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PMCPA Case

AUTH/3720/12/22: Complainant v GSK – Blenrep promotional email (no breach)

📅 2022 | 🖉 Dr Anzal Qurbain
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Key facts

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Case numberAUTH/3720/12/22
PartiesComplainant v GlaxoSmithKline (GSK)
ProductBLENREP (belantamab mafodotin)
MaterialPromotional email (PM-GB-BLM-EML-220011; date of preparation December 2022)
AllegationsUnsolicited promotional email (no consent; not relevant to recipient) and imbalanced/misleading due to omission of Phase III trial failure/market withdrawals
Applicable CodeABPI Code of Practice 2021
Clauses considered5.1, 5.6, 6.1, 15.5
DecisionNo breach of Clauses 5.1, 5.6, 6.1, 15.5
Complaint received27 December 2022
Case completed5 January 2024
AppealNo appeal
Panel notes on consent/targetingComplainant appeared to have opted in (account created 2 Aug 2020), had not unsubscribed, registered under haematology/oncology, and engaged with multiple myeloma content prior to the triggered email
Panel notes on balanceOmission of DREAMM-3 results (different population/line; unlicensed indication) did not render the email misleading for the licensed indication promoted

Download the full case report (PDF)

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

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What happened

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  • A health professional complained about a promotional email for BLENREP (belantamab mafodotin) sent on behalf of GlaxoSmithKline (GSK) on 27 December 2022.
  • The email subject line was: “GSK: Rethink your treatment strategy for RRMM patients (contains promotional content)”.
  • The complainant alleged the email was unsolicited (no consent) and they did not treat multiple myeloma.
  • The complainant also alleged the email was imbalanced because it did not mention the reported failure of a Phase III confirmatory trial and subsequent withdrawal from some international markets.
  • GSK explained the email was delivered via a third-party health professional platform using a triggered email program (sent within 24–48 hours after a member viewed content tagged as multiple myeloma).
  • GSK stated recipients had to (1) opt in to receive “relevant information from industry”, (2) be logged in, and (3) have recently viewed multiple myeloma-tagged content.
  • After the complaint, GSK instructed its agency and the publisher to pause all third-party email activity for Blenrep while investigating.
  • On further request, GSK obtained evidence from the publisher that the complainant’s account (created 2 August 2020) was opted in and had not unsubscribed; the complainant had engaged with multiple myeloma content in Nov/Dec 2022.
  • On balance, the Panel considered the Phase III trial referenced (DREAMM-3) related to a different (unlicensed) indication/population than the licensed indication promoted (supported by DREAMM-2 data).
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Outcome

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  • No breach of the ABPI Code of Practice (2021).
  • The Panel found prior permission for promotional emails was in place and the recipient’s interest could reasonably be assumed.
  • The Panel found the email was not misleading due to omission of DREAMM-3 results (not aligned with the licensed indication at the time of the complaint).
  • No appeal.
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