Social Sharing: It’s All in the Content
The notice of violation issued by the Division of Drug Marketing, Advertising and Communications (DDMAC) to Novartis on July 29, 2010 created a small tremor in the pharma marketing world. The news quickly sent many of us to our browsers to view our website’s source code, hoping our metadata was compliant and sites like Facebook and Google were not indexing noncompliant snippets to be used as titles and descriptions for consumers. After we got over the initial excitement at Intouch Solutions, we released our insight and recommendations titled “Dissecting DDMAC’s N.O.V. Letter on Content Sharing.”
Now that we’ve had a chance to dig into the situation more, we’ve found that DDMAC has given our industry a morsel of much-needed guidance and pointed out a bigger issue when it comes to pharma in social media. Not only do we need to carefully evaluate the social media tools we use, but we also need to evaluate the content we are asking people to share. And once we decide we have content that is deemed valuable and shareable, we need to use tools that consider the unique needs of the pharma industry to ensure fair balance is represented to the end consumer.
Did the letter to Novartis change everything?
Although the Novartis letter painted a very definitive picture of how pharma marketing content can be shared via social media widgets, it did not change what we already knew about digital pharma marketing. According to the letter, DDMAC’s stance on social sharing is no different than it has been for content disseminated in every other marketing channel, reinforcing the idea, “It’s the message not the media.” As pharma marketers, we know the existing rules and will be expected to adhere to them in the absence of guidance, regardless of technological innovation.
Although there was seemingly no change in DDMAC’s position, one result of the Novartis letter is that many marketers are now very aware of metadata. Yes, metadata exists in website code, and other programs use that data to display descriptions of the content on your site. And, yes, you should review your social sharing tools to ensure they are not using inaccurate or noncompliant metadata. Many would argue that you should alter your metadata to make it less descriptive, omit indications or remove it altogether. This is not the approach Intouch recommends. Much like the pages on your website, your metadata should be reviewed for regulatory compliance. But understand, if your important safety information exists on your website, it exists in your website’s code as well. And the important safety information will be found in the pages of code where your metadata exists. So, like any other copy on your Web page, your metadata may very likely still be considered compliant.
But this issue runs deeper than metadata, or sharing tools for that matter. Granted, the letter to Novartis is about how content is shared using a social widget. But, in the aftermath of the letter, two more important questions arise:
- What content on pharma sites is valuable enough for people to share?
- How can we ensure fair balance is intact on the content that is shared?
Creating valuable content
Without being directly connected to Novartis, Intouch can only speculate about how many people were actually sharing the content of the Tasigna site on Facebook, which was the focus of the DDMAC letter. However, chances are very few people were using the sharing widget. That’s not to say that providing a means for people to share your content has no value. Quite the contrary, word-of-mouth is extremely important. A study of frequent social media users by market research firm Invoke Solutions found that the most trusted information was posted by people respondents knew. 29% of respondents said they trusted information from friends or people they knew versus 17% who said they trusted information from companies or brands they follow. But, was the content on the Tasigna site worth sharing? Did the content compel the user to click on the sharing widget? If not, then the sharing widget was simply a patsy for the bigger issue. So, the question quickly becomes, what content has value for the consumer? And how do we consistently create content that has enough value that people will be compelled to share it? These are two very difficult questions, especially for a regulated industry like pharma.
In some cases, it is the media we are using to convey the message. Recently, video has emerged as the media leader online. According to research from Frank N. Magid Associates, conducted on behalf of Metacafe, 85% of males and 68% of females watch online videos weekly. But video is not feasible in all cases. That’s why it is important to have a strategic media mix that integrates messaging across all customer touchpoints. This includes traditional marketing channels like TV and print.
In other cases, value is defined by timing. Being first to market and providing the content before anyone else makes it inherently valuable and shareable. This has gone on for years in the news industry with competing agencies working hard to “scoop” one another. Scooping the competition becomes increasingly difficult because pharma companies can rarely mobilize to provide relevant content at the speed consumers have become accustomed to in the digital age. There are also many more competitors in the race to provide relevant information. Pharma companies are not only racing against competing companies but they are also racing the general public, whose information may be questionable or noncompliant.
And still in other cases, value is determined by the consumer’s location and attitudes at the time of receiving the information. For example, a consumer would find more value in a doctor discussion guide delivered while they sit in a waiting room versus a week before their appointment while sitting at their computer. The same theory applies on a different level when talking about socially shareable content. A consumer will find more value in the results of a clinical trial delivered in a forum where they are engrossed in a discussion about a disease versus Facebook where they are discussing the latest adventures of their children with friends and family.
It’s not easy to create content that meets all of the criteria above — right message at the right time in the right place via the appropriate channel. But this is what determines content value. And ignoring these criteria leaves companies with content that no consumer would share regardless of how many sharing widgets are available.
The line between accountable and irresponsible
DDMAC’s letter set many precedents. One that may be the most overlooked is the definitive line that was drawn regarding pharma’s accountability for information that is being shared online. Novartis’ violation occurred after the information had left the Tasigna website but before the user confirmed that the information be shared. Technically, this is on Facebook. But the message is clear: Pharma companies are responsible for information that is displayed up until the final moment when a consumer decides to share that information.
There are still a multitude of scenarios that are not defined by the letter, but we now have direction regarding one aspect of social sharing. This does not account for users who cut-and-paste URLs and add their personal commentary before they share the information, or users who quote passages or alter information in any way before it is shared. But the letter does account for static information that social sites, like Facebook, pull through from legitimate sources controlled by pharma companies. We are accountable for what we can control.
Responsible social sharing is possible
Once valuable content has been created and we accept responsibility for how the information is shared via sharing widgets, we must evaluate where we expect the content to be shared. Though Facebook is the most popular social network, we must ask, “Can we safely share information on Facebook?” In some cases the answer is “yes,” but for some drugs the answer is a resounding “no.”
Intouch recommends a cautious approach to social sharing via widgets. Generally speaking, character limitations on sites like Facebook will make sharing information about drugs with a boxed warning via a social widget impossible. There is simply no room to include important safety information. Branded information will need careful consideration when utilizing a social widget. This information may need to be relegated to a reminder message via the sharing tool. And unbranded information may be easily shared via sharing widgets without restriction.
Since inception, Intouch has been focused on making the Web safer for our pharma clients through creative solutions. The DDMAC letter, though it has sparked a lot of conversation around our office, was not surprising after we dissected what was being cited as violations. And we have been working on a tool to make social sharing that allows pharma companies to safely allow people to share information across social channels and e-mail. The tool is called Share�Send�Save.
Share�Send�Save gives our clients the ability to not only control what content is being shared but also the titles, descriptions and images that sites like Facebook display prior to final user confirmation. It’s a tool that has been built specifically for pharma, excluding third-party server interactions, interstitial ads or other issues that arise with commercial social sharing widgets.