Lundbeck corporate website: partial takedown altered a certified site (AUTH/3466/2/21)

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Key facts

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Case	AUTH/3466/2/21
Company	Lundbeck Limited
Material	Lundbeck UK corporate website (microsite within Lundbeck.com domain)
Complainant	Anonymous, contactable; described as a health professional
Complaint received	01 February 2021
Case completed	27 September 2021
Applicable Code year	2019
Appeal	No appeal
Breach clauses	9.1, 14.3
No breach clauses	2, 14.1, 28.1
Sanctions	Undertaking received; additional sanctions not stated
Key issue	Unpublishing a single page altered a website certified in its entirety, without re-certification

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

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An anonymous, contactable complainant (self-described health professional) complained about Lundbeck Limited’s UK corporate website and referenced a prior complaint about similar material (Case AUTH/3463/1/21).
The complainant alleged the “About us” page was inappropriate for the public/patients and had not been re-approved since 2018 (job number UK-NOTPR-0031 shown on pages).
The complainant alleged the “About us” page linked to a UK “research and development” page, which then linked out to the global site where the complainant said pipeline/products information could be found.
Lundbeck said it intended to take down the UK website in its entirety in January 2021 to determine whether reapproval was needed; the home page was unpublished but, due to human error, other pages remained live until 1 February 2021.
Lundbeck said the UK site had been certified as a whole on 7 December 2018 and included a pop-up warning users they were being redirected to a non-UK website; global pages were clearly marked “GLOBAL”.
The Panel noted the complainant’s link to the “About us” page was not available when accessed by the case preparation manager (the remaining pages had been taken down on 1 February 2021, before the complaint was received on 4 February 2021).

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Breach found: Clause 14.3 and Clause 9.1.
No breach: Clauses 2, 14.1 and 28.1 (and no breach of 14.3 in relation to initial certification date).
The Panel ruled that unpublishing a single page of a website that had been certified in its entirety altered the final form of the website without re-certification (breach of Clause 14.3).
Because robust certification underpins self-regulation, the Panel ruled high standards had not been maintained (breach of Clause 9.1).
The Panel did not consider the circumstances warranted Clause 2 (no breach of Clause 2).

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