Watch Your Words in Social Media Landscape
Devicemakers wishing to establish a full online presence must take special care to ensure their use of social media doesn’t throw them out of compliance with FDA promotional speech regulations, Edward Basile, from consulting firm King & Spalding, told a recent session of the FDA/Xavier University MedCon.
To avoid doing so, companies should develop a written policy on use of social media, Basile advised. The policy should cover objectives of online messaging, encouraged and prohibited topics, employee training and participation guidelines and how to disclose any adverse events.
Once online, companies should be prepared to continually monitor social media outlets, looking for anything that might be perceived as promotional speech. Basile noted that companies can be held responsible for postings that individual employees make about their products.
The FDA has been slacking when industry leaders have asked for social media guidance, forcing companies to act more on impulse.
Despite the few guidances out there, there seems to be as many unwritten rules as written ones and it’s become pretty confusing for pharma companies to “color inside the lines.” Guessing is not a strategy you want to use.
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