I this presentation, I present pharma social media “milestones” or “firsts” that have paved the way for others to follow and identify the “Pioneers” who have helped the industry navigate through “uncharted” territory lacking regulatory guidance. I also review some “mistakes” made by both leaders and followers. Only those who learn from the mistakes of their competitors will move forward. Those who learn from their OWN mistakes will move forward fastest! Finally, I offer some ideas for “best practices” and “guiding principles” that may help pharma avoid regulatory actions.

1. Thank
you
for
invi.ng
me
speak
at
the
Roche
Digital
Academy!
Unfortunately,
I
will
have
to
speak
rapidly
in
English
to
get
through
all
my
slides
in
the
alloAed
.me,
but
I
am
sure
you
will
get
a
copy
of
my
slides
–
including
my
notes
–
to
read
at
your
leisure
aDerward.

2. I
this
presenta.on,
I
will
show
you
some
pharma
social
media
“milestones”
or
“firsts”
that
have
paved
the
way
for
others
to
follow.
I
will
iden.fy
the
“Pioneers”
who
have
helped
the
industry
navigate
through
“uncharted”
territory
lacking
regulatory
guidance.
I
will
also
show
you
some
“mistakes”
made
by
both
leaders
and
followers.
Only
those
who
learn
from
thee
mistakes
of
their
compe.tors
will
move
forward.
Those
who
learn
from
their
OWN
mistakes
will
move
forward
fastest!
Finally,
I
will
present
some
ideas
for
“best
prac.ces”
and
“guiding
principles”
that
may
help
you
avoid
regulatory
ac.ons.

3. The
dic.onary
defines
"aficionado"
as
a
“person
who
is
very
knowledgeable
and
enthusias.c
about
an
ac.vity,
subject,
or
pas.me.”
I
have
been
around
for
a
quite
some
.me
and
have
first-­‐hand
experience
with
government
regulatory
and
voluntary
industry
codes
of
prac.ce.
Studying
digital
pharma
has
been
my
“pas.me”
for
many
years.
But
I
don’t
just
study
digital
pharma,
I
document
and
try
to
INFLUENCE
it,
as
you
will
see
in
the
following
slides.

4. FDA’s
famous
14
leAers
alerted
pharma
to
the
fact
that
the
agency
is
now
looking
carefully
at
how
the
industry
promotes
its
products
via
the
Internet.
I
pushed
this
issue
in
December
2006
when
I
blogged
that
“FDA
should
be
taking
a
closer
look
at
drug
promo.on
via
the
Internet.”
And
the
.ming
of
my
2009
April
Fools’
joke
was
perfect
–
many
pharma
people
were
primed
to
believe
the
FDA
actually
came
out
with
digital
guidance
and
several
were
angry
at
me
for
playing
such
a
cruel
joke!

5. The
14
leAers
took
aim
squarely
at
the
so-­‐called
“one-­‐click
rule”
which
was
not
a
rule
at
all
–
it
was
just
what
pharma
people
wanted
to
believe
and
were
lead
to
believe
by
FDA’s
inac.on
prior
to
the
14
leAers.
In
fact,
I
warned
the
industry
about
the
invalidity
of
this
“rule”
or
“received
wisdom”
as
far
back
as
November,
2006,
when
I
debated
it
at
an
industry
conference.
Alas,
only
someone
outside
the
industry
could
see
that
the
Emperor
had
no
clothes!

6. I’d
like
to
believe
that
my
call
for
public
hearings
back
in
April
2009,
mo.vated
the
FDA
to
act.
Unfortunately,
however,
the
hearings
were
has.ly
organized
and
as
a
result,
they
did
not
include
ALL
stakeholders
as
I
urged.
Consumer
advocates
were
missing
and
agencies
and
industry
service
providers
dominated
the
speaker
roster.
Rela.ve
to
the
1996
hearing,
few
pharma
companies
made
presenta.ons
at
the
2009
hearing.
This
shirt
appeared
in
my
presenta.on
to
the
FDA
at
the
November
hearings!
It
was
my
way
of
predic.ng
the
outcome.

7. Congress
put
some
language
in
in
recent
legisla.on
that
requires
the
FDA
to
issue
social
media
guidance
by
July
2014.
Does
that
mean
the
FDA
will
deliver?
If
not,
it
wouldn't
be
the
first
.me
that
a
government
agency
missed
deadlines
imposed
by
Congress.
I
call
this
FDA's
"Social
Media
Guidance
Cliff.”
FDA
Safety
and
Innova.on
Act
(FDASIA)-­‐TRACK
must
include
the
deliverables
with
statutory
dates,
as
well
as
other
tasks
required
to
implement
the
law.
To
date,
no
“other
tasks”
for
SM
guidance
have
been
entered
in
the
database.
Why
the
delay?
Perhaps
the
industry
wants
legally
binding
regula.ons,
not
guidance.
Pfizer,
for
example,
contends
that
FDA’s
proposed
social
media
guidance
“raises
First
Amendment
concerns.”
Guidance,
said
Pfizer,
is
too
vague
and
engenders
“extensive
[First
Amendment]
li.ga.on.”

8. Over
the
2011
Christmas
holidays,
while
most
of
us
were
s.ll
on
vaca.on,
the
FDA
quietly
issued
without
fanfare
"Guidance
for
Industry
Responding
to
Unsolicited
Requests
for
Off-­‐Label
Informa.on
About
Prescrip.on
Drugs
and
Medical
Devices."
Sec.on
VI.
of
this
guidance
addresses
responding
to
unsolicited
requests
on
public
forums
such
as
the
Internet.
While
this
may
not
be
the
"social
media"
guidance
many
people
were
expec.ng,
it
does
include
guidelines
for
responding
to
unsolicited
requests
for
off-­‐label
informa.on
encountered
through
"emerging
electronic
media.”
The
primary
take-­‐away
is
that
such
requests
NOT
be
handled
by
sales
or
marke.ng
people
and
that
responses
should
be
via
private
channels
not
via
open
forums
such
as
on
Youtube,
blogs,
and
TwiAer.

9. As
soon
as
the
FDA
issued
the
public
no.ce
about
the
hearings
and
posted
19
ques.ons
it
was
seeking
to
answer,
I
hosted
a
survey
that
asked
my
readers
to
respond
to
those
same
19
ques.ons.
FDA
asked
“Open-­‐Ended”
ques.ons.
My
survey
asked
respondents
to
vote
on
specific
op.ons
as
well
as
including
comment
boxes.
I
submiAed
the
complete
survey
results
to
the
FDA
docket
and
summarized
the
results
in
my
presenta.ons
at
the
hearing.
The
following
slides
also
summarize
some
results
from
that
survey
as
well
as
comments
submiAed
to
the
docket
by
major
pharma
companies.

10. FDA
asked
“Open-­‐Ended”
ques.ons.
My
survey
asked
respondents
to
vote
on
specific
op.ons
as
well
as
including
open-­‐comment
boxes.
Regarding
accountability,
the
survey
wanted
to
compare
situa.ons
where
pharma
paid
for
content,
provided
grants
for
independent
content,
or
sponsored
branded
ads
that
targeted
specific
3rd-­‐party
content.

11. Another
survey
I
hosted
asked
slightly
different
ques.ons
in
an
aAempt
to
define
some
“best
prac.ces”
regarding
disclosures
and
accountability.
One
“best
prac.ce”
that
I’d
like
to
see
more
companies
prac.ce
is
a
Public
Social
Media
Policy
that
includes
a
no.ce
of
its
transparency/
disclosure
and
other
policies
rela.ng
to
social
media.
About
two-­‐thirds
of
survey
respondents
agree
with
me!
I
know
of
only
one
company
that
has
a
public
social
media
policy.
That
company
is
Roche.

12. Comments
submiAed
to
the
FDA
docket
by
the
drug
industry
allow
us
to
learn
more
about
what
the
industry
considers
to
be
best
social
media
prac.ces
and
where
it
believes
the
regulatory
boundaries
are.
Not
all
pharma
companies,
however,
agree
on
defini.ons
or
where
to
draw
the
boundaries.

13. Back
to
my
survey.
How
pharma
corrects
or
allows
misinforma.on
to
be
posted
on
social
media
sites
it
controls
is
an
important
part
of
its
social
media
policy
that
should
be
revealed
to
visitors
of
such
sites.
Nearly
a
majority
of
pharma
respondents
would
not
like
to
see
FDA
mandate
that
they
correct
misinforma.on
about
products
on
3rd-­‐party
sites,
although
about
one-­‐fiDh
think
misinforma.on
of
real
and
imminent
danger
to
the
public
health
(to
be
determined
by
company)
should
be
corrected.

14. One
important
3rd-­‐party
site
where
misinforma.on
about
drugs
may
be
found
is
Wikipedia.
“If
you
want
your
customers
to
access
informa.on
about
your
products
from
the
quality
perspec.ve
and
in
the
simplest
way,
you
have
to
deal
with
using
Wikipedia,”
said
Dr.
Bertalan
Meskó
(@Berci).
Berci,
however,
did
not
mean
that
pharma
companies
should
secretly
and
selec.vely
alter
informa.on
as
in
this
example:
In
July
of
2007,
employees
of
AbboA
Laboratories
altered
entries
to
Wikipedia
to
eliminate
informa.on
about
a
Mayo
Clinic
study
that
revealed
that
pa.ents
taking
the
arthri.s
drug
Humira
faced
triple
the
risk
of
developing
certain
kinds
of
cancers
and
twice
the
risk
of
developing
serious
infec.ons.
I
hosted
another
survey
asking
respondents
under
what
circumstances
should
pharma
edit
drug
ar.cles
on
Wikipedia.
Based
on
this.
The
best
prac.ce
is
to
appoint
an
“official”
Wikipedia
editor
as
recommended
by
Berci
and
ensure
that
editors
reveal
.es
to
companies.
Although
a
substan.al
minority
of
respondents
feel
that
FDA
should
regulate
pharma
edits
to
Wikipedia
drug
ar.cles,
in
comments
submiAed
to
the
FDA
docket,
PhRMA
suggested
that
manufacturers
would
welcome
correc.ng
misinforma.on
about
their
products
posted
to
3rd-­‐party
sites
such
as
14

15. According
to
my
survey,
the
vast
majority
–
83%
–
of
pharma
respondents
think
it
is
impossible
to
adequately
handle
AEs
from
social
media
sources.
“It's
remarkable
how
very
liAle
we
see
that
meets
the
criteria
of
an
adverse
event,”
said
one
pharma
respondent.
The
criteria
referred
to
are
these:
an
iden.fiable
pa.ent,
a
specific
medica.on,
an
iden.fiable
reporter
and
a
reac.on.

16. The
“iden.fiable
reporter”
is
the
most
difficult
bit
of
“required”
informa.on
to
obtain.
“Many
people
use
the
Internet
to
share
informa.on
and
remain
anonymous
when
doing
so,
even
if
an
email
address
or
other
personal
(excluding
a
name)
is
provided,”
noted
PhRMA
in
its
comments
to
the
FDA.
“Unless
people
opt-­‐in
to
say
they
want
their
informa.on
to
be
shared
with
pharmaceu.cal
(or
other)
companies,
these
companies
should
not
pursue
contac.ng
a
person
if
an
AE
is
reported.
While
not
everyone
understands
that
AEs
can
be
reported
directly
to
the
FDA
or
a
company,
there
needs
to
be
more
emphasis
to
consumers
about
how
they
should/can
report
AEs
so
that
companies
are
not
liable
for
what
they
"happen"
to
find
online.”
In
light
of
all
the
emphasis
US
pharma
companies
place
on
“iden.fiable
reporter,”
it
is
interes.ng
that
ABPI
(UK)
advised
its
members
that
“AEs
should
be
collected
and
documented,
regardless
of
seriousness
of
event
and
whether
or
not
there
is
an
iden.fiable
reporter”
(see
SLIDE
#
X).

17. Pharma
companies
had
some
sugges.ons
for
how
FDA
could
help
the
industry
deal
with
online
adverse
event
reports.

18. Meanwhile,
some
companies
are
sexng
the
“Gold
Standard”
for
managing
online
adverse
event
reports
and
deploying
the
necessary
resources
to
make
it
possible.

19. The
Associa.on
of
the
Bri.sh
Pharmaceu.cal
Industry
has
also
come
out
with
specific
guidelines
for
managing
adverse
events
on
pharma
owned
or
sponsored
Web
sites.
Interes.ngly,
the
guidelines
ignore
the
“iden.fiable
reporter”
condi.on
required
by
the
FDA
for
an
AE
to
be
“reportable.”
The
Brits
have
also
issued
some
guidance
for
using
TwiAer
to
communicate
with
physicians,
making
correc.ons
to
Wikipedia
–
an
issue
discussed
in
a
previous
slide
–
and
appropriate
use
of
metadata.
You
can
find
details
by
following
the
links
given.

20. Despite
the
lack
of
FDA
guidance,
pharmaceu.cal
marketers
have
come
a
long
way
in
integra.ng
social
media
into
their
overall
marke.ng
strategy.
These
are
data
from
the
Social
Media
Readiness
survey
tool
I
have
been
running
since
December,
2007.
Over
300
marketers
working
for
drug
or
device
companies
have
taken
the
survey.
The
survey
asks
ques.ons
to
evaluate
readiness
in
three
categories:
regulatory
(e.g.,
aversion
of
risk),
culture
(e.g.,
sensi.vity
to
cri.cism),
and
personal
experience.
Scores
are
calculated.
This
compares
scores
prior
to
July,
2009,
with
scores
aDerward.
Not
every
pharma
company,
however,
is
at
the
same
point
in
the
adop.on
curve.
Some
are
more
willing
to
take
"risks,"
some
are
more
savvy
about
applicable
FDA
regula.ons,
and
some
are
more
knowledgeable
about
social
media
in
general.
Let’s
see
how
Roche
did.
20

21. These
results,
of
course,
are
based
on
a
very
small
number
of
responses.
It
seems,
however,
that
Roche
employees
feel
that
the
company
is
savvy
regarding
the
regulatory
issues
rela.ng
to
social
media
but
lacks
the
type
of
culture
required
to
be
comfortable
with
making
social
media
mistakes.
If
you
have
not
taken
the
survey,
please
do.
I
can
report
back
updated
results
aDerward.
21

22. Let’s
look
at
more
detail
regarding
how
pharma
employees
rate
their
companies’
readiness
to
deal
with
social
media
readiness
issues.
You
can
see
that
in
the
early
period
prior
to
July
2009,
the
majority
of
respondents
thought
their
companies
had
a
“very
cau.ous”
regulatory
climate
with
only
24%
saying
the
climate
was
“very
aggressive.”
Theses
days,
it
seems
from
these
results,
pharma
companies
are
seen
as
much
less
cau.ous
and
more
aggressive.
I
guess
that
is
due
to
the
lack
of
significant
FDA
“warning”
leAers
being
sent
that
involve
social
media.
In
other
words,
the
“received
wisdom”
is
that
pharma
companies
are
nego.a.ng
the
social
media
regulatory
challenges
without
specific
guidance
from
the
FDA.
Be
careful
though!
The
FDA
hammer
may
fall
again
just
as
it
did
the
day
aDer
April
Fools’
Day
in
2009.
22

23. While
pharma
may
be
gexng
more
comfortable
engaging
in
social
media
without
FDA
guidance,
there
has
been
some
retrenchment
in
adop.ng
social
media
for
marke.ng.
For
example,
there
are
fewer
pharma
Facebook
pages
today
than
there
were
prior
to
August
15,
2011,
when
Facebook
changed
its
policy
on
comments.
ADer
the
change,
which
did
not
allow
pharma
companies
to
turn
off
comments
to
their
Facebook
pages,
many
companies
just
shut
down
their
pages.
"This
new
policy
will
alter
our
ability
to
consider
the
appropriateness
of
comments
before
they
are
posted
which
is
important
to
us
as
a
company
in
a
highly
regulated
industry,”
said
McNeil
Pediatrics
when
it
shut
down
its
ADHD
Moms
page.

24. An
example
of
this
was
the
shutdown
of
the
Psoriasis
Facebook
page
by
Janssen
Pharmaceu.cals.
This
page
–
launched
in
October,
2010
–
was
the
first
pharma
Facebook
page
that
published
comments
BEFORE
reviewing
but
reserved
the
right
to
delete
them
aDerward.
Janssen
cited
its
inability
to
moderate
posts
made
to
the
Psoriasis
360
wall,
one-­‐third
of
which
"men.on[ed]
a
specific
drug
by
name,
or
talk[ed]
about
the
efficacy
of
a
par.cular
treatment
is
(or
its
side
effects)."
In
such
cases,
Janssen
had
to
ask
for
the
post
to
be
removed
or
to
"pull"
it.
Perhaps
this
decision
represents
a
lack
of
commitment
aDer
Alex
Butler,
former
Janssen
Digital
Strategy
and
Social
Media
Manager,
leD
the
company.
Alex
was
the
person
responsible
for
Psoriasis
360.
For
his
efforts,
I
awarded
him
the
first
ever
Pharmaguy
Social
Media
Pioneer
award.
Another
example
was
the
shutdown
of
the
ADHD
Moms
Facebook
page
by
McNeil
Pediatrics.
This
was
the
first
pharma
Facebook
page
–
launched
in
June,
2008.
"This
new
policy
will
alter
our
ability
to
consider
the
appropriateness
of
comments
before
they
are
posted
which
is
important
to
us
as
a
company
in
a
highly
regulated
industry,”
said
McNeil.

25. There
were
examples
of
pharma-­‐owned
or
sponsored
open
discussion
boards
even
before
Facebook
became
popular.
GSK’s
Ques.onEverything,
which
was
launched
in
April,
2006,
is
an
example.
It
allowed
comments
from
consumers
and
posted
them
aDer
review
(“pre-­‐modera.on”).
This
site
is
no
longer
available.
Pre-­‐modera.on
–
where
possible
–
may
be
the
best
prac.ce
for
pharma
social
media
sites,
including
YouTube.
However,
these
days,
very
few
pharma
companies
allow
any
comments
at
all,
which
is
a
shame
because
that
is
the
best
way
to
build
community
and
aAract
more
viewers

26. Of
course,
there
is
good
reason
why
pharma
companies
fear
comments
on
Facebook
as
this
case
demonstrates.
However,
this
could
have
been
prevented:
• Problem
#1:
No
one
at
S-­‐A
was
monitoring
this
site
or
seemed
to
be
responsible
for
it.
• Problem
#2:
There
was
no
policy
in
place
for
what
cons.tutes
acceptable
comments
and
how
comments
would
be
moderated
or
deleted.
• Problem
#3:
There
was
no
social
media
“crisis
management
plan”
other
than
“remove
all
comments!”

27. Sanofi
learned
from
its
mistakes
and
even
spoke
about
them
in
a
public
forum;
i.e.,
my
Pharma
Marke.ng
Talk
show
.tled:
“What
Sanofi-­‐Aven.s
Learned
from
Its
FaceBook
Experience
&
What
the
Experts
Recommend
It
Do
Now.”
In
that
show
I
interviewed
Dennis
Urbaniak,
VP
U.S.
Diabetes.
Listen
to
the
podcast:
hAp://bit.ly/PMT098
The
Sanofi
US
Diabetes
team
won
the
third
(2012)
Pharmagy
Social
Media
Pioneer
Award.

28. Even
the
biggest
pharma
company
in
the
world
can
be
humbled
by
Facebook
backlash.
In
this
case,
it
was
Pfizer
and
the
product
is
not
regulated
by
the
FDA.
Nevertheless,
it
illustrates
how
important
it
is
to
pay
aAen.on
to
what’s
going
on
in
the
social
media
spaces
that
you
own
and
to
have
a
“crisis
plan”
in
place.
The
issue
was
this:
Pfizer
selec.vely
deleted
“nega.ve”
comments
in
an
aAempt
to
control
the
discussion.
What’s
the
lesson?
You
are
NOT
in
control
of
the
discussion
on
social
media.
This
is
pharma’s
major
social
media
conundrum:
(1) pharma
marketers
are
used
to
controlling
the
discussion
(or
not
having
a
discussion
at
all),
and
(2) pharma
marketers
are
legally
responsible
for
the
content
of
the
discussions
on
sites
they
own.

29. Although
Pfizer
got
into
trouble
with
comments
on
Facebook,
it
did
not
shrink
from
allowing
comments
on
other
social
media
sites
like
its
“Get
Old”
community.
On
June
18,
2012,
Pfizer
launched
"Get
Old,"
a
mul.-­‐year
ini.a.ve
supported
by
nearly
a
dozen
advocacy
organiza.ons.
Registered
users
can
post
links,
videos,
photos,
or
stories
(including
comments
up
to
1000
characters)
to
the
site.
You
can
even
submit
comments
to
other
posts
and
"Like,"
tweet,
or
email
comments.
Every
comment
submiAed
is
reviewed
before
being
uploaded
-­‐
a
process
that
is
completed
within
48
hours.
Pfizer
says
it
has
a
social
media
“Playbook,”
according
to
Ray
Kerins,
Pfizer’s
former
Vice
President
of
Worldwide
Communica.ons.
“While
I
don't
want
to
say
it's
proprietary,”
said
Kerins,
“I
also
don't
want
to
make
too
big
of
a
deal
about
it
because
we
call
it
common
sense.”

30. In
the
U.S.,
of
course,
direct-­‐to-­‐consumer
branded
drug
adver.sing
is
permissible,
but
is
it
always
necessary?
I
cri.cized
this
tweet
as
“sleazy
twiAer
spam”
because
I
did
not
follow
this
account
to
receive
branded
messages
but
to
learn
more
about
how
the
celebrity
racecar
driver
Charlie
Kimball
coped
with
managing
his
diabetes
while
racing.
Although
the
adver.sed
product
is
part
of
the
story,
this
tweet
had
no
educa.onal
value
and
was
merely
a
“product
placement”
or
“reminder”
type
of
ad
that
PhRMA
says
should
not
be
used
–
at
least
on
TV.
But
if
it’s
not
OK
for
TV,
it
should
also
not
be
OK
for
social
media.
Anyway,
Novo
Nordisk
par.cipated
in
open
discussion
about
this
and
learned
–
I
haven’t
seen
any
other
tweets
like
this
since.
Listen
to
this
Pharma
Marke.ng
Talk
podcast:
“Novo
Nordisk's
Race
With
Insulin
Campaign:
It's
Not
Just
About
TwiAer”
hAp://bit.ly/PMTalk087

31. Back
in
November,
2011,
I
asked
“Will
a
Pharma
Company
Ever
Host
a
Chat
on
TwiAer?”
(hAp://bit.ly/Twchat).
I
answered
my
own
ques.on
with:
“most
pharma
companies
may
never
directly
host
or
moderate
TwiAer
chats
because
they
can
control
neither
the
audience
nor
the
message.”
So,
I
was
surprised
when
Astrazeneca
hosted
the
first
live
TwiAer
chat
session
on
February
16,
2011.
Despite
dire
predic.ons
of
"PR
failure,"
the
chat
was
a
great
success
and
proof
that
a
pharmaceu.cal
company
can
indeed
host
meaningful
TwiAer
chats.
There
were
a
few
aAempts
by
two
or
three
"malcontents"
to
"hijack"
the
conversa.on.
These
people
made
the
most
tweets
that
included
the
#rxsave
hash
tag,
but
despite
their
aAempts
to
ask
"the
tough
ques.ons"
about
off-­‐label
promo.on
of
drugs
and
Seroquel
side
effects,
everyone
completely
ignored
the
hijackers
and
the
conversa.on
con.nued
as
if
these
people
were
not
even
there.
Tony
Jewell
(@tonyjewell),
Senior
Director
of
External
Communica.ons
at
AstraZeneca
US,
received
the
2nd
Pharmaguy
Social
Media
Pioneer
award
for
his
pioneering
use
of
TwiAer.

32. It
is
one
thing
to
host
a
TwiAer
chat
where
you
can
control
what
is
being
posted
by
your
representa.ve(s)
as
part
of
that
chat.
But
it
is
quite
another
problem
controlling
unauthorized
tweets
made
by
employees
without
the
knowledge
of
your
MLR
people
as
this
case
illustrates.
A
“Global
Social
Media
Policy”
doesn’t
mean
much
unless
• It
is
publicly
available
so
the
company
can
be
held
accountable
in
a
transparent
fashion,
and
• Employees
are
trained
in
the
policy,
which
should
include
sanc.ons
such
as
dismissal
for
viola.on
of
the
policy.

33. Having
social
media
principles
that
guide
how
your
employees
use
social
media
and
interact
with
the
public
online
is
a
good
first
step.
But
if
they
are
to
have
any
effect,
employees
must
be
TRAINED
to
understand
how
to
apply
the
principles
in
the
real
world.
And,
as
with
privacy
policies,
the
fact
that
employees
receive
this
training
should
be
stated
in
the
outward-­‐facing
social
media
policy
that
the
company
publishes.
These
are
just
a
few
of
my
“half-­‐baked”
ideas
pertaining
to
a
public
social
media
policy
for
pharmaceu.cal
companies
to
adopt.

34. Roche
is
the
only
pharmaceu.cal
company
that
has
publicly
disclosed
its
social
media
principles.
Bravo!

35. In
closing,
I
would
like
to
emphasize
that
to
implement
a
strategy
for
using
social
media
as
part
of
your
marke.ng
campaigns,
it
is
important
to
have
a
plan.
But
what
are
the
ac.on
items
for
implemen.ng
your
plan?
This
survey
asked
respondents
to
indicate
how
important
the
following
ac.on
items
are
in
implemen.ng
a
social
media
plan:
• #1:
Get
everyone
-­‐
including
marke.ng,
regulatory
people,
corporate
communica.ons,
C-­‐level
execs
-­‐
on
board
• #2:
Become
a
dialogue
company
-­‐
learn
how
to
listen
and
respond,
not
just
push
messages
out
• #3:
Have
a
sustained
vision/goal
• #4:
Train
people
who
will
be
interac.ng
directly
with
consumers
• Create
a
social
media
Tsar
posi.on
to
oversee
all
the
company's
SM
projects
to
assure
compliance
with
guidelines
• Develop
a
modera.on
strategy
• Develop
guideposts,
internal
and
external
standard
opera.ng
procedures
• Marshall
necessary
resources
-­‐
use
the
best
tools
available
• Unblock
corporate
access
to
social
media
so
employees
can
monitor
and
use
applica.ons
such
as
Facebook
while
at
work
35