Key Topic 3: Email, digital adverts and apps - Digital Adverts
Advertisements for prescription products should only be placed in digital journals and other digital communications targeted at healthcare professionals (except in USA/New Zealand).
Advertisements in digital media communications should comply with the requirements for all advertisements and any special requirements for Internet advertisements.
Signatories need to consider whether the screen view might make content misleading, for example by important information being lost from the initial screen as a result of the user needing to scroll down the screen to view additional content.
Consider this example
Take a look at this webpage. Cedax Example
Which of the following do you agree with?
- The intended audience is stated adequately
- The webpage does not give balanced information about the product there is a lack of any adverse event information, warnings and precautions or contraindications
- This website can be accessed by non US residents and so constitutes promotion to the public it is clearly marked for US resident only and direct to consumer advertising is allowable in the USA
This webpage was the subject of an FDA warning letter due to the lack of important safety information. Important contraindications and warnings and precautions were omitted. Although there is a link to prescribing information, the FDA stated that this did not mitigate the complete omission of important risk information from the webpage.
