AUTH/3470/2/21: GlaxoSmithKline – Seretide digital banner ad (no breach) | PMCPA Case

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Key facts

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Case number	AUTH/3470/2/21
Company	GlaxoSmithKline UK
Product	Seretide Evohaler (fluticasone/salmeterol)
Material	Four-frame digital banner advertisement (ref PM-GB-FPS-WBAN-190016; date of production November 2019)
Main disputed claim	“For the regular treatment of your asthma patients with an ICS/LABA”
Other issue raised	Clarity of access to prescribing information; use of “PI” abbreviation
Complainant	Anonymous, contactable; described self as a health professional
Complaint received	8 February 2021
Case completed	29 July 2021
Applicable Code year	2019
Appeal	No appeal
Decision	No breach
Clauses considered	2, 3.2, 4.1, 4.4, 6.2, 7.2, 7.4, 9.1, 29
Sanctions	None stated

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

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An anonymous, contactable complainant (self-described health professional) complained about a four-frame digital banner advertisement for Seretide Evohaler (fluticasone/salmeterol) (ref PM-GB-FPS-WBAN-190016; date of production November 2019) placed by GlaxoSmithKline UK.
The first frame included the claim: “For the regular treatment of your asthma patients with an ICS/LABA”. The complainant alleged this was false/misleading because Seretide has different strengths and age-related dosing/licensing, and a busy HCP might only see the first frame and assume use in any/all asthma patients at any age.
The complainant cited the digital requirement that where an ad has multiple screens, no screen should be false or misleading when read in isolation, and alleged this had not been applied.
The complainant also alleged it was unclear how to access prescribing information and that using the abbreviation “PI” could be misunderstood as “product information”; “prescribing information” should have been written in full.
The complainant referenced prior GSK Seretide digital cases (AUTH/3179/4/19 and AUTH/3148/1/19) and alleged a breach of undertakings from those cases.

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No breach of the Code was ruled.
The Panel considered HCPs would understand the claim in the context of step-wise asthma guidelines and that Seretide would be an option once an ICS/LABA was appropriate.
The Panel did not consider the claim inconsistent with the Seretide Evohaler SPC or unsubstantiated.
The Panel did not consider the ad unclear regarding access to prescribing information; each frame stated “Click here for PI and Adverse Event Reporting” and the obligatory information was available when clicked.
The Panel did not consider undertakings from the earlier cases relevant to this complaint (which did not concern non-proprietary name placement or certification of a static image).

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