Lilly rheumatology website: “share by email” templates breached high standards (AUTH/3112/11/18)

📅 2018 | 🖉 Dr Anzal Qurbain
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Key facts

CaseAUTH/3112/11/18
CompanyLilly
Complaint sourceConcerned UK health professional
MaterialEli Lilly rheumatology website (www.lillyrheumatology.co.uk) including “share by email” functionality and Twitter user guidelines
Products mentionedOlumiant (baricitinib); Taltz (ixekizumab)
Complaint received4 November 2018
Case completed24 May 2019 (site lists completed 25 May 2019)
Applicable Code year2016
Breach clauses9.1
No breach clauses4.6; 4.10; 12.1; 14.5
SanctionsUndertaking received; Additional sanctions: Not stated
AppealNo appeal

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

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What happened

  • A UK health professional complained about Lilly’s rheumatology website (www.lillyrheumatology.co.uk), saying it was unclear if it was promotional or an HCP resource.
  • The site required users to self-declare as a UK health professional before accessing HCP content.
  • The complainant alleged: no statement that the site was promotional; no visible link to prescribing information; issues with black triangle display for Olumiant (baricitinib) including an alleged grey triangle; and that “share by email” functions generated emails that didn’t make clear Lilly had crafted the template and that the link led to a promotional website.
  • The complainant also alleged Lilly’s Twitter user guidelines appeared not to have been updated since October 2016.
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Outcome

  • Breach found: Clause 9.1 (high standards) in relation to email templates generated via “share by email” functionality—recipients were not sufficiently clearly informed that Lilly had created the email template.
  • No breach: Clause 12.1 (disguised promotion) – the website was sufficiently clearly a Lilly promotional website to HCPs.
  • No breach: Clause 4.6 (prescribing information) – product pages in “Our Products” included prominent links to SPC and prescribing information.
  • No breach: Clause 4.10 (black triangle) – complaint not sufficiently specific and evidence did not support the alleged grey triangle.
  • No breach: Clause 14.5 (recertification) – complainant did not evidence that the Twitter guidelines were promotional/required recertification under the Code.
  • No appeal.
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