The Social Media Code
Bio/pharma companies have a lot to consider when tackling social media communications, especially within Europe.
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Adhering to rules and codes around promoting drug products is nothing new for the bio/pharma industry, with many companies agreeing to self-regulation practices that comply with codes set out by industry bodies. However, the increasingly prevalent use of social media by companies and their employees has added another level of complexity to consider and seems to be leading to several code breaches.
In the United Kingdom, for example, advertising of medicinal products is regulated by the Medicines and Healthcare products Regulatory Agency (MHRA), but many companies that operate within the UK also tend to self-regulate in accordance with other codes of practice. For prescription-only medicines, companies should adhere to the Association of the British Pharmaceutical Industry (ABPI) Code of Practice, which is administered by the Prescription Medicines Code of Practice Authority (PMCPA) (1).
The ABPI Code of Practice was first introduced in 1958 and has undergone regular revisions since that time to encompass any relevant amendments or additions that may be necessary to ensure the continued appropriate use of medicines (2). In 2023, PMCPA published a new guidance document that specifically tackles the use of social media by bio/pharma companies and their employees (3).
“We recognize that social media can pose particular challenges for companies under the ABPI Code. With its wide reach and international audience, information on medicines can be seen by audiences it wasn’t intended for,” said Alex Fell, director of the PMCPA, in a press release about the launch of the guidance (3). “I hope this guidance will help companies navigate the potential pitfalls of social media, with more confidence, a clearer knowledge of the principles to follow and the legal requirements.”
While this guidance undoubtedly helps companies within the bio/pharma industry, the social media landscape is still proving to be reasonably tricky to navigate with some companies falling foul of the Code of Practice. Most notably, Big Pharma companies Novartis, GSK, AstraZeneca, and Novo Nordisk have all been found to be in breach of various clauses from the code on the LinkedIn platform (4–7). In all cases, the breaches occurred as a result of employees sharing/reposting and/or ‘liking’ posts, thereby distributing content to a wider, public audience.
A review of the potential impact of pharmaceutical promotional activities on social media has demonstrated potentially wider reaching public health concerns from increasingly covert promotional activities on these platforms (8). With such concerns apparently becoming ever more pressing, further regulatory development to ensure patient safety seems inevitable.
References
1. Williams, A.; Mulryne, J. Pharmaceutical Advertising Laws and Regulations England & Wales 2024–2025. ICLG, 7 Aug. 2024.
2. PMCPA. ABPI Code of Practice for the Pharmaceutical Industry: Introduction. PMCPA.org.uk (accessed 7 Feb. 2025).
3. PMCPA. PMCPA Launches New Social Media Guidance for Pharmaceutical Companies. Press Release, 26 Jan. 2023.
4. PMCPA. AUTH/3843/11/23 and AUTH/3844/11/23—Complainants v Novartis Alleged Promotion of a Medicine on LinkedIn. Case Completed on 3 Jan. 2025.
5. PMCPA. AUTH/3810/8/23—Complainant v GSK Alleged Promotion of Jemperli (dostarlimab) on LinkedIn. Case Completed on 11 Oct. 2024.
6. PMCPA. AUTH/3774/6/23—Complainant v AstraZeneca Allegations about Conduct on LinkedIn. Case Completed on 21 Oct. 2024.
7. PMCPA. AUTH/3867/12/23 - Complainant v Novo Nordisk Alleged Promotion on LinkedIn. Case Completed on 14 Aug. 2024.
8. Mor, J.; Kaur, T.; Menkes, D.B.; Peter, E.; Grundy, Q. Pharmaceutical Industry Promotional Activities on Social Media: A Scoping Review. J. Pharm. Health Serv. Res. 2024 15(4) rmae022.
Article details
Pharmaceutical Technology Europe
Vol. 37, No. 1
January/February 2025
Page: 6
Citation
When referring to this article, please cite it as Thomas, F. The Social Media Code. Pharmaceutical Technology Europe 2024 37 (1) 6.
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