This article is the sixth in a series produced by the Pharmaceutical Marketing Society’s Digital Interest Group to address some of the industry’s most pressing challenges in the digital space. They have been designed and written to inform and share good practice, but most importantly to generate discussion and collaboration.
Ever since we have been working in pharma – and the sum is a fair number of years – the most common refrain we have heard as to why projects are stopped, changed, delayed or cost more is – Compliance.
And this seemed to become louder when it came to why the adoption of digital channels was taking so long in Pharma. Most surveys or polls would put compliance/regulatory/legal/Code/MLR approval at the top…. alongside proving ROI.
Why is this and is it a real obstacle or just a convenient excuse for poor planning, knowledge or project management?
In addition, what can medical and Compliance teams do to move from a reactive “policing” role to an enabling, proactive and value adding position?
We are not the only regulated industry. Think gambling, finance, alcohol etc. In fact the only law that applies to pharma’s prescription products and not these other industries is about promoting directly to the public (with the exception of the USA, New Zealand and somewhat in Canada). All other compliance issues – data protection, copyright, accessibility, consent, IT security etc. apply to these industries but they have driven away with digital channels.
We believe that there are two main issues at play here:
- delay in engaging the right people and
- a lack of knowledge about the ABPI Code and other compliance topics (see above) that relate to the use of digital channels.
The first issue is surprisingly easy to define yet so common to miss. You wouldn’t ask someone to join you in watching a film ¾ way through, so map all the stakeholders in delivering your programme and engage early.
For the lack of Code understanding, or the complaining that it isn’t clear enough……it never will be!…. as this video from Nick Broughton on the recent social media guidance describes. Actually in the UK the ABPI Code probably gives the most guidance compared with many countries but still many don’t think it is clear enough.
To help, the Code has a digital version, enabling faster and easier access to specific areas. Using the tools provided and understanding the cases that shaped it will always set you up for success. These checklists will also help you prepare.
Good Cop – Bad Cop
Dr Rina Newton, a Code and compliance expert stated her view: “It can be infuriating for the approver to have to be the one that says no, when others involved would have had the same opinion at the outset of an idea/project. I train compliance and signatories to never say no. Instead, being constructive and suggesting other options can put an end to the perception of bad cop.”
Compliance teams are now, more than ever, co-creators of content and assets, yet are rarely given the support to understand the ever-changing landscape of digital activities and new technologies.
Digital Compliance Champions – an example from CEO & Medical Director, Lucent biopharma
The issue in the business that we needed to solve was one issue with many heads – (1) we didn’t have a handle on what was acceptable from a Code compliance perspective in digital, (2) no-one seemed to have the experience to become the internal expert that was needed to ensure that the business could make progress with its omni-channel plans, and (3) there was a range of differing opinions in different departments meaning a lack of consistency on the topic.
So we pulled together a group of signatories from across the business, who had an interest in digital and omni-channel, and set about (1) understanding together what was and what wasn’t compliant in digital, (2) increasing the knowledge and skillset of the team week-by-week and (3) sharing ideas and practices to ensure we were converging on common ground.
What emerged was the Digital Compliance Champions (DCC) group – a team of around 12, representing all business units in the company, who week-by-week increased the knowledge and understanding of the compliance implications of digital, and then diffused those learnings back into their teams.
The organisation as a whole learned and improved through this – and the omni-channel plans (that were desperately trying to keep-up with a nationwide lockdown) proceeded at pace.
We encourage Compliance to take a greater interest and increase their understanding in this space as becoming more knowledgeable will support teams in focusing on truly valuable content to meet the business’ objectives.
Compliance is a Team game and everyone has a role to play. We win or lose as a team.
Authors: Paul Dixey – Consultant, Debbie Young – Otsuka Europe, Aristides Grau – Novartis UK
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The Digital Interest Group is made up of passionate pharma digital experts who volunteer their time to:
- Promote digital best practices across pharma marketing and the wider commercial organisation
- Explore and share an understanding of what digital strategies and tactics marketers in the life sciences sector can employ effectively to support their brand, business and customers.