It’s Time to Get Social Without Fearing the FDA

This post originally appeared on PJA Bow + Arrow.

The FDA takes pharmaceutical social media regulation seriously. Zarbee’s Natural Children’s Cough Syrup recently found this out the hard way, when the FDA sent them a warning letter. Among Zarbee’s infractions Zarbees “liked” the following comment made on October 30, 2013: “Love Zarbee’s this is the only medicine we use for our 2 year old. Colds and congestion clear up in 2 days.” The FDA argues that liking this post is considered an endorsement.

It’s no wonder that fear of the repercussions for improperly handling social media communications has kept many pharmaceutical brands from actively engaging with patients.

Social media has historically felt off-limits to pharmaceutical companies.  Big Pharma did not want to touch the likes of Twitter and Facebook, where regulation from the FDA has been unclear and virtually non-existent. But now the FDA has cleared the way for social media usage with clear guidelines. These guidelines outline the proper use and behavior of pharma companies on the Internet.

What this means for your organization:


  • All information on your site must be monitored. Make sure you have a team to check the accuracy of information.
  • You’re not responsible for user-generated content, but you do have to pay close attention to third party sites. You’re responsible for anything on these sites over which you have influence or control.
  • If an employee acts on your behalf on a personal account, you’re responsible.Make sure that they know that they are a representative of the company and to act accordingly.
  • Thorough, accurate documentation is just as important as ever. You’re at fault if any inaccurate information comes out through your sponsored sites and communities.


Clearer guidelines ultimately mean it’s time to get engaged. The IMS Institute found that nearly half of the top 50 pharma companies are on social media, but few are interacting or engaging with patients. The companies that effectively engage early on will win huge kudos with their patients. With fewer regulatory hurdles, the first-mover advantage of interacting with patients far outweighs the risks associated with social media.

One of the problems that pharma companies face is that most pharma social media teams need training. Medtronic, a medical device company, made itself approachable by training their team to respond appropriately and establishing a presence on Twitter, LinkedIn, and YouTube. Their team continuously monitors social media and answers questions promptly and in a personal manner. The company now has 180,000 Facebook fans.

With the rising occurrence of patient complaints about pricing, dry drug pipelines, and demands for transparency, now is the time to (at the very least) become active on social media. According to Pew Research, seven out of ten adult Internet users search online for information about health. Social media allows you to remedy incorrect information and to become a part of the ongoing conversation about your brand. Participating in the conversation in the digital age will return some agency to the management of your brand.

Branding: Honesty is Truly the Best Policy

The lesson: Brands that engage in honest dialogue and respond to complaints will win kudos from social savvy consumers. In contrast, those that don’t come completely clean will lose brand equity.

The Super Bowl was a big disappointment all around this year. The game itself was uneventful and there were no ads that are likely to be remembered. None that we saw on the TV screen, anyways.

Newcastle Brown Ale didn’t put any money into Super Bowl sponsorship, but they did put money into some cheeky storyboards that portray what their Super Bowl ad would’ve been like. According to Newcastle, those ads have garnered a combined  9 million views, more than even some Super Bowl ads posted online. And they did so under the lauded “No Bollocks” moniker.

Newcastle is just one among several brands that have woken up to the value of being earnest. With the widespread advent of social media, people know right away when a brand is lying or full of it. So if you’re beating a family of seals or putting makeup on kittens, the Internet will know. The good news is that brands can get brownie points for coming out and telling the truth.

The most recent example of a company successfully using honesty in their branding comes from McDonald’s Canada. A widely circulated picture on the Internet made it appear that disgusting pink goop, which the industry calls mechanically separated chicken, was in McDonald’s Chicken McNuggets. McDonald’s responded by literally bringing us inside a plant where chicken was processed and explaining the process.

It’s not the most appetizing process, but it’s not as bad as the pink goop myth either.

The Top 5 Most Strategically-Driven Advertisements of 2013

2013 marked what I like to deem as the start of the “human era.” I’m not alone, as Hill Holliday later released a white paper stating the same thing. More than ever, people crave authentic stories and companies that value them as individuals. The rise of social media has allowed people to cut through the bureaucracy of large companies–to see them for what they are. As such, personable, transparent communications  have never been more important. Advertising built on a sound strategy that helps reduce the distance between brand and consumer, such as the ads featured below, will  continue to come to the forefront in 2014.

*Note: These ads were chosen for their ability to utilize insights effectively, they aren’t necessarily my personal favorites.*

1. Chipotle “Scarecrow”

A continuation of the “Back to the Start” advertisement that has received rave reviews from consumers and industry experts alike. It may not be very popular with marketing execs, but it does have 11.6 million views on YouTube. This ad lines up with a consumer desire to know where their food comes from and to live a more healthy lifestyle. It positions Chipotle as daring enough to take on the establishment. The introduction of an app-based game gives Chipotle another medium to show how they “cultivate a better world.”

2. Skype “Family Portrait” Campaign

Rather than explain the features of Skype, these ads show the end benefit to consumers. Skype connects people; it makes the world a close-knit place. Since Skype is free, barring some extra features, all the ad needs to do is get more people to use Skype.

3. PlayStation 4 “Perfect Day”

The juxtaposition between a classic song and visually aggressive behavior provides the perfect backdrop for what console gaming is about. Men (and it has been mostly male since video games were engendered in the late 1990s) want to play online with their mates as a way of socializing in a competitive environment. No other ads have captured the reason men game better than this one.

4. Coca-Cola “Let’s Go Crazy”

Coca-Cola wanted to spread happiness, but it is tough to do that in today’s world of 24/7 bad news. The folks at DAVID The Agency discovered towards the end of 2012 that kindness was the best way to spread happiness, as 98 percent of consumers agree that it’s the key to a happier world. By highlighting positive stories of people giving, they were able to create a campaign that resonates globally.

5. Toshiba “The Beauty Inside” (crowdsourced short)

Mac is cool, but Toshiba…not so much. That’s the problem Toshiba faced when trying to stay relevant to younger generations.  In response, Pereira & O’Dell created several short films that utilized social sites such as Facebook.  “The Beauty Inside” story spilled onto social media and continued beyond the confines of film. It won several awards and made the Toshiba brand a little more desirable to youth.

Honorable Mentions:

Dove “Real Beauty Sketches”

Famous Footwear “A Letter to Mom”

Dodge Ram “Farmer” (See my criticism)

Novel Idea: Stop Publishing Crappy Content

More than 48 hours of content is uploaded on Youtube every minute. That’s a lot of entertaining cat videos competing with a lot of droll marketing videos. So here’s a novel idea: Publish something worth watching–don’t publish crap.

Writing on a serious topic? That doesn’t mean it can’t have some form of entertainment value. A video that talks about retirement probably won’t aim to be funny, but retirees will be much more apt to watch it all if it’s filled with intriguing, fun facts, rather than straight forward explanations. It pays to entertain while you persuade.

An entertaining, persuasive piece of content.

Many companies see frequent content output as a way to achieve stronger brand equity, but fail to realize that it can equally lead to a loss of brand equity.  It’s better to produce nothing than content that is sub-par and that turns off your customer base.

As  content  guru Andrew Davis said on the PJA Advertising + Marketing Unconventionals radio show: “The goal with content creation is that you’re actually building trust with the customer and you’re shortening the sales cycle. And if you’re not driving revenue with content, then it’s a waste of time.”

Content that does not build trust–that does not resonate with your desired target audience–is a wasted investment. How can you expect to build trust with your customers when you shoot a blunderbuss at the market? Content with a more narrow focus can actually drive sales more than content pieces that do not reach the correct audience.

So the next time you think about piecing  together something, clarify the objectives and put yourself in your customers’ shoes. Would they want to watch that video? Would they want to see that photo? Would they read that white paper? Otherwise, it’s time to go back to the drawing board.

Learn how to develop your first content strategy.


Not as Advertised: Moving Beyond Traditional Definitions

In my first advertising class, my professor told us that advertising was: “A paid form of communication with the objective of selling a good or service.” Advertising would therefore be the profession that plans, designs, and writes advertisements. However, so much of advertising these days does not even involve these traditional definitions.

Here’s why:

1. Most advertising agencies are now big data warehouses filled with just as many programmers as account people.

Agencies are waking up to the fact that data is now a determinant of whether an agency lives or dies. As such, they mirror software development companies as much as agencies.  It’s no coincidence that the primary conversation about the Publicis-Omnicom merger has revolved around data. People in ad land wonder whether a merger gives the two ginormous networks the ability to compete with the likes of Google.

2. PR and advertising are increasingly falling under the same roof.

Even a few years ago, it used to be that advertising and PR were separate things. They still are to a degree, but the rise of social media and other forms of multi-way communication has signaled that the two industries will inevitably collide. It’s not unusual to see advertising firms doing PR and vice versa. That’s why buyouts like that of  Allen & Gerritsen’s of Neiman Group make perfect sense. And that’s why articles like the 10 Differences Between Advertising and Public Relations will soon lose relevance.

3. Advertising is a parity industry–agencies need to secure business, not be a slave to definition.

There’s a reason that most agencies have slightly different terms for the same job. Agencies call my internship position anything from human insights to account planning, because they are looking for ways to differentiate themselves. At PJA Advertising + Marketing, I asked my supervisor , Hugh Kennedy, EVP of Planning, about whether the agency at one time focused more on B2C. He said, to paraphrase, that the agency started with a large variety of clients but moved towards a B2B specialization. Through capitalizing on this specialization, PJA was able to grow from a 15 person shop to the present day 63 person shop. In order to survive and thrive agencies need to find something they excel at. The agency that finds a real niche is the one that will last.

Although a catvertising department might not work, John St. projects their unique, humorous culture through this promotional video.