Author: Elsa Abruzzo
My foray into the universe of blogging and social media oddly coincides with my initiation into the Good Promotional Practices (GPP) Alliance. As a regulatory affairs professional and now a GPP Superhero, (well a girl can dream,) I am conflicted by the great marketing opportunity social media provides to medical device companies, big pharma, and other regulated industries and its ability to wreak serious havoc on promotional compliance activities. After many years of working with cross-functional teams at a variety companies to develop and execute GPP systems that work well for the more conventional marketing vehicles, here comes real-time, social media marketing to create its own unique set of questions and complex circumstances. How can you regulate such an animal, rein it in and domesticate it so it works for you, without killing it or its wild (viral) spirit? How can you approve, authorize, and control content that is flying out to your internal and external customers at the speed of the broadband and G4 networks through Tweets, Facebook updates, LinkedIn Group Chats, YouTube, and a host of others?
Recently, going over the content for a GPP talk, I had a “Eureka” moment – you can control the use of social media by your company like you would your teenage driver. This of course is not foolproof or easy – as those with teenage drivers in the household can attest, but you just have to do your best. Go with me on this now… I’ll explain.
First you need to buy your teenager a safe vehicle, preferably a large one with lots of airbags and safety features. It has to maneuver well, but take a big impact with ease. This is equivalent to making sure that you have the proper SOPs and GPP system in place; such as the one you use for your conventional marketing, but customized to address your company’s social media policy. Like teenagers and cars; your employees are going to use social media. They are already chatting on various LinkedIn groups, tweeting, and they may not even know that their involvement in these could be considered promotional activities on behalf of your company. Long gone are the days where you could just post anonymously on Yahoo Finance; now with some of these other social media outlets your name and affiliations are not just public, but rather a badge of honor we flash proudly as we try to amass as many friends and contacts as humanly or virtually possible. Could I as a member of a LinkedIn group affiliated with a company or University get you in trouble by talking about one of your/our products? You bet ya! Even with the best intentions, and that is usually the case, the use of social media, even those of which you are not aware, could stir a nidus of compliance issues with regulatory agencies directly and provide fodder for you competitors to use against you. FDA, DOJ, your competitors, they are on these sites as well … aren’t you on theirs?
Then there is getting good insurance to cover you for the expected and more importantly the unexpected. To differentiate between company-sanctioned vs. personal social media usage by your employees, your SOPs and GPP system have to be equipped with safety features that clearly outline what is authorized promotional material and what is outside the scope of your GPP system or non-sanctioned usage. Your SOPs should be specific enough to clearly convey their intent and scope, but broad enough that you are not limited to the current social media vehicles and circumstances de jour. Think of this as a good auto insurance policy, which in this case should include uninsured motorist coverage. Sometimes it’s not your teenager, but another driver that can catapult you into the abyss or far recesses of the WWW. Maybe the issue doesn’t come from a current employee or department you anticipated would be involved in promotional activities, but rather an unlikely source within or loosely associated with your company. Although good SOPs and GPP systems are constantly evolving, you don’t want to be caught in an incident without the proper coverage. Take the time to focus on how social media is going to impact your company because what you don’t know can hurt you.
I am very interested in hearing from you on how scary and simultaneously exciting the idea of social media is for your company and if you have some best practices that seem to be working in this space. Feel free to email me your thoughts and be kind with your constructive criticisms. As far as your newly minted GPP Regulatory Superhero, well there is much more to come on the subject of social media – let alone the far-reaching subject of GPPs… next time. To wet your whistle, here are just some of the other areas we have yet to explore on this subject: the spiel on the rules, gas money, GPS and checking the odometer…