We were intrigued by a comment made on Twitter regarding pharma employee involvement with social media:
[It's] important to allow all employees to engage within guidelines and not restrict with bureaucracy
We have worked both with and within several pharma companies over the years. One thing that has been consistent is the blocking of web sites such as Facebook, Twitter, YouTube, and even LinkedIn. Telephony and chat services such as Skype and Google Voice are usually forbidden within pharma companies. Whether you agree or not, companies have good reasons for this:
1. The FDA still has not issued guidelines on how pharma companies can use social media sites and tools. They might become available in QI of this year, but we wouldn’t hold our collective breaths.
2. The SEC has some fairly strict restrictions on communications emanating from listed companies. In fact, SEC guidance on the use of web sites for corporate communications is as recent as 2008. How companies can use blogs, LinkedIn,etc. for communications remains largely an open question.
3. So, unlike companies in other industries, listed pharma companies face a dual challenge of avoiding regulatory scrutiny from not one, but two agencies. But to further complicate the matter, many employees have access to highly confidential information. It would be fairly easy for an unscrupulous employee to buy shares, then “accidentally” pass market-moving information on to investors prior to any public announcement. Thus, blocking the tools to enable this activity protects companies from both unscrupulous employees and the wrath of the SEC.
But this is exactly where external consultancies can be helpful. Speaking from a business development perspective, Lacerta Bio does not have these restrictions. We can actively use LinkedIn, Twitter, and other tools on behalf of our clients. In fact we use these tools to engage, learn, and seek business development opportunities on behalf of our clients.
Now of course, we do not disseminate confidential information without client permission, and any confidential information is only shared via email or via client-hosted secure data rooms. But it’s relatively easy and effective to describe what we’re looking for on our web site, Twitter, and LinkedIn…something that our pharma brethren simply can’t or won’t do beyond vague descriptions on company web sites.
We think that a balance needs to be struck between the need for pharma to engage online more and the regulators’ desires to protect the public (both patients and investors). We don’t foresee a day where every Pfizer or Merck employee will be posting on a corporate Twitter account. However, as AstraZeneca showed us yesterday, some engagement can yield may benefits for the company, their prescribers, and their patients.
Are there ways in which pharma can better communicate with patients and the broader public via social media? Perhaps. We leave the answers to this complex question to others. For one example of a possible approach (and rationale), take a look at this timely post from @GaryMonk, who suggests:
The sooner companies encourage their employees to get involved in online discussions related to their industry, the sooner we can mend our broken reputation. Clearly guidelines may be required but these should be based on common sense and transparent outside of the company.