Using social media in aesthetics

01 Sep 2014

With the news that the FDA have released draft guidelines for pharmaceutical companies using character and space-limited social media sites, Aesthetics investigates how the UK is responding to these changes

In 2013, allegedly incorrect advertising of prescription only medicines (POMs) via social media accounted for more than 10% of complaints received by the Medicines and Healthcare products Regulatory Agency (MHRA) in the UK.1
Responsible for monitoring online medical advertising, the MHRA’s annual report recorded 283 complaints, and, consistent with previous years, a high proportion of these complaints related to the advertising of botulinum toxin to the public. Despite the MHRA setting stringent guidelines for digital communications in general, 2013 saw an increase of complaints about advertising on social media, as well as the first complaint relating to advertising via Twitter. 1
Meanwhile in the US, the Food and Drugs Administration (FDA) recognised communication problems with character space limitations on social media sites and internet platforms by releasing draft guidelines. Suggestions include that the prominence of risk information should be comparable to the benefit information featured within each individual character-space-limited communication. An FDA spokesperson, says, “Character-space-limited internet or social media platforms may pose challenges for firms in providing a balanced presentation of both risks and benefits of medical products. This draft guidance aims to aid the industry in effectively communicating benefit and risk information in product promotion.” Based in the US, global aesthetics industry consultant Wendy Lewis believes the guidelines will encourage pharmaceutical companies to embrace social media, who have until now, been hesitant to engage online because of unclear guidelines. She says, “Some companies have taken a one-way approach to social; they have a presence, as in a page or a Twitter account, but do not engage, share, respond to, or otherwise interact, with the general public. Clearly this defies the very essence of what social is all about.”

UK guidelines relating to the use of social media and digital advertising in the health and aesthetic industry are supplied by the MHRA, Association of the British Pharmaceutical Industry (ABPI) and the Prescription Medicines Code of Practice Authority (PMCPA). However the use of social media for aesthetics is further complicated by the fact that some aesthetic companies will not be governed by the ABPI, depending on whether they supply prescription only medicines POMs, and so companies need to address whether these rules of practice apply to them. Worry lies in the misrepresentation of POMs on social media. Advertising POMs to the public is prohibited in accordance with the Human Medicines Regulations 2012, and, as the MHRA report demonstrates, botulinum toxin is of paramount concern for the aesthetics industry. Publicising POMs is subject to the ABPI Code of Practice, administered by the PMCPA, supported by Government legislation, and enforced by the MHRA. The correct use of social media is a contentious issue for both pharmaceutical companies and individual aesthetic clinics. The Committee of Advertising Practice (CAP) provides some guidance on publishing information about botulinum toxin online,2 but as Medical PR Tingy Simoes notes, “Social media in our sector is still in its infancy. It’s skyrocketing in popularity but still used clumsily. Reputations can be badly damaged at the click of a button.”
An MHRA spokesperson explains that the MHRA operate a targeted approach to action on clinics, and other services, offering treatments involving botulinum toxin products and other POMs. This focus however, is primarily on the home pages of clinic websites, and not on Twitter posts or sponsored links. With Twitter, along with other social networking sites, being increasingly used as a promotional platform, the character space limitations it encompasses can make it difficult to know how to use it effectively, and most importantly, legally. Aesthetic doctor, Dr Sarah Tonks, acknowledges these challenges for clinics, and suggests a potential alternative to Twitter. “Google+ is underused,” she says, “But it provides plenty of character space.” Most importantly, she says, there is room to post any potential risks or side effects the medicine may have. The APBI Code of Practice states that when pharmaceutical companies discuss POMs online, only factual and balanced information must be distributed. The PMCPA published informal guidance last year on these digital communications for the pharmaceutical industry, including a section specifically on social media.3
In their new draft guidelines, the FDA has suggested the use of hyperlinks to allow direct access to a more complete discussion of risk information about the product in question. AJ Barroso, digital marketing manager at digital healthcare agency emotive, says, “The way people access information on the web is constantly evolving, and the suggestion to incorporate the use of hyperlinks is a good first step. However, more can be done to govern the use of social media in this industry. This could include greater moderation of social content by governing bodies, and even the development of a tweeting template to aid clarity and consistency in the messages published.”
Acknowledging the new guidelines, an MHRA spokesperson said, “We have recently laid regulations to amend the law to permit companies to include a link to the summary of product characteristics, in place of the prescribing information currently required.”
He added, “We will continue to investigate complaints received and take action where a potential breach of the legislation is identified.”

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