GSK Duac banner ad on Pulse Today: complaint about missing prescribing information (AUTH/3367/7/20) – No breach | PMCPA Case

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Key facts

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Case number	AUTH/3367/7/20
Company	GlaxoSmithKline
Complainant	Concerned UK health professional (as described)
Product	Duac 5% (benzoyl peroxide, clindamycin phosphate)
Indication (as stated)	Topical treatment of mild to moderate acne vulgaris
Material	Online banner advertisement on Pulse Today (ref PM-GB-CBP-BNNR-200005)
Main issue alleged	Could not access prescribing information; ad appeared static and did not provide PI; high standards not maintained
Applicable Code year	2019
Clauses alleged	4.1, 4.2, 4.6, 4.9, 9.1
Panel decision	No breach
Clauses ruled on (outcome)	No breach of 4.1, 4.6, 4.9, 9.1
Complaint received	24 July 2020
Case completed	17 September 2020
Appeal	No appeal

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

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A UK health professional complained they could not access prescribing information (PI) for Duac 5% (benzoyl peroxide, clindamycin phosphate) from an online advertisement on Pulse Today (ref PM-GB-CBP-BNNR-200005).
The complainant said the ad appeared static for several minutes, did not change, and did not provide PI; clicking did not provide a “one click” link to PI.
GSK said the material was a two-frame banner: frame 1 included brand/generic names plus a clearly labelled PI link and adverse event reporting statement; frame 2 included the job number/date and linked through to the Duac webpage.
GSK said the two frames displayed for 15 seconds in total, with frame 1 visible for at least 6.5 seconds, triggered when the viewer approached the ad area to allow time to read and click.
GSK said that if there were a technical issue, a separate static default image would display which included a link to PI and adverse event reporting.
The Panel noted the complainant provided an image of only the second frame and that it appeared to have stayed on screen; the Panel could not determine why the ad did not display/function correctly on the complainant’s screen or why clicking did not take them to the Duac website as intended.

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No breach of the Code was ruled.
The Panel accepted that when displayed correctly the first frame included a prominent “Click here for prescribing information” statement.
The Panel noted the Duac website homepage (the intended click-through) included a link to Duac prescribing information and that PI included adverse event reporting information.
The Panel considered it was unfortunate the ad did not display/function correctly for the complainant, but it was impossible to determine why.
The Panel ruled that high standards had been maintained.

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