GSK: Responsive disease-awareness website breached Clause 8.3 due to uncertified desktop vs mobile final forms (AUTH/3819/9/23)

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Key facts

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Case	AUTH/3819/9/23
Company	GSK UK Limited
Complainant	Anonymous, non-contactable
Material	GSK “Tackle Meningitis” disease awareness website (public educational material)
Main issue	Desktop and mobile views differed; Panel considered these to be substantively different final forms requiring separate certification
Pages assessed	Homepage; “Know the symptoms” webpage
Applicable Code year	2021
Breach findings	Clause 8.3 (x2)
No breach findings	Clause 5.1; Clause 2
Sanctions	Undertaking received; additional sanctions not stated
Complaint received	7 September 2023
Case completed	7 November 2024
Appeal	No appeal
Source	https://www.pmcpa.org.uk/cases/completed-cases/auth3819923-complainant-v-gsk

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

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An anonymous, non-contactable complainant alleged GSK’s public disease-education website (Tackle Meningitis) had not been certified separately for mobile viewing.
The complainant pointed to differences between desktop and mobile views on: (1) the homepage and (2) the “Know the symptoms” webpage.
Examples cited included icons appearing on mobile tiles but not desktop, and content/tabs present on desktop but not on mobile.
GSK said the site was “responsive” (one website adapting to screen size) and stated it had been reviewed/approved on desktop and mobile via a staging environment, with evidence recorded in its approval system.
The Panel assessed whether the differences created two different “final forms” and whether each had been certified as required for public disease education material.

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Breach of Clause 8.3 (x2) – failing to certify educational material for the public related to disease (for each of the two webpages assessed).
No breach of Clause 5.1 – requirement to maintain high standards.
No breach of Clause 2 – activities/materials must not bring discredit upon, or reduce confidence in, the pharmaceutical industry.
No appeal.

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