| When using patient testimonials on your pharma Web site it's important to be aware of the compliance requirements, said James M. Beslity, senior counsel and head of global privacy and records management at Bristol-Myers Squibb, during CBI's e-marketing conference in Philadelphia yesterday. "Compliance is everybody's responsibility," including marketers', Beslity said. A testimonial may be considered promotion if it makes product claims, and therefore would be subject to FDA regulation, Beslity said. Because of the chance of FDA scrutiny, testimonials should be reviewed by the company's legal department before they are used. Before posting testimonials on their sites, pharmas should have the patient sign a consent and release form that outlines how the testimonial is going to be used, Beslity said. If the patient who provided the testimonial is referred by a healthcare provider, a HIPAA authorization is also needed. |
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