For many companies, dipping their toes into the social-media water is reminiscent of the backyard pool in late spring. The cold water stings your feet. You hang out on the first step for a few minutes until you get used to the cold. Another step and that sting is back, but you're on your way to a fun day of swimming in the sun. Well Big Pharma is still learning to swim, and Google just came along trying to shove them into the deep end.
Last month, Google launched a product called Sidewiki, an extension to the Google Toolbar. With a short download (and a recent version of Firefox or Internet Explorer, with Google Chrome coming soon), anyone can comment on any website and respond to other comments. Pharma companies, concerned with everything from brand perception to adverse event reporting, are now put in a situation where they need to take action or they risk losing control of their brands' online presence -- or worse, having the FDA perceive Sidewiki entries as an integral part of a brand site.
The possibilities of Google Sidewiki are far reaching, and it could be some time before it is adopted broadly. Sidewiki could ultimately fail to resonate with consumers who are overwhelmed by the "noise" of a forum where literally anyone viewing a website can participate. The fact remains, however, that comments are already happening. In November, the FDA will be conducting public hearings about social media "intended to help guide FDA in making policy decisions on the promotion of... prescription drugs and biologics and medical devices using the Internet and social media tools." In the next two months, Pharma companies need to decide what action to take.
Pharma Brands Are Already Getting Wet
Potentially damaging comments are already appearing on the home pages of Pharma sites. Here are some examples:
- Amgen: The first and only comment showing on Amgen's site is a post from a blogger covering the pharma industry, including a link to "The Amgen Files" on the author's site. The Sidewiki comment mentions an unidentified whistleblower filing a lawsuit accusing Amgen of illegally marketing two of its well-known drug products.
- Pfizer: In a similar fashion, another industry blogger has posted the first comment on Pfizer's Viagra.com regarding his blog post, claiming a recent 15-second TV ad in Canada is a "reminder ad," forbidden by the FDA in the U.S.. He also tests the adverse-events reporting arena by claiming that not only did Viagra not work, it caused his arm to fall off. (Let's be glad it wasn't worse and caused other body parts to do the same.) Other bloggers have followed suit.
- Sanofi-Aventis and Bristol-Myers Squibb: The same blogger who posted on Viagra's site dropped by Plavix's site on a deeper landing page, posting a link to his blog post about how the FDA sent warning letters regarding a paid search engine ad for Plavix in April 2009. S-A's Ambien CR site was also commented with more blog links and criticism over the use of actors without disclosing they are not actual patients.
Grab Your Floaties
What can Pharma brands actually do? Waiting until the November FDA hearings doesn't seem prudent (guidance may not come for months -- if ever), nor does waiting on the sidelines. There are four steps recommended for Pharma brands:
- Verify your site with Google Webmaster tools. IT folks or SEO agency help may need to be involved, but this process allows the website owner to "own" the first entry displayed within Google Sidewiki on each page, and enables future alert tracking to new comments. Google hasn't yet released the ability to do this for an entire domain (each page must be registered separately) but I'd expect this functionality to come soon. Nationwide Insurance (a Rosetta client) has done an effective job at claiming the first entry.
- Prepare a content strategy. Develop approved messaging now since that could be a lengthy process at most Pharma companies. Pre-approved comments could be used as disclaimers, provide instructions for adverse event reporting, or provide a concise statement of indications and fair balance.
- Determine when to engage with comments. Ignoring them is not recommended, but there are pros and cons to pre-emptive comments and reactive comments. Make sure that there is internal alignment between regulatory, PR, IT and marketing on the approach.
The Water Might Be Fine...
Ultimately Sidewiki is an unproven, disruptive technology that has accelerated the risks many Pharma companies have by avoiding social technologies. Hopefully the FDA will drop by in November as a "lifeguard." Just don't ask me to name who is David Hasselhoff.
Adam Cohen is a partner at Rosetta and leads the search, online and social media business unit. Rosetta's Healthcare practice has developed a point of view on Google's Sidewiki and Its Implications for Pharma Brands.