Pharma communication in a multi-regulatory world

User research informs education website

Few could have predicted the way in which the Internet has changed the dynamic of relationships amongst healthcare stakeholders. For the pharmaceutical industry, it seems there is an opportunity to also play a role in the many online relationships which are made possible by the Internet.

Figure 1: A representation of the way the Internet has impacted healthcare relationships


Despite the Internet being completely global and respecting none of our historical or legal boundaries, the differing regulatory systems present a very polarised approach to pharmaceutical communication.

Therein is a challenge and an opportunity, to find the perfect balance which allows a pharmaceutical company to provide appropriate information to the right people at the right time, and of course in the right way.

In a series of interviews early this year, in New York, London and Munich, I asked for some considered opinions about the regulatory divide that exists between direct-to-consumer markets and ‘the rest’.

Watch the video below, or visit our Creation Healthcare YouTube channel for the edited interview and more.

Ray Chepesiuk, Commissioner of the Pharmaceutical Advertising Advisory Board in Canada points out that  there is “…lots that pharmacy (if they use ingenuity) could do within the constraints“. Ray provides an interesting perspective on the issue of regulation on both sides of the pond, because Canada is of course more closely aligned with the European model of communication, yet often impacted by television communication from their ‘neighbour’ which seems to ignore terrestrial boundaries.

He explains that the big difference lies in the right to ‘freedom of speech’ within the United States:

“… the first amendment is always evoked when people are either talking about personal speech or commercial speech; it’s sacred really. It gets in the way sometimes, moving forward together… there’s a lot of independence of thought.”

Alex Butler, now EMEA Marketing Communications Manager, EMEA Strategic Marketing at Johnson & Johnson Pharmaceuticals is wary of those seeking specific technical regulations on social media – for either side of the proverbial pond – and of those companies that are holding back from exploring the possibilities within the existing guidance:

“I hope that far more Pharmaceutical companies do more, because I think it does benefit all of us; the more engagement we have, the more it is accepted as a norm. I hope that it is not curtailed by guidance… we don’t need to move beyond, in a way, the core principles that we already have…”

Amy Cowan and Jens Monsees, both of Google’s Health Care Industry vertical, are unsurprisingly looking at the issue from the point of view of patients (or other stakeholders) and the information that they are actively seeking. From within their industry analysis the ‘Zero Moment of Truth’ is a Google term which Amy introduces as a new touchpoint in the customer (patient) journey;

“…patients are actually now looking for information prior to their interacting with their physicians…”

Although Jens’ concern is that all the information that might be provided by pharmaceutical companies, is not being provided:

“…information is held back by big pharma… they are limited in putting out the whole information that they have, that they cannot show…”

Alex Butler is aligned with this need to improve the provision of information, and even has a vision of pharmaceutical companies providing a service which is so much more than simply connecting with stakeholders around the physical product. His horizon scanning suggests that pharmaceutical companies could actually curate content:

“I do genuinely believe that a challenge will be to provide high quality content where people want to consume it, and to curate that content, and to think very differently about how we work together as a pharma industry… do we want to duplicate each other or do we want to start thinking about what everyone is doing and where we can add real value.”

Which is a valid point. In a rush to own audience attention, it can be easy to simply build the next thing without thinking about the existing information that is out there. All too often websites are designed to be bigger and better or more flashy than the competition, but not really considering the actual needs of the audiences which are already seeking information or using existing services online.

To this point, search engines have been helping us to sift and prioritise the ‘valuable sites and information’ since the need first arose in the 1990s. Jens explains:

“…we see each other as a connector… to find the right people that have a need, and the right people that have an offer, and bring them together to have a dialogue.”

Could a pharmaceutical company become a reliable provider of medical information and signposting? Could it participate in the centre of the online relationship network?

Figure 2: Could pharmaceutical companies participate from within the conversation cloud?


Regardless of the answer to these questions, the problem of misinformation is potentially exacerbated by regulations which hinder the communication expectations of ordinary citizens from the ‘Internet nation’. Butler is concerned about the sheer volume of information out there;

“If you think about content on the Internet as absolutely mind boggling – no one can really get to grips in their mind of how much content there really is, probably in health care alone –  it is a landfill of information”

Butler continues,

“The big challenge will be how can we take part in the curation of that content for people, but not based around our own assets, but based around helping people to find the right information for them at the right time. I think that that has many challenges, both ideological in a sense but also challenges regarding copyright, ownership, and also whether we are prepared to serve our communities… in a way that is best for them, or whether we still just want to push our own agenda and our own message on people.”

The cultural differences that divide our world into countries and differing regulatory systems are unlikely to change in a hurry, as Chepesiuk concludes:

“will they ever all be one happy, harmonious regulatory world? No, I don’t think so.”

Yet that is no excuse to not look to the future together, and to support each other as new territory is explored within the constraints of each regulatory system. Butler concludes his thoughts;

“Pharma is broadly supportive of each other, with regards to trying to get to grips with this difficult area for us – in a highly regulated environment…

I don’t think that within this space… there is a desire to see other people fail terribly, which I think would be very bad for the industry as a whole.”

Lets think more strategically about what, when and where information is provided through pharmaceutical communication. Even this most basic ‘content strategy’ with a traditional ‘push’ of one-way information provision can be more effectively tailored to provide value to a new landscape of health care relationships – with or without two-way engagement. It could be that the rush to innovate in social media has meant that simple ‘right-time’ communication has been left by the wayside.


Creation Healthcare believes that there are many opportunities to improve on the basics of online communication. To speak with a member of our consultant team, please contact us now and we will be pleased to further understand the challenges that you may be facing in your organisation.

If you are a business leader or communicator in healthcare, you can also get your free subscription to the Healthcare Engagement Strategy e-Journal at http://engagementstrategy.tv/

View all articles >