Roche’s Social Media Approval Process


Most communication or content approval processes within regulated industries such as pharmaceutical, medical device and biotech companies are set up for maximum accuracy and rigor vs. maximum speed regardless of medium of communication.   However, with the need for speed in social media, is there a compliant middle ground?  As discussed by Elsa and by both Elsa and me in our recent RAPS webinar (free access until 03/31/11), we suggest that one way may be sufficient documentation and pre-approval of certain types of social media by certain highly trained individuals.  As such, I thought you all would be interested in learning Roche’s best practices for social media approval from their well-thought out Social Media Guideline.

1. First, they state that all communications are subject to their internal approval process.  Very smart considering the potential repercussions of not including press releases, training documents and the like.

“All of Roche’s communications have to be correct and clear, and remain in line with our general standards for information. Principally, the
same approval processes as with any other official communication and publications of Roche apply.”

2. They gone on to provide boundaries to balance rigor with speed for social  media, specifically pre-approval of agreed-upon topics and situations with a specific individual:

“Given the interactivity and speed of the new medium, however, it is not realistic to have each response undergo full approval by communications, legal and regulatory. Therefore, you should establish with your usual approval partners a common agreement on a bandwidth of topics and instances that may not require the normal process.” (bolding is ours, not Roche’s)

3. And, lastly, they have close-looped the process by establishing a cross-functional, socially-savvy Social Media Advisory Board as a second opinion:

“Use your professional judgement [sic] as a communication expert, and if in [sic] you have any doubt about a specific message, seek advice from a senior communicator or the Social Media Advisory Board prior to posting.”

If your company is one of the 95% lacking a social media SOP, study the Roche Social Media Guideline and the Pfizer Social Media Playbook to kick off the process.

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One response to “Roche’s Social Media Approval Process

  1. Pingback: 5 Pharma To-Dos with Examples for Managing Facebook “Comments On” | Good Promotional Practices

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