By Thomas L. Harrison
We like to be heard if we’re willing to listen. And yet, until now, pharmaceutical companies with a presence on Facebook have understandably been reluctant to “listen” by allowing consumers to post comments on their Facebook pages.
That changes on Monday, August 15, and the change leaves many pharma companies facing a dilemma. Most people agree that social media is an important way to engage with customers, and that it’s here to stay. The scale and level of engagement that Facebook provides is unprecedented; from that perspective, walking away from the platform doesn’t make much sense.
For pharma, though, opening up Facebook pages to commentary also may open a Pandora’s box of well-known issues – and potential liability. Reputational knocks come with the territory, but comments about adverse events and off-label uses – which companies take very seriously – present real challenges.
So how are pharma companies likely to respond to the Facebook dilemma? My guess is that they will adopt one of three courses of action:
First, some companies will choose to go dark – close down their sites and wait for the FDA to issue guidelines on how to report potential adverse events they may discover on their Facebook pages.
This approach, while prudent, may involve a certain amount of wishful thinking. The FDA has long promised social media guidance, and their self-imposed deadlines have come and gone. What’s more, the current rule-making process may be somewhat less precise and prescriptive than many people think – or hope. For example, the FDA almost certainly will not provide specific guidance for individual social networks, such as Facebook and Twitter.
Second, some companies may go dark temporarily, while they build the infrastructure to cope with the real time flow of consumer commentary. These companies understand that a more open Facebook is in their future. But they also understand that this new reality requires structures, policies and staff to make it work.
That leads to the third, and certainly smallest, group – the companies that have prepared for August 15. These companies have had the foresight to build infrastructure in advance. They have figured out what kind of organizational structure and staff they will need to monitor Facebook and other social networking sites. They have the data collection systems in place to capture relevant information. And they have built the protocols and legal oversight for reviewing that information and reporting it to the appropriate regulatory bodies.
These enlightened companies may also find a significant benefit in opening themselves up to commentary on Facebook – an increase in return on their social media investment. As others in the industry have discussed in recent blog posts, companies currently blocking commentary on Facebook are not reaching nearly as many readers as they could – or as meaningfully. That’s because when most people log onto Facebook they first see their News Feed. That’s basically the default setting that catapults you to friends and other pages you most frequently dialogue with. That in turn constantly feeds into the algorithm that determines what your News Feed will consist of in the future. That’s called your “EdgeRank.” A page that doesn’t allow comment basically achieves a zero “EdgeRank.” That can mean that few will ever see your posts, which largely defeats the purpose of having a Facebook page in the first place.
In the end, the change in Facebook’s policy can prove to be an opportunity for the pharmaceutical industry – and opportunity to engage in a heightened dialogue with consumers, customers, shareholders and other interested parties and to create a fuller understanding of the industry’s concerns and achievements.
The alternative is to go silent in the world’s most far-reaching forum. For many of us who’ve worked in the pharmaceutical industry for many years, and care deeply about its future, that’s not much of an option. A Facebook page after August 15 will bring a new degree of vulnerability. But companies that decide to remain on Facebook will benefit from taking part in a powerful community that is already woven into billions of lives whose voices want and need to be heard.
We like our voices to be heard. That’s dialogue. And that’s the beginning of understanding and relevant insight. Pharma has a great story to tell. It should take every opportunity to tell it.
Thomas L. Harrison is chairman and CEO of Diversified Agency Services, Omnicom Group Inc.