Pharma regulation in the pixel world.
16th September 2011 by Felix Jackson
Although there are some people who think otherwise, it is clear to me that the regulations that govern Pharma in the particle world apply in the pixel world. The question that I am unsure about is: How?
There are certain things we expect from the people, institutions and commercial organisations that look after our health. Things like: good communication, confidentiality, high-quality decision making based on up-to-date information, safe medicines and devices, transparency and truthfulness.
Things we sometimes take for granted, but things many people can't get. Regulation is used as a way to ensure that these people, institutions and commercial organisations, like Pharma companies, meet our expectations and provide these things.
I like this because I know that if a doctor prescribes me a medicine in the UK, I can be confident that the doctor is a doctor and the medicine is safe for me to take and the best medicine to treat my condition. But, how do we regulate online information provided by Pharma companies?
In a world where people believe information in health and wellness blogs without checking the author's credentials. Where being top in search results for a specific search term implies it is an authoritative source. Where 140 characters of information written on a phone on a bus is influential enough to be shared globally. Should we have laws, guidance or codes of practice for online information? Or just work it out as we go along?
The recent cookie legislation aimed at giving website visitors knowledge of what is being downloaded to their computers is a great idea, but it is being interpreted differently across countries and organisations. Opt in or opt out? In the browser or on the site? A lack of clear guidance being a cause of frustration. Laws are very helpful, but they are very blunt tools.
Many of our regulating organisations are providing helpful practical guidance. But this guidance is often in response to risks seen in specific cases rather than a cohesive understanding of all risks and benefits created by new technologies. Guidance is very helpful, but they are often hard to apply to different situations.
Codes of Practice?
Codes of Practice are very useful. The PMCPA has bravely provided us with digital communications guidance to complement the ABPI Code. But guidance on the Code is rarely updated and the ABPI Code is updated only every two years. Codes are very helpful, but often capture existing practice rather than help with tomorrows decisions.
Within the past year Facebook changed their commenting policy, Twitter released a new user interface, LinkedIn launched personalised news feeds, Google Instant changed the way SEO works, Apple announced iCloud, Nokia announced they are on a burning platform... and many more events changed the way the Internet works.
How can lawyers, politicians and the councils of honourable institutions tell Pharma how to behave next year, when none of us really understand the changes that are happening today?
Well, I'm not sure. But I think the answer lies in understanding the ethical principles behind Pharma activities and applying these ourselves to our own online activities. I believe that the Open-access Social Media Guide by Dr Bertalan Mesko is one initiative that will do this. So I'll put my name on it.