AUTH/3369/8/20: Complainant v Pfizer — Ecalta leavepieces accessible via Google (no breach) | PMCPA Case

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Key facts

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Case number	AUTH/3369/8/20
Company	Pfizer
Complainant	Concerned UK health professional
Product	Ecalta (anidulafungin)
Materials	Leavepieces refs ECA359 and PP-ERA-GBR-0169
Main issue alleged	Out-of-date prescribing information accessible online; potential public access via Google
How accessed	Google search results linking to direct PDF URLs behind Pfizerpro
Company explanation	Items withdrawn/unpublished in 2017; PDFs remained in backend folders and were indexable; pop-up gating not enabled on direct PDF URLs
Corrective actions	Deleted PDFs; set embedded PDFs to “private” requiring login/registration to prevent Google access/indexing
Applicable Code year	2019
Clauses considered	2, 9.1, 26.1
Panel decision	No breach of the Code
Complaint received	11 August 2020
Case completed	29 March 2021
Appeal	No appeal

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

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A UK health professional complained about two Ecalta (anidulafungin) leavepieces (refs ECA359 and PP-ERA-GBR-0169) found online via Google search results and direct links referencing the Pfizerpro website.
The complainant alleged the leavepieces contained out-of-date prescribing information (one appeared prepared in 2016 with PI updated in 2014; multiple PI updates had occurred since).
The complainant also alleged there was no check to prevent public access, and that Google search results appeared to promote a prescription-only medicine to the general public.
Pfizer said both items had been withdrawn (April 2017 and October 2017) and unpublished from Pfizerpro, but later discovered that “unpublishing” removed them from view without deleting the underlying PDFs in folders behind the site.
As a result, the PDFs could still be accessed via direct URLs and could be indexed/returned by Google; the health professional self-validation pop-up was not triggered on those direct PDF URLs.
After the complaint, Pfizer deleted the PDFs and set embedded PDFs to “private” requiring full login/registration, to prevent Google indexing and direct access.

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The Panel considered it unfortunate that withdrawn materials with outdated prescribing information could still be accessed via Google.
However, the Panel accepted that the leavepieces had been withdrawn/unpublished in 2017 and that the remaining PDFs were effectively on an internal company site rather than intended for an external audience.
On balance, the Panel decided the unintended Google accessibility did not amount to promotion of Ecalta to the public.
No breach of the Code was ruled.

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