by Rohit Bhargava
Category: Digital Influence
Next week Ogilvy will be sharing our point of view when it comes to how pharmaceutical and medical device brands should be allowed to use the web and social media for marketing and promotion. This has been a significant gray area in the past and the FDA has begun the process towards having some updated guidelines set. We are one of over 60 organizations that will be speaking during the two day hearing next week, and the questions will range from everything to what information marketers should be allowed to link to, and how they should be held responsible for content online.
The biggest question that the entire process will raise is how to define the content, messages and conversations online that marketers should be held accountable by the FDA for. To answer this top question, we will be presenting our point of view through “The 3 C’s Rule” …

What do you think - does this “rule” go too far, or far enough towards helping define what messages marketers should be accountable for online? For more context, check our our full FDA presentations on Slideshare:
Crossing the Pond Working with the Media in the UK and USA
November 6th, 2009 at 3:17 pm
Hello - What about contents prepared by someone else, which has some equity participation from the sponsor company? Will that be covered by Collaboration? Just thinking loud…
November 7th, 2009 at 5:09 am
hi,
two comments
1. should apply to all pharma people not just marketers e.g. medics, MSLs, clinical researchers etc
2. what if pharma funds the space but not the creators of the messages in that space?
rgds
Paul
November 12th, 2009 at 11:45 am
[...] Ogilvy’s Presentations Today and Tomorrow at the FDA >> Summary of Ogilvy’s 3 C’s Model For Accountability >> [...]
December 7th, 2010 at 2:16 pm
Good point Paul re no 2: I suspect this depends on whether the pharma has any editorial control as part of that funding of the space.
January 3rd, 2012 at 4:25 pm
springfield mo marketing company…
[...]Introducing The 3′Cs Rule For Pharma Marketing[...]…