10:16 — Monica: I oversee social media over all business units. I have a lot of enthusiasm about social media.
10:18 — Monica: This topic applies to everyone, not just pharma. We know that social is super powerful.
10:20 — Monica: Social became more relevant to Sanofi because that is where our customer are. Those first internal conversations about social we were hard to have. Social creates new opportunities and new responsibilities.
10:22 — Monica: We have three guidance documents to know what the FDA is thinking, but there are also warning letters and untitled letters that help. The FDA cares about things like character limits on Twitter.
10:23 — Monica: The first guidance document tells us that if we take control over something, we may take responsibility for that content. But a company is not responsible if it only provides financial support.
10:23 — Monica: The second document is about character space limitations. FDA says its the message, not the medium.
10:24 — Monica: The third document is about corrections. We need to be balanced and fair. Legally, social is a gnarly world for pharma. Your lawyers are balancing this.
10:25 — Monica: Every little detail can matter when we review, the platform is important. You have to have someone who stays on top of new terms.
10:26 — Monica: A one-size-fits-all policy when you have many business units can be tricky.
10:27 — Monica: Comparisons, case studies, testimonials can be very tricky. We have laws we need to live by.
10:28 — Monica: It can be scary, but we can participate. Social media for us has been an evolution. We’ve gone from internal guidance documents to a social media task force.
10:29 –Monica: Our task force is cross-functional. Our membership in SocialMedia.org is invaluable to these teams.
10:30 — Monica: I think we are very successful on social. As a lawyer I want my clients to be fully competitive. We stretch the canvas, our social teams paints the picture.
10:31 — Example: We had one product where we wanted to accept UGC, so couldn’t edit content. There were a lot of nuances we needed to work out. We had to some content we couldn’t use — like testimonials that showed extra-ordinary results. We weren’t getting the impact we wanted so we moved to picture sharing which worked much better.
10:34 — Monica: Engage your lawyers early and often. As a lawyer, hold office hours.
10:35 — Monica: When you meet with your lawyers, come with alternatives. Know that your policies are. Be open.
Q: Do you have individuals and though-leaders leveraging social? There isn’t much clarity on regulation there.
A: Monica: I faced that. It is a unique challenge. Lead by example, educate first through informal discussions. The language can be hard.
Q: Can you call the regulators like the FDA to get answers?
A: Monica: I would not recommend that. We learn from warning letters, even those that have nothing to do with your space. Learn from what you send to your regulator and works.