Module 17 2024

03/12/2024

Online

• Same rules – but practical differences

• Don’t forget: some MSs restrict DTC advertising!

• Don’t hide qualifications on other pages

• Watch out for “rapid responses” from marketers

• Website/social content is advertising if directed to sale of a product

• UGC isn’t advertising unless “adopted” but consider this also from a Vigilance perspective and note some MSs impose specific requirements

Take care with targeting

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Rankings and reviews

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The Organisation for Professionals in Regulatory Affairs

TOPRA MSc Module 17

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Online – brand ambassadors and influencers (excluding HCPs)

• Ads must be “obviously identifiable”

• Payment + control = advertising

• Affiliate marketing = advertising

• Disclosure: #ad, #advert, #advertising – avoid anything else

• Up-front, prominent and obvious

• Consider how ads are displayed on different devices and platforms

Influencer agreements

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Unsolicited posts

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The Organisation for Professionals in Regulatory Affairs

TOPRA MSc Module 17

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