AbbVie voluntary admission: uncertified HCP registration webpage (Clear Horizons) breached Clauses 5.1 and 8.1

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Key facts

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Case	AUTH/3852/10/2023 (listed on PMCPA site as AUTH/3852/11/23)
Company	AbbVie
Issue	Uncertified promotional material (HCP registration webpage for ‘Clear Horizons’)
Channel	Promotional website / registration webpage for UK HCPs
How identified	Voluntary admission after responding to another PMCPA case (AUTH/3834/10/23)
Key root cause described	Third-party agency inadvertently published an incorrect version under the same job code; live page differed from certified version
Applicable Code	2021
Breach clauses	Clause 5.1; Clause 8.1
Sanctions	Undertaking received; Additional sanctions: Not stated
Complaint received	25 October 2023
Case completed	6 September 2024
Appeal	No appeal

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

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AbbVie made a voluntary admission after, during its response to another PMCPA case (AUTH/3834/10/23), it identified that a ‘Clear Horizons’ registration webpage for UK health professionals had not been correctly certified in the form that was published.
The webpage was used to collect HCP contact details so they could access on-demand content in the ‘Clear Horizons’ promotional medical educational series (dermatology therapy area) on AbbVie’s promotional website.
AbbVie used a third-party agency to develop and upload the page. The page was uploaded to AbbVie’s internal approval platform and certified, but the agency then inadvertently published an incorrect version (same job code) to the live site.
The certified version differed from the published version (including a section with a checkbox list of three webcasts/episodes; layout changes; minor wording changes). A certificate for the published version was unavailable.
AbbVie stated the site had an HCP attestation “ramp” and that the incident was isolated human error; it retrained internal teams and the agency and shared learnings with senior leadership via an internal compliance forum.

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