Key Topic 7: Digital considerations
All of the information covered so far applies to digital assets but here are some specific considerations that you will need to apply to assets in digital form – click on each for more information
- Approval must be in final complete form
- Accessibility by general public
- Privacy and Security
- Permission
Approval must be in final complete form
Digital assets need to be reviewed within the channel that they will be delivered through, before they can be approved. For example an e-visual aid designed for an ipad needs to be reviewed on an ipad.
A website needs to be approved as it would appear when live, and not just through screen shots. Where items are to be viewed in multiple formats the data should ideally be checked in them all to ensure required text is clearly visible. Where this is not possible e.g. sites visible via any device, a number of different device types should be checked or specific software used that allows views to be generated for different device types.
Interactivity, downloads, links, metadata etc all need to be checked for compliance with regulations.
Accessibility by general public
When generating assets and considering target audience, you should treat anyone who is not a health professional as a member of the general public. For the majority of countries, promotion or ‘advertising’ of prescription medicines to the general public is forbidden. (A notable exceptions is the USA).
Patients are a special subset of the general public. Patients may be people who have been prescribed and are being treated with an AstraZeneca product, or representatives of a patient population (e.g. members of a patient organisation).
Many digital forms of dissemination are open to the general public e.g. websites, social media such as Twitter, YouTube. Therefore in the case of promotional material you need to consider whether restricting access to health professionals is warranted e.g password protection or requiring declarations of professional status. Geotargeting may also be used in the case of websites to restrict access to certain countries.
Note that ‘filters’ on social media are not considered adequate for targeting health professionals – case law has shown that they are not accurate enough to prevent access by the general public.
It is good practice to state clearly and prominently the intended audience on digital material and if possible to divert members of the general public to relevant information designed and approved for them.
Privacy and Security
Digital media must conform to regulations covering:
- Data privacy – ensuring that data are only used for the purposes for which they were gathered
- Data security – ensuring that data are protected through adequate passwords etc
- Confidentiality
Personal data must not be captured from users of digital assets without their consent.
Permission
There is a difference between proactively ‘pushing’ information towards an audience through digital media, and that audience using digital media to ‘pull’ out information that they have made a decision to obtain for themselves.
In the ‘push’ scenario, prior permission must be obtained in the case of any promotional information. This permission needs to be formally documented. In addition, those who have given such permission must be given the opportunity to withdraw it at any time (e.g. there should be an ‘unsubscribe option’ on promotional emails)
