By now, everyone has heard of the social media debacle, in which the FDA issued a warning letter to Duchesnay USA for an Instagram post celebrity Kim Kardashian posted to her personal Instagram page. You know the one- the post promoting Diclegis, a drug indicated for the treatment of morning sickness. In evaluating the Instagram post, it’s fairly clear as to why the FDA expressed an issue with it- the post fails to effectively balance the benefits of Diclegis with the appropriate safety information.
While receiving an FDA warning letter is serious business, by no means should this deter healthcare marketers from considering celebrity endorsements via social media in the future. This was an unfortunate oversight by Duchesnay USA, as healthcare marketers know that any company sponsored branded communications must always balance safety and efficacy information.
So how do you prevent a “Kim Kardashian Instagram Incident” on social media and still leverage a celebrity endorsement of a branded pharmaceutical product? Here are some ideas:
- Never have a paid celebrity (or spokesperson) post any content about your product/drug without writing the original content and having it reviewed and approved by your Med/Legal/Regulatory team
This may seem obvious, but seriously, there is no scenario in which letting paid spokespeople write their own content is a good idea – specifically in the highly-regulated pharmaceutical world. Of course, paid spokespeople will want to add their creative flair to ensure the message reflects their personal style/voice – but there always needs to be elements of the final message that are non-negotiable (such as the balance of safety and efficacy information).
- Always follow the same external promotional marketing guidelines across all branded communications – including social media
If your branded print ads require specific verbiage or safety information, your branded social media posts will need to adhere to the same regulations. Period. If you follow that golden rule, your sponsored content will be within FDA compliance. Does this mean that you may need to squeeze a lot of information into a small space? It may – but that doesn’t mean it can’t be done.
- Consider hosting a celebrity “ad” on your own branded social media channel and have the celebrity “share” the original post on their personal social media pages
While this scenario may have a slightly different impact on how the ad is perceived, it still allows you to reach the celebrity’s vast social network while ensuring all shared content is within compliance (ex: celebrity to repost with “Check out my new ad” or language that does not mention the brand name).
This situation should be a clear reminder that just like any other marketing platform, all external promotional guidelines apply when talking about a brand – and social media is no exception. Social media is nothing to be feared, as long as it is leveraged in a smart, compliant and informative way.