Pfizer: webinar invitation email found to be disguised promotion and sponsorship not clear at the outset (AUTH/2818/1/16)

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Key facts

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Case number	AUTH/2818/1/16
Complainant	Clinical Commissioning Group employee (head of medicines and prescribing)
Company	Pfizer
Material	Email invitation (sent by a third party event organiser) about a webinar
Product	Sayana Press (medroxyprogesterone acetate)
Issue	Alleged lack of consent; alleged disguised promotion; sponsorship not explicit/prominent
Applicable Code year	2016
Complaint received	05 January 2016
Case completed	19 February 2016
Panel findings	No breach Clauses 9.9, 11.2; Breach Clauses 12.1, 22.4
Sanctions	Undertaking received; additional sanctions not stated
Appeal	No appeal

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Reviewed by Dr Anzal Qurbain (FFPM) — ABPI Final Signatory

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What happened

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A head of medicines and prescribing at a clinical commissioning group (CCG) complained about an email sent by a third party event organiser to another CCG staff member.
The email subject was: “Understanding the Clinical and Practical Aspects for the Self-Administration of Sayana Press (medroxyprogesterone acetate)”.
The invite listed “faculty” including a Pfizer UK medical employee, a GP with a special interest in gynaecology (also a member of a women’s health forum), and a nurse consultant in sexual health services.
The email included an agenda and what appeared to be a separate advertisement for Sayana Press, including the description: “A convenient self-administered subcut LARC that gives the ‘I-barely-have-a-moment’ woman a choice”.
The invitation ended with “Thank you for your kind attention. Pfizer Ltd”, the Pfizer logo and prescribing information.
The complainant alleged (1) the recipient had not consented to receive Pfizer promotional material, (2) the webinar was disguised promotion, and (3) sponsorship was not explicitly stated (eg, “this webinar is sponsored by”).
Pfizer said the recipient had proactively opted in via a women’s health forum database to receive information from partners, including “relevant promotional meetings run by pharmaceutical companies”, and that the third party was a partner.
Pfizer said the webinar’s purpose was educational for health professionals/decision makers in women’s health on the use of Sayana Press, with expert clinician presentations and Q&A.

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Outcome

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No breach of Clause 9.9 (prior permission): the Panel accepted the recipient had opted in to receive partner emails including pharmaceutical promotional meetings.
No breach of Clause 11.2 (distribution of promotional material): the Panel noted the frequency limitations on “mailings” did not apply to emails where prior permission existed.
Breach of Clause 12.1 (disguised promotion): the Panel found it was not sufficiently obvious at the outset that the email was promotional and from a pharmaceutical company.
Breach of Clause 22.4 (sponsorship): the declaration of sponsorship was not sufficiently prominent to ensure readers were aware of it at the outset.
No separate ruling under Clause 9.10: the Panel decided the breach of Clause 22.4 covered the alleged breach of Clause 9.10.
No appeal.

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Pfizer: webinar invitation email found to be disguised promotion and sponsorship not clear at the outset (AUTH/2818/1/16)

Key facts

What happened

Outcome

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