Let’s Talk Social Media

So we asked you all to tell us what you thought posed the least risk when it comes to

a social media post. The results are in, and we’ve got a bit of a split between hashtags and substantiation.

To be honest, we thought substantiation would come out on top, especially considering a recent case (3747/2/23) where a social media post breached Clause 6.1 for not being substantiated. It was the first time we’d seen a breach like that, which really highlights how important it is to make sure all claims are backed up properly.

We could also look back at the MSD disclosure case from a few years ago, where inaccuracies on their disclosure portal led to breaches, including Clause 7.2 for providing misleading information. It’s a gentle reminder that anything inaccurate is, by its very nature, impossible to substantiate!

There’s definitely a chance someone might pick up on this and lodge a complaint.

However, hashtags just about won the poll, and that’s fortunate because it’s a bit easier to talk about them. The PMCPA’s social media guidance points out the risks that come with using hashtags. Sure, they’re great for finding things, but they also bring risks. You can easily link to content that might breach the Code. You might direct people to something that’s false (we're sticking with this point) or, worst-case scenario, something that could be seen as promoting to the public. The guidance also reminds us to make sure that the wording of our hashtags doesn’t accidentally promote products.

#Product #Outcome #Claim

What’s really important, especially in our industry, is that we could be held responsible for any content our hashtags lead to, even if we don’t control it directly. Cases like AUTH/3431/11/20 and AUTH/3441/11/20 show just how careful we need to be.

But honestly, it’s manageable if we just consider all the aspects of the ABPI Code.

Thanks again to everyone who took part in the poll. We’ll reach out directly to the winners of The Code Explained. Stay tuned for more updates, and get in touch with

us at enquiries@compliance-hub.com if you’d like to book your bespoke training to help your teams stay compliant.