EU regulations on personal privacy are strict, and almost all European countries have added their own particular nuances. Despite this, there are many things that pharma marketers can do to communicate with their patients in the EU, but, to date, very few are doing much of anything.
Many companies, including Pfizer, Novartis, Serono and UCB have already started down this path and have been very successful. While many of the initiatives have concerned disease awareness advertising, with requests for more information, data is quickly becoming one of the most important corporate assets for today’s innovative marketing companies, and pharmaceutical and biotech companies are no exception. Data is necessary for informed decision-making and for building long-term relationships and corporate value.
With the expansion of computer technology and software development, huge volumes of detailed personal information can easily be collected and analysed, but many individuals want control over records containing information about them. Marketers need to be proactive in understanding privacy guidelines and in diffusing all privacy issues upfront. They need to review their local country privacy and safe harbour guidelines and discuss with their internal medical,legal and regulatory colleagues to present a clear plan on what your objectives are,why you want to communicate with patients and what you will be doing with the information once you collect it.
In 1995,the EU passed a Data Protection Directive to better protect personal information and to harmonize the various privacy laws among its member states.The EU Directive on the Protection of Personal Data prohibits the transfer of personal data to non-EU countries that do not meet the European ‘adequacy’ standard for data protection. As a result, this Directive places important burdens on companies that collect personal data online.
The EU Directive requires the European Data Protection Commission (with representative(s) from each member state) to determine the adequacy of data protection in other non-EU countries, and to prohibit the flow of personal data to foreign countries with privacy systems not considered adequate.
Very stringent rules apply to processing sensitive data (that is, data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and data relating to health or sexual preference). In principle, such data cannot be processed.
Clause 20 of the Association of the British Pharmaceutical Industry (ABPI) Code of Practice for the Pharmaceutical Industry 2006, which focuses on relations with the general public and the media, states specifically that no prescription drug can be advertised to the general public. But clause 20.3 states that companies can work with patient organizations but must ensure that the involvement is made clear and arrangements comply with the code. The code defines three types of data requests: proactive, reference and reactive information.The last type, reactive, is the key one.The code defines reactive information as a response to a direct request. How are you to respond to a direct request unless you have a ‘mail-able’ address (either email or postal carrier)? Hence,“required information”(name and address) is the first and most important type of information needed and allowed for RM.
When collecting information,make sure that you have a clear plan and specific measurable objectives about how you will be using the information:
1Be upfront and specific. Explain why the information is being collected,where it will be stored, how it will be used, who will have access to it,and how to opt out.
2Use accessible language, and include the ability to opt-out easily. Caution should be used when implementing bundled or broad ‘consent forms.’ Here, you should ensure that the language used is simple and clear and that you do not collect too much information that will never be used. All additional communications should also have a check box for consumers to ask that they do not receive additional information (opt-out).
3Review and execute strategically sound outbound marketing or ‘push’ tactics. These acquisition or opt-in tactics will enable companies to run outbound campaigns that are highly targeted and do not overwhelm the customer. Track every interaction to ensure a complete view and understanding of each customer’s experience. Close the loop on every communication to ensure continuous improvement on messaging and relevance.
4Ensure that all of your inbound-marketing tactics are fully leveraged. Inbound interactions (telephone calls, website data, etc.) occur with the permission of the customer, so ask a few profiling or segmenting questions.
5Once you master outbound and inbound contacts, you can begin to coordinate your activities across channels to create seamless customer relationships, and you can then enhance all customer interactions with strategically based marketing guidance. Therefore, each contact with your customers will be more intelligent — and more valuable.
Thinking about your RM programmes in this light allows personal privacy sensitivity to be managed in a way that provides a positive experience for both parties. The customers maintain the privacy they desire and you get the insight you need.