posted frequent criticism towards J&J for not joining a patent pool to lower the
cost of HIV treatment. Whilst this poses a threat to J&J’s reputation, still other
issues are far more concerning from a regulatory standpoint. In particular,
numerous drug users have posted claims that certain J&J drugs - particularly
Levaquin - cause dangerous side effects. This leaves J&J in a bind - with a
Facebook wall open to consumer claims of adverse drug effects, how do they
handle these claims with the necessary regulators?
The Problem with Adverse Events and Adverse Effects: No Clear Guidance
In order to understand J&J’s - and all of pharma’s - dilemma, we need to
understand two things: adverse events and adverse effects.
An adverse event is any adverse change in health or side effect that occurs in
a person who participates in a clinical trial while the patient is receiving
treatment or within a previously specified period of time after the treatment
has been completed.
An adverse effect is a harmful and undesired effect resulting from a medication
or other intervention.
In many countries - including the United States and the United Kingdom -
pharmaceutical companies are required to report adverse events and adverse
effects to the drug regulatory of the respective country. However, when these
events are reported in an open forum such as Facebook, it’s not exactly clear
how the pharma company should respond.
For example, as of now, there is no FDA guidance that explains how current
regulation applies to online discussion (this despite pharma marketers’
request for clearer guidance in 20091). The current guidelines give four
parameters for submitting information about adverse events. The pharma
company should have knowledge of
1 An identifiable patient
2 An identifiable reporter
3 A specific drug or biologic involved in the event and
4 And adverse event or fatal outcome
However, it is unlikely that an adverse claim posted on a Facebook wall will
contain all four pieces of information necessary to make a report. In fact, in a
Nielsen study of 500 healthcare-related messages posted online across
multiple disease categories, they found that only 56 (11%) of messages
contained enough information to submit a report2.
However, these guidelines were set in 1993, long before the advent of social
media, and pharma’s demand for an update is understandable. Without clear
rules, Facebook remains a hazy marketing area for companies like J&J. Their
Facebook page illustrates why many pharma companies are wary of Facebook,
with many having little or no presence whatsoever (Abbott Laboratories, Merck
& Co. and Eli Lilly just to name a few).
1 Still No Answers For Digital Pharma Marketers, Says FDA, Kate Kaye, Clickz.com, 23 Dec 20102 Listening to Consumers in a Highly Regulated Environment, Melissa Davies, Nielsen Online, August 2008
Pharmaceutical Companies on Facebook3
Company Facebook Presence
Comments allowed
Fan Count
Abbott Community Page No 6,458
Amgen Community Page No 1,215
AstraZeneca Official Page No 10,198
Bayer Official Page Yes 533
Boehringer Official Page Yes 12,134
Bristol-Myers Community Page No 270
Daiichi Sankyo Community Page No 270
Eli Lilly Community Page No 3,092
GlaxoSmithKline Official Page No 10,012
Johnson & Johnson Official Page No 15,589
Merck & Co. Official Page No 946
Merck & Co. Community Page No 2,489
Novartis Official Page No 6,521
Novo Nordisk Official Page Yes 3,568
Pfizer Official Page No 26,482
Roche Careers Page Yes 3,128
Sanofi-Aventis Page for Initiative Yes 706
Sanofi-Aventis Community Page No 6,107
Takeda Community Page No 425
Teva Official Page No 1,015
3 Fan numbers were gathered on 8 June, 2011. Community Pages are pages created automatically by Facebook; they include a wiki article description, cannot be edited by users and do not contain a Wall for fans to post on.
Until recently, pharma companies took some comfort in the ability to disable
comments on their Facebook pages, thus sidestepping all regulatory issues
around adverse events and effects. This month, all that changed.
Facebook Tells Pharma They Must Allow Comments
Pharmaceutical companies currently have the option to enable or disable
commenting on their Facebook page. However, in line with its effort to ensure
Facebook remains an open platform, Facebook recently changed its policy that
allowed high-risk pharmaceutical businesses to turn off commenting4.
Now, Facebook pages with comments disabled have until August 15 before
open comments become a requirement.
The rule change has many pharma brands in a panic - one look at J&J's
Facebook page shows you why. No doubt, the comment policy will be a
challenge, but it also presents an opportunity for pharma, who have so far seen
limited success in using Facebook for marketing and PR.
The new Facebook rules are poised to change the way pharma manages
comments on Facebook. At present, various tactics are used to moderate
unwanted posts.
J&J's page appears lightly moderated, with the result of constant negative
commentary from consumers. Sanofi-Aventis’ VOICES page, however, appears
heavily moderated - despite posts claiming an excess of 100 comments, only a
small handful of comments (less than 10 in one case) are visible. This suggests
that the other comments have been deleted, which makes you wonder just how
bad those 90+ comments were.
Boehringer Ingelheim is the only pharma company we found which successfully
uses Facebook as a positive engagement tool. For example, their Facebook
page shows positive activity fuelled by a photo contest as can be seen by the
top terms used in conversation.
4 Facebook Tells Pharma Brands They Must Allow Comments, Kate Kaye, Clickz.com, 20 May 2011
Source: Skyttle Friends Facebook Analytics
Negative comments are hard to find and are most likely removed in accordance
with their usage policy, stated clearly on their Welcome page:
The company reserves the right to delete any postings at its sole discretion
(sorry - we know it's not very social media but we work with serious medical
conditions and we can’t risk unmonitored or unverified medical advice being
published).
This Facebook challenge is very real for pharmaceutical companies. After all,
how do you leverage an open platform when you own brands that commonly fall
under consumer scrutiny? Some pharma companies have handled this by
staying away from Facebook altogether. But others, like J&J, Sanofi-Aventis and
Boehringer Ingelheim, are testing the Facebook waters and slowly catching on.
Facebook's new rules may seem like a shark in the water, but in fact, they're an
opportunity. Openness doesn't pose a threat to brand reputation; it offers an
opportunity to manage reputation in a productive and positive way.
Case in point: BP Gulf Oil Spill
Like pharmaceutical companies, oil companies too must constantly play defence
to consumer criticism. Take a PR disaster like the BP oil spill in the Gulf of
Mexico, a disaster which made BP's Facebook page a prime channel for
consumers to vent their outrage.
BP could have deleted the comments, or deleted their account altogether, but
instead, BP saw an opportunity to use Facebook's popularity to manage the
conversation.
BP recognised that consumers needed a place to express their concerns, stay
informed and - most importantly to BP - stay aware of what BP was doing to
rectify the situation. So BP set up two separate sections of their Facebook page:
“Gulf Updates” and “Voices from the Gulf”. The effect was to channel
conversation about the oil spill away from their main wall and onto these topical
pages. They also published a friendly but firm “commenting” policy that
encourages "constructive, respectful" but disallows vulgar, obscene or
threatening comments.
As bad as the oil spill was for BP, Facebook allowed BP to protect its reputation
and manage the conversation by doing two things:
• Providing something useful to consumers - information -
that both educated consumers and advertised their positive efforts to
repair the damage.
• Portraying an honest, sincere voice that demonstrated BP's
desire to engage in constructive dialogue about the brand, be it about the
oil spill or other company activities.
The result is a boon to BP's overall Facebook presence, which continues to attract
fans and positive comments on its various content pieces.
BP illustrates how any company - including pharmaceutical brands - can use
Facebook to manage conversations, even those that seem potentially harmful.
The key is in understanding what Facebook is good for and why it's such a
powerful platform for consumer conversation and brand interaction. In other
words, you have to embrace - not fight - Facebook's open features.
Pharma on Facebook: How to Make it Work
Our own studies for pharmaceutical clients have shown that Facebook is an
important influencer in the exchange of health information. Therefore, there is
much to gain from joining the conversation, provided you approach Facebook
systematically.
Four things are key to pharma’s use of Facebook to ensure it gets the most
benefit while still abiding to regulations around adverse event reporting:
• Structured management
• A clear policy on commenting for your Facebook page
• Listening (including monitoring)
• Sincere engagement
Structured management means putting someone in charge of Facebook who
takes an active role in conversations and is responsible for ongoing monitoring
and moderation of Facebook comments.
A clear commenting policy posted publicly on your Facebook page will allow
you to moderate conversations in line with what you intend your page to be
used for. This means you can delete inappropriate comments as you see fit.
Boehringer Ingleheim has done an excellent job of this on its Facebook
Welcome page by posting a clear policy that allows them to remove
potentially damaging comments.
A listening strategy should include some form of rigorous monitoring to ensure
you catch all comments that require action. In particular, any comments that
are inappropriate should be removed, and any reports of Adverse Effects
should be investigated and reported if necessary. But listening isn’t all about
dealing with problems; it’s also about getting consumer insights from people
having real conversations about you and your products.
The true value of a Facebook page comes from sincere engagement with
users. Comments, even negative ones, reveal endless insights valuable to the
brand:
• Popular topics of conversation reveal what consumers care about, good
or bad
• Negative feedback allows you respond to problems directly and points
to opportunities to improve products and services
• Positive comments provide great word of mouth and potential ideas for
positive PR campaigns
• Popular discussions and wall posts reveal which ideas resonate with
consumers
But in order to get at these insights, you need to have one thing: a sincere
voice, especially in the face of criticism.
This is where most pharmaceutical companies seem to struggle. A successful
Facebook page needs an authentic voice that cares about its fans issues and
responds with a sincere, honest touch. People like a Facebook page because
they're looking for this voice, a voice that they respect and want to engage
with. After all, would you want to have a conversation with someone as dull as
a doornail who keeps bringing up the family picnic even though you keep
telling them how devastated you are over your recent cancer diagnosis? No,
give me some sympathy, and tell me something that might help!
In Johnson & Johnson's case, they don't necessarily need to join the patent
pool to win over their Facebook fans. But they do need to give something back
that's useful and sincere. For example, several topics are currently driving
negative commentary on J&J's Facebook page, particularly specific drugs like
Levaquin, and the Medicines Patent Pool.
Taking a cue from BP, J&J could start posting news about their current
activities around these issues, or even start a page that directly addresses
these concerns. More importantly, J&J could respond to comments, especially
those that are respectful and constructive, albeit negative about the brand.
J&J's participation would be both a gesture of goodwill and an opportunity to
learn about their customer's concerns. Moreover, it would help encourage
positive conversation around their other, more positive, activities like the
company sports team and their environmental work.
Today's digitally connected world demands sincere engagement, particularly
on a platform like Facebook. However, this demand makes Facebook a
mechanism - not an obstacle - for sustaining positive PR and protecting
reputations. Pharmaceutical companies are still in their early days of figuring
this out, but those that do will be in a prime position to benefit from the 600
million people currently using Facebook.
About Market Sentinel
Market Sentinel is a thought leader in online conversation monitoring and
analytics. We work with major brands from around the world to help them
make sense of the web.
Our tools and services include brand monitoring, benchmarking analysis and
digital planning with Skyttle, a suite of on-demand social analytics tools. Our
most recent addition to the Skyttle family is Skyttle Friends, offering in-depth
Facebook analytics for any Facebook page, public or private.
Market Sentinel's unique mix of business and marketing professionals,
mathematicians, linguistic experts, software engineers and social media
analysts creates best in class solutions that produces long lasting client
relationships.
Source: Skyttle Friends Facebook Analytics