The US Food and Drug Administration has been urged to conduct a thorough investigation into the use by pharmaceutical companies of digital marketing techniques.

The health and safety of US consumers must be protected from “inappropriate and potentially harmful use of digital marketing applications that have been embraced by pharmaceutical and health marketers,” and which have given the industry “unprecedented abilities to take advantage of consumers,” claims the non-profit Center for Digital Democracy (CDD).

“Direct-to-consumer digital marketing of pharmaceutical and health-related products requires the FDA to re-evaluate its standards for advertising practices, including what should be considered as truthful and non-misleading,” the group adds, in comments which it sent to the FDA on Monday as part of the agency’s ongoing investigation into pharmaceutical marketers’ use of on-line marketing and social media.

According to the CDD, a digital marketing system which is designed to “more effectively tap into the concerns - and anxieties - of those seeking health information” has emerged on pharmaceutical websites, “unbranded” sites, popular social networks and interactive video channels. However, few people are aware that they are being identified, labeled, profiled and tracked on the Internet while they search or access information on specific conditions or concerns, it adds.

“It is essential that the FDA craft regulatory safeguards for Internet-related promotion, especially since interactive communications will become the dominant form for the delivery of health information and advertising to both consumers and health professionals,” says the CDD’s executive director, Jeff Chester.

He claims that, during the two days of hearings conducted by the FDA last November on these issues, pharmaceutical marketers had “purposely painted a sanitised, storybook image of social media marketing. Missing was data and information related to the powerful capabilities of interactive marketing to promote relationships with specific brands, including its ability to foster what has been called consumer ‘micro-persuasion,’” he adds.

Most of the new interactive marketing techniques which have been “purposely designed to tap into the concerns and anxieties of individuals who are going online to seek health information” remain invisible to consumers, and some may be unfair, deceptive, and/or harmful, according to the CDD. Such techniques include:
- behavioural targeting and other forms of on-line data collection designed to identify, track, profile and target an individual consumer based on information-seeking behaviors related to illnesses or symptoms;
- use of on-line video and advertising networks to create “disease-” or “condition-specific” channels (without clear disclosure of sponsor relationships) targeted at consumers with specific health concerns;
- social media marketing applications that “stealthily eavesdrop” and analyse conversations by and among health consumers, taking advantage of users’ networks of friends to orchestrate peer-to-peer brand promotion; and
- the use of neuroscience research-based techniques – “neuromarketing” - to influence subconscious decision-making processes about pharmaceutical products.

“We want the FDA to make some policies related to pharmaceutical marketing that reflect the distinct nature of interactive marketing,” says the CDD, which has commended the FDA for sending out warning letters to 14 drugmakers in April 2009 relating to their “inappropriate” use of search marketing advertising.