Whilst the on-going battle of opinion has continued for some time with arguments for and against ‘specific’ guidance on social media in the pharmaceutical industry, some communicators have used this as an excuse to stay away from new and emerging channels altogether.
I personally keep coming back to the simple truth that regulatory guidance is only there to protect the industry and patients, by telling us what is NOT permitted rather than necessarily ‘HOW TO’ do social media in the pharmaceutical space.
Industry codes and laws have done this job more than adequately for a long time, and these are rightly slow-moving bodies of work which can never truly respond to the rapid idiosyncratic changes in technology or techniques for communicating.
Here, I draw a parallel with the aviation industry. There are generic (and international) aviation laws which all pilots must learn, and pass an exam for. Quite simply, don’t break these laws.
Yet all manner of pilots fly many different types of aircraft, and in different ways, and for different purposes; each has tolerances and best practice for operating efficiently and safely. No single pilot can know all there is to know about aviation. Nor can a single person know everything there is to know about social media. We start with generic laws which protect the industry and those affected by it.
For pilots, they then rely on continuous training and simulation to build experience of the many scenarios which could cause trouble. They also rely on checklists and predetermined procedures which can be found in the Pilots Operating Handbook (POH) for each aircraft. No two POHs are identical, because every aircraft is slightly different, even if there are similarities with others of the same type. A pilot pre-reads and familiarises themselves with this specific handbook before launching into the air. In the case of an emergency, and with time permitting, they will refer to the appropriate section and follow the procedures for the best possible outcome in most cases. It is for this reason that the ‘emergency procedures’ section is before the ‘normal operation’ section of the handbook. Is that your priority thought when developing a campaign for launch i.e. getting the ‘what if something goes wrong’ section completed before the ‘everything will be rosy’ section?
The POH is a living document, and as new information comes to light it may be appropriate for the manufacturer to issue an insert which either more fully explains something, or even replaces the original content altogether. In this way, there is up to the minute guidance for the pilot which is more like a ‘help file’ or ‘how to’ document rather than law. From the introduction:
“This handbook is not designed as a substitute for adequate and competent flight instruction or for knowledge of current airworthiness directives, applicable federal aviation regulations and advisory circulars… it should not be used for operation purposes unless kept in a current status.” (Robinson, 1992)
Social media campaigns and channels are also never implemented in exactly the same way. They each have idiosyncrasies and have agreed limits or boundaries for their administration.
In recent times, Creation Healthcare has been helping clients to develop their own ‘handbook’ which may be relevant in a generic sense, but which can be tailored to individual campaigns. The handbook contains scenarios, procedures, and recommended limits for a campaign – in the same way that a POH guides a pilot. The key is that these are not Standard Operating Procedures or company corporate policies; they are more like the ‘help’ section that you might refer to when you are using a piece of software such as Microsoft Word. They are a quick reference for when you want to know the best way of doing something, or how to troubleshoot an issue.
For this format, we have in some cases recommended a Wikipedia style internal portal. Appropriately experience authors and subject matter experts can provide simple tips and advice – usually bulleted. This is not binding, but can save a lot of time and help to bring unified understanding of digital channels within an organisation.
Of course, should a particular section no longer be relevant (let’s say Twitter fell bankrupt or was surpassed by a competitor technology), that section can be removed or updated to reflect the current thinking. Just like a POH, the new entry is dated accordingly, and people within the organisation can then also see the history of the current thinking.
Preparing to ‘take-off’ in social media really does require proper planning and training. Attempting to get airborne without the necessary precautions is a risk not worth bearing. Plenty of companies have learned the hard way, that ‘failure to plan is planning to fail’.
To speak with Creation Healthcare and learn about how your organisation can simplify your preparation for social media communication – whether through instruction, developing protocols, or interpreting regulation – contact us now.
Robinson Helicopter Company (1992) R44 Pilot’s Operating Handbook and FAA approved rotorcraft flight manual RTR 461, Torrance, California, Robinson Helicopter Company.
Photo: Image by John Jackson