AUTH/3371/8/20: Complainant v Pfizer — ‘Hidden’ PfizerPro page for Sayana-Press and missing prescribing information (No breach)

📅 2020 | 🖉 Dr Anzal Qurbain
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Key facts

Case numberAUTH/3371/8/20
CompanyPfizer Limited
ComplainantConcerned UK health professional (as described)
ProductSayana-Press (medroxyprogesterone acetate suspension for injection)
IssueGoogle access to a “hidden” Useful Resources list page without prescribing information
ChannelCompany website (PfizerPro) / search engine indexing
Clauses consideredClause 4.1; Clause 9.1
RulingNo breach of Clause 4.1; No breach of Clause 9.1
Corrective actions notedLimited Useful Resources tile to four links; deleted hidden list pages in backend; re-indexed site on Google to remove historical links
Complaint received12 August 2020
Case completed29 March 2021
Applicable Code year2019
AppealNo appeal

Download the full case report (PDF)


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

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What happened

  • A complainant (a concerned UK health professional) provided a screenshot of a PfizerPro page about Sayana-Press (medroxyprogesterone acetate suspension for injection) showing two “Useful Resources” links (“Order materials” and “Sayana-Press Patient website”).
  • The complainant alleged there was no link to prescribing information on that page.
  • Pfizer explained the Sayana-Press PfizerPro microsite had four pages and each page included prescribing information at the bottom (cost, legal category, and a link to the SPC).
  • Pfizer said the page in the screenshot was a system-generated “hidden list page” for the Useful Resources tile, created in case more than four links were added and a “See All” page was needed.
  • Because there were only two links, the “See All” option was not shown and the hidden list page was not accessible from within the microsite—however, Google could surface it directly in search results.
  • All microsite pages sat behind a self-validation pop-up requiring visitors to confirm health professional status; non-confirming visitors were redirected to Pfizer.co.uk.
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Outcome

  • No breach of Clause 4.1.
  • No breach of Clause 9.1.
  • The Panel noted concern that content not appearing to meet Code requirements could be accessed via Google, but accepted it was a hidden page not intended for UK health professionals.
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