Advertising materials presented at Canadian digital conferences are subject to PAAB review. The principles that govern the PAAB’s review of other Advertising/Promotion Systems (APS) apply similarly to these materials. When submitting for digital conferences, it is important to be clear and detailed about all aspects of the booth, the platform and any and all other interactions. The following provides general guiding principles that reflect current review practice. A detailed advisory will follow shortly.
Healthcare professional audience |
It is the sponsor’s responsibility to ensure that advertising intended for healthcare professionals are limited to healthcare professionals and that these materials are not disseminated beyond this audience. The onus is on the sponsor to understand and be clear with the association/platform about how the content will be restricted, including but not limited to sharing capabilities and search engine results. |
Linkages |
All linkages should be disclosed for review, including but not limited to:
Linkages that are not acceptable in print material are also not acceptable in digital conferences. Examples include but are not limited to:
|
Claims |
All content, both text and visuals, can be considered to be claims and will be reviewed as such. This includes the filenames of downloadable resources (e.g. swag bag, delegate bag, etc.). |
Fair Balance |
Product claims should be accompanied by the indication and the appropriate level of fair balance (for the whole of the product content at the digital conference). The indication and fair balance should be presented with a prominence similar to that of claims and should be easily legible without requiring any additional action from the user (e.g. click to enlarge). The PAAB allows for direct scaling of APSs without resubmission with the understanding that all aspects of the APS remain legible. If an APS will be scaled to a size such that some aspects (e.g. the fair balance) are not legible, it does not meet the standards of the Code and is a violation of Code section 2.4. |
Chat |
By providing this functionality, the manufacturer is exposed to regulatory risk if the chat room becomes advertising.
Downloading/sharing/recording chat room content |
Search |
Content descriptors for APSs provided by the pharmaceutical company for use in the internal search function of the conference (e.g. meta tags, keywords) are subject to PAAB review and should be included in the submission for the APS. Similarly, any other mechanisms whereby the sponsor can influence search output should be disclosed in detail for review. |
Learning Sessions |
Learning sessions that meet the requirements for continuing medical education (CME)/scientific symposia/exhibits per the Health Canada policy document, The Distinction Between Advertising and Other Activities, do not require PAAB review. The PAAB can conduct an opinion assessment to provide a determination if the item meets requirements. It is also the manufacturer’s responsibility to conform with industry standards (e.g. the Codes from applicable industry associations). These should not be linked to promotional materials or activities that refer to the product, including but not limited to corporate booths or websites. |
Corporate and medical booths |
Corporate booths that meet PAAB Code s. 1.5.E can be exempt from PAAB review. Likewise, medical booths controlled and staffed by Medical Affairs can be exempt from PAAB review. However, should these booths be associated with or linked to advertising, they may no longer be exempt. It is important that all linkages be disclosed. |
While digital conferences are a relatively new way for manufacturers to communicate with healthcare professionals, the application of the PAAB Code to digital conferences is reflective of its application to all other advertising material. Essentially, the same principles apply regardless of the form. When preparing submissions for digital conferences, the inclusion of information on the entirety of the manufacturer’s involvement/representation at the conference will help facilitate a smooth review.
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In an effort to constantly serve our clients better, PAAB has unveiled a new electronic submission process(eFiles). Effective January 2, 2008 all submissions will have to be submitted via the eFiles system. Please have a Senior Official (Director level) send an email to the administration team at review@paab.ca with the contact information of the person(s) who will be designated as administrator(s) for your company. Click on eFiles, on the menu, then eFiles Tutorial for a tutorial on how eFiles works.
Please contact the admin team at PAAB if you need assistance with eFiles
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