Subtopic 2: Target Audience
When reviewing assets a good principle to remember is that material should only be sent or distributed to people whose need for, or interest in it, can reasonably be assumed.
As a nominated signatory you will approve materials for a certain target audience.
If the material were to be used with a different audience for which it was not approved, it could breach regulations.
Consider this example
A sales representative in the UK was instructed to sell her product to healthcare professionals working in nursing homes, as the product was thought to be beneficial in elderly patients with dementia. She entered a residential home for the elderly and asked to speak to ‘the nurse in charge’. She was introduced to the assistant manager of the home and she gave him some information about her product including a leave-‐piece. She didn’t know at the time, but it was subsequently revealed that the assistant manager was not a nurse – but he was a qualified social worker.
Later, a doctor treating one of the residents at the home was asked by a member of staff if he would prescribe the product. The doctor complained that the product had been promoted to the public.
Which of the following do you think are true about this case?
- There was no breach as all the materials used were approved for use by sales representatives
- There was a breach as the representative had promoted her product to a member of the general public
- The social worker was deemed not to be a member of the general public
- There was a breach because the representative used materials which were not approved for use with social workers
Ruling
Although it was deemed that the social worker was not a member of the public, he did not have prescribing rights and would not make decisions about a patient’s care in terms of medicines. Therefore the information that would be suitable for him would not be the same as the information that would be appropriate for a nurse. The materials that the representative had used were approved for use with nurses but not for social workers. A breach had occurred because of use of material with an unapproved target audience.
