Next week, pharmaceutical, biotechnology and medical device companies will change the way they interact with consumers on Facebook. These changes are occurring, not based on new communications strategies or industry regulations, but because Facebook itself is changing its policies.
On May 17, pharmaceutical, biotechnology and medical device company Facebook users were notified via email of policy changes directly affecting how the industry engages in this social networking service. Essentially, Facebook will no longer allow the industry to disable the capability for people to post comments on their pages. These changes already came into effect for any new pages in June and will now affect existing pages from August 15. No longer can the industry utilise Facebook simply as a ‘broadcast’ channel for messages about their company and different diseases, but instead must either interact or withdraw from the platform completely.
Some exemptions to healthcare pages do remain, however; for example, those that name prescription drugs or devices, and/or those that include prescribing information on the page will still be able to block comments. However, as the vast majority of healthcare-supported pages are open to audiences outside of the US, the majority of healthcare company supported pages don’t name prescription drugs/ devices or include PI – so are not exempt.
According to Facebook, these policy changes “support consistency for the Facebook pages product and encourage an authentic dialogue between people and business on Facebook.” Facebook’s mantra of social openness has been evident from the start, so in some ways this change should have been expected. “We also understand that these changes may lead you to re-evaluate your strategy and presence on Facebook. We are committed to helping you during this transition,” according to Facebook’s email. Yet this change, arguably, could have more impact than any of the long-awaited new FDA digital engagement guidelines. Some outside of the industry may see healthcare companies as overly conservative and unwilling to engage with customers, but one needs to simply look at the recent hacking of Pfizer’s corporate Facebook page to see executives’ fears about protesters targeting the industry’s pages being bought to life.
It’s difficult to assess exactly how many companies and Facebook pages will be directly affected by this change, as the exact number of pages produced or supported by the healthcare industry is unknown (although several leading companies have more than 30 pages globally each). Nonetheless, the initial reaction by many in the industry is one of concern—for current and future plans for engagement on Facebook. In fact, the reaction of many industry leaders with current Facebook pages, particularly those with fewer followers, may be to remove their pages, rather than try to identify solutions that will cause legal/regulatory—and staffing—burdens for monitoring and responding to comments.
The requirements to report adverse events related to drugs and devices; the potential inclusion of inaccurate or off-label information; and animal rights and environmentalist protesters being able to comment – all are potential risks that will need to be monitored, reported, and responded to, in the new Facebook paradigm. Further, the need for immediate response to both positive and negative comments—to show engagement and timely responsiveness with customers—adds a staffing burden that many are unable to address immediately.
The solution would seem to be to instigate some form of Facebook moderation system, combining a level of automation with manual monitoring. A number of suppliers have developed several off-the-shelf solutions and a number of industry sponsors are in the process of selecting and implementing these. These options include automatically filtering certain ‘blocked’ terms and notifying an administrator of suspect ones, automatically deleting any comments as soon as they appear, outsourcing live manual moderation, and real-time moderation via a ‘custom’ wall. The concept of a custom wall is perhaps the most attractive of these options. Without going into the technical details, this application is added onto the Facebook page – effectively mimicking that of the Facebook Wall, but allowing the page-owner to filter who can ‘like’ their page (essentially, who can add comments) and putting comments into a holding zone whilst they are moderated.
The delivery of all of these options still offers challenges:
- Firstly, they largely remain unproven, with most having been developed in direct response to the Facebook changes in the last few months. In looking at current solutions and seeking to develop new ones, we have identified some technical challenges that need to be overcome. The custom wall, for example, doesn’t turn off the Facebook Wall – so all content must be removed from there and the ability to add new comment conversations turned off; otherwise, users could just comment on the Facebook Wall instead. Also, any user still has the option to comment on the profile picture – a function not currently possible to disable.
- Secondly, many of these options change the user experience away from that typical for Facebook. A custom wall, for example, requires users to permit their personal information to be shared with the company (in itself a potential legal privacy issue).
- Third, all of the options we’ve seen still require significant manual moderation. Receiving comments in multiple languages that need to be translated, reviewed and approved in a timely manner is both challenging and time consuming for 30+ pages for each company.
- Lastly, Facebook is continually developing its products and services, so further changes are not only possible but also should be expected. For example, just a couple of weeks ago, Facebook introduced a new ‘preview’ function. Here website links included in comments are previewed directly on the Facebook page, before the page-holder can review it. Any moderator would then need to review the website link as well as actual comment.
Clearly, none of these options currently offers the right solution for the medium term and whatever the solution requires a significant revision of industry social media policies. Whilst the industry adapts to the current round of Facebook policy changes, the most important question remains not what are the best immediate solutions to this newest challenge, but what is the industry’s longer-term strategy for delving into the world of social media and two-way communication with the broader public – while protecting its reputation, and responsibly engaging with customers in ‘real’ time.
– Sam Barnes, Director, Head of PR, AXON