Underscore’s POV on the 11/2009 FDA hearings regarding digital DTC

 The following is Underscore Marketing’s POV on what the FDA should consider is developing guidelines for digital DTC advertising.

1.       The internet has changed human behavior as it relates to health and wellness.

The internet has enabled consumers to form hypotheses regarding their health and pre- or self diagnose medical problems.  Whereas prior we would rely on in person advice from trusted medical professionals and socially from peers and/or  family members, we now turn to the internet to self educate before we do the former. As the web has evolved over time the sources for this online information have evolved from strictly content and pictures to live discussions, forums and debates. In essence, the seeking of health and wellness information has returned to its social and interactive roots. The major change is the ability to monitor, document, and censor the conversations that technology has enabled.

2.       As in the real world, responsible advertisers cannot be held accountable for what consumers say or do regarding their brands within the social media realm.

We could not predict or censor what neighbors would say to one another about a brand, or be a fly on the wall during a medical exam pre-Internet, but brands still found ways to influence the conversation. Examples include: doctor detailing, samples, sponsored hand-outs and consumer events among others. It’s true that just because technology enables us to monitor conversations it doesn’t mean brands can freely interject. On the other hand, it does not suddenly make brands responsible for what consumers say and do online with said brands.

There are many instances where brands should interject—where they can educate, correct misinformation, or offer  additional resources. The key is establishing guidelines for responsible and transparent brand participation in social media. Consumers should be clear when they are engaging with a brand representative and fully understand what said representative is able to do. Telling people what your role is and what your limitations are is honest. It allows people to set the right expectations and act accordingly. However, brands should not be held responsible for consumers who act and speak outside of the communicated rules of engagement.

3.       We must lobby hard for agreement that “a click away” is sufficient for any fair balance/disclaimers that are mandated in Rx/OTC advertising. It should not appear in initial banners, buttons, videos or search copy, but be a single click away that is highly visible.

This is important for many reasons, most importantly digital effectiveness. The bottom line is that people use the internet to seek a wealth of information (health at the top of the list), to solve personal problems,  for personal entertainment and also for utility (scheduling, maps, weather, etc.). Regardless of usage patterns by segment, there is a common behavior of clicking to drill into information. This was established from the beginning of the commercial web through “step search” and has not changed as adoption and usage has increased over time.

4.       Common language for the “one click away” should be adopted by all advertisers.

If we do this we will train consumers to immediately understand where they find the details without having to consume large parts of the ad space explaining where to click and what to expect there. Much like people expect to click to drill into details, they will quickly associate a common phrase in health advertising with an expectation.