Lessons from the Allergan PMCPA breach

At a high level, pharmaceutical companies understand the importance of avoiding promotional or inappropriate messages on corporate social media accounts. However, social media are by their definition difficult to control, and represent the edge of the digital marketing and communication frontier. A recent breach of the Prescription Medicines Code of Practice Authority (PMCPA) by Allergan has shown that the industry has much to think about when it comes to gaining control of its digital programmes, as the company was censured because one of its employees communicated about a product via a personal social media account.
Furthermore, whilst social media are becoming critical to the commercial success of pharmaceutical companies, sub-optimal management of social media programmes is widespread, as shown by recent statistics:
• Large companies have an average of 178 discrete social media accounts, not including employees’ personal ones.
o Less than half (49%) of companies have an inventory of their social media accounts.
• Less than half (48%) of companies take a coordinated approach to social media.
• Just 26% of enterprise-class companies offer social media training to non-executive employees.
Blurring the boundaries
Each employee is a ‘portal’ for their respective companies, especially as the lines between personal and professional social media consumption blur. An employee’s personal Twitter account could follow accounts of professional interest and contacts and acquaintances met through work, as well as friends outside work and general interest accounts, such as those relating to current events, travel or entertainment. In the Allergan case, an employee responded to a tweet from a friend employed by an agency that happened to be working for a relevant patient organisation. The tweet referred to potential use of Botox in stroke rehabilitation, and it was sent without the knowledge of Allergan, on a personal, not a corporate Twitter account. According to the PMCPA report, the employee in question was inexperienced in Twitter use, and had intended to send a private message rather than a public tweet.
This breach was in spite of company policy stating that employees must not comment on Allergan products or activities on social media forums. Allergan’s actions have since included updating its social media policy and training.
What does this mean for the industry?
Such incidents will no doubt worry other companies, and some may decide that engaging in social media activities is not worth the risk, especially given the ROI of such work can be difficult to define or measure. There are however, numerous examples of how social media can be used safely and effectively in pharma – from useful Twitter feeds, to popular Facebook pages and YouTube accounts with comments enabled – and those companies that shy away from engagement could miss out on important ways to connect with patients, partners and healthcare professionals. In the Allergan case, even avoiding all corporate social media activities would not have prevented the problem, as the tweet was sent from a personal account. The issue here is clear and effective communication of company policy, and the training of employees on social media, whether they use it for work or not.
Of course it is not possible for companies to be in a position to control the private activities of their employees. Implementing thorough, thoughtful training programmes and communicating in a way that truly engages employees may help the case of any company brought to task for the private activities of individual employees, though – indeed in the Allergan case, the PMCPA panel ruled that the company had been let down by the employee, as policies were in place. A breach of clause 22.1 of the code was ruled, but not a more serious clause 2 breach.
What should my company do?
The first step for any pharmaceutical company involved in social media activities is to ensure that clear and robust social media policies are in place, and that these are communicated to all employees. Training at the relevant level should also be offered, including the basics of social media platforms for potentially all employees, to ensure that those who use these technologies outside work have a certain level of proficiency.
It is worth considering the format of policies and training sessions. Whilst comprehensive policy documents are required, creating accessible summaries for employees may help improve uptake. In addition to PDFs, printed materials and informational emails, companies could consider posters, messages on internal networks and presentations dedicated to the communication of key facts. Training sessions should also be accessible, perhaps with some elements being self-learning, taking place online. Real-world case studies, exercises and best practices can all help to get employees’ attention, maintain engagement and encourage application of lessons learned.
Creation Healthcare can help you gain control of your digital programmes, reducing risk and increasing return on investment by translating data into actionable strategies. We offer social media training programmes that really work, because we know how to engage with employees at all stages of the digital journey – this means programmes for complete beginners, through to those for colleagues who need to coordinate the finer points of navigation through the complex landscape.
Contact us to learn more about a special offer on an introductory course.


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