I review 100’s of clinician videos and often i think: technically great, strategically risky. In CASE/0360/11/24 (Complainant v AstraZeneca) a Trixeo video on the company website looked harmless until the PMCPA sliced it apart. I’ll take you through what went wrong, what the Panel was really warning us about, and a compact playbook so your next HCP testimonial video survives clinical scrutiny.
Why this PMCPA case on a HCP testimonial video matters to you
When “authentic” becomes “actionable”: the AstraZeneca lesson
TL;DR
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An HCP testimonial video hosted by AstraZeneca was clearly treated as promotional—not “just experience sharing”.
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One word (“best”) in a patient quote triggered a superlative breach (Clause 14.4).
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Missing safety balance meant the video didn’t stand alone (Clause 6.1), and editorial control raised the bar (Clause 5.1).
What happened (plain English)
In PMCPA case CASE/0360/11/24 (Complainant v AstraZeneca), a promotional HCP testimonial video about Trixeo sat on an AstraZeneca website. It included positive outcomes, a patient story, and wording like “best inhaler”, plus limited safety context. The Panel found breaches of Clause 5.1 (multiple), 6.1, and 14.4. “New” wasn’t a breach (Clause 6.5) in context.
Why you should care
If you brief, script, edit, approve, or certify HCP videos, this case is your warning: testimony equals promotion. Small edits can sink a whole campaign—because the company owns the final cut.
Good briefing prevents breaches — Dr Anzal Qurbain
What happened:
An AstraZeneca promotional video for Trixeo sat on an AstraZeneca-hosted webpage. In the video, a Health Professional talked through their prescribing experience and shared a patient case with positive outcomes.
The complaint wasn’t about “having a video”. It was about what the video ended up claiming and what it left out. Specific concerns included:
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Use of the word “new” (suggesting novelty).
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A patient history that referenced a heart attack context (raising questions about cardiovascular cautions and whether the story was framed safely).
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A patient-style line calling Trixeo the “best inhaler” — which, in promo, reads as a superiority claim and triggered Clause 14.4.
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Missing safety balance and context, meaning the asset didn’t feel “complete” on its own — a Clause 6.1 issue (you can’t rely on a PI link to do the balancing).
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Process gaps: briefing and approval didn’t sufficiently protect against these predictable risks, engaging Clause 5.1.
The Panel did not uphold breaches for “new” (it was seen as “new to them”), and it didn’t uphold the narrow unlicensed-indication point — but it still queried the cardiovascular framing.
Promotional content must stand alone — Dr Anzal Qurbain
What the Panel was really saying — the 3 hidden rules
In CASE/0360/11/24, the Panel wasn’t just picking at wording. It was signalling three “hidden rules” that explain why HCP testimonial videos so often trigger a Breach of the Code, a Misleading Claim, and failures of High Standards.
Rule 1: Testimonials = claims (even in a patient voice)
“Best” sounded like a human story, but the Panel treated it as a superiority claim. That’s why it landed as a Breach of Clause 14.4. If it’s in your promo, it’s your claim—and it needs robust support or removal.
Rule 2: Balance must be visible in the asset
The video couldn’t rely on a PI/SmPC link to “complete” the message. Promotional material must stand alone, with clear limitations and safety context on-screen/in-script. That’s the core of the Breach of Clause 6.1.
Rule 3: Editorial control = regulatory responsibility
The Panel effectively said: you briefed it, filmed it, edited it, hosted it—so you own it. Weak Code briefing and what stayed in the final cut became a Breach of Clause 5.1.
If you host it, you own it — Dr Anzal Qurbain
Where teams get caught (patterns I see)
In CASE/0360/11/24, the Panel’s message was simple: if you host it, you own it. These are the repeat traps I see when teams think HCP “experience” videos are safer than claims-led promo.
1) The brief is about cameras, not the Code (High Standards)
Teams brief on lighting, locations, and “be natural” — but miss balance, SmPC cautions, and how to avoid a Making misleading, exaggerated claim. The Panel flagged inadequate briefing/approval under Clause 5.1.
2) “Authenticity” becomes a loophole (it isn’t)
Unscripted praise is still promotional once edited and published. Leaving “best” in a patient quote can imply superiority and trigger Clause 14.4.
Authenticity doesn’t override accuracy — Dr Anzal Qurbain
3) Final-cut bias: punchy lines win, qualifiers lose
Editors keep the snappy soundbite and drop the safety context. That’s how you end up with material that doesn’t stand alone (Clause 6.1) and relies on a PI link to “complete” it.
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Briefing omission: no explicit “avoid superlatives” + “include SmPC qualifiers”.
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Script edits: qualifiers removed to improve flow.
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Certification oversights: branding checked; balance and hanging comparisons missed.
Do this instead — The practical playbook (brief, script, certify)
Brief (reduce editorial risk before the camera rolls)
For Promotional video compliance, I brief HCPs on Code principles, not just filming. Include: no unqualified superlatives (Clause 14.4), balance inside the asset (Clause 6.1), and the reality that you have editorial control (Clause 5.1). Add SmPC cautions you expect to be mentioned on-camera (don’t rely on a PI link).
Script (control the red flags)
Co-create a tight script and a “red-flag phrases” list. Treat every testimonial as a mini-label that must stand alone.
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Script-safe wording: swap “best” for
“in my experience, it can be a good option for appropriate patients”or“one option I consider, alongside others”. -
Ban “hanging comparisons”: require qualifiers like
“for some patients”,“when clinically appropriate”, and“based on the SmPC”.
Certify (prove Clause 5.1 discipline)
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Sign-off confirms the Promotional video is balanced (Clause 6.1) and avoids implied superiority (Clause 14.4).
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Keep an editing log: what was removed/kept, why, with timestamps, version control, and SmPC references.
Treat testimonial scripts like mini-labels — Dr Anzal Qurbain
The AskAnzal risk test — 5 yes/no questions
I use this AskAnzal risk test as a final pre-publish gate for any HCP testimonial video. It forces binary answers on the exact failure points the Panel highlighted in CASE/0360/11/24—superlatives (Clause 14.4), “standalone” balance (Clause 6.1), and company control/briefing standards (Clause 5.1). If you can’t answer cleanly, you’re walking into a Code Breach.
Five quick checks save you from longer headaches — Dr Anzal Qurbain
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Superlatives: Does the video include any superlative (e.g., “best”) spoken by an HCP or patient?
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Standalone balance: Does the asset clearly state key safety considerations and limitations without requiring the viewer to click a PI/SmPC link?
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Briefing proof: Was the briefing document specifically signed off to instruct against promotional superlatives and hanging comparisons?
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Editorial traceability: Is there an editorial log showing who edited or removed lines and why?
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Certification: Was medical/compliance certification obtained?
Interpretation: “Yes” to Q1–Q4 = high risk and likely rework/hold. Q5 must be “yes” before publish.
10 things to lock in before you film an HCP experience video
In CASE/0360/11/24, a Promotional video on a Product Website still breached because the company had editorial control, the story wasn’t balanced/standalone, and one “best” line became a superlative claim. Pre-filming controls materially reduce downstream breaches.
Lock the basics before you roll camera — Dr Anzal Qurbain
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Approved brief that includes Code principles + key SmPC cautions (not just filming tips).
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Red-flag list (3 words): “best”, “superior”, “safest”. Keep it memorable on-set.
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Script-safe phrasing bank for HCPs/patients (see below).
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Safety lines to include in the asset so it’s balanced and sufficiently complete (Clause 6.1).
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Consent forms stating company edit rights and final cut control (Panel expectation under Clause 5.1).
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Named editorial owner with sign-off authority.
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Version-controlled script + editing log (what changed, why, who approved).
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Med/Compliance checklist pre-publish (claims, balance, references, context).
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Hosting plan: if it sits on a Product Website, assume highest scrutiny and ensure it can stand alone.
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Monitoring plan for unauthorised edits/comments post-publication.
Script-safe wording (swap “best”)
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“One option that worked well for this patient.” -
“In my experience, it helped improve control alongside appropriate review.” -
“A suitable choice for some patients, considering SmPC cautions.”
Script-safe wording: safer alternatives to “best”
In CASE/0360/11/24, one patient line (“the best inhaler”) was treated as a superlative in promo and triggered Clause 14.4. That’s the trap: a warm testimonial can still become an Exaggerated claim and a Misleading claim once it’s on your branded site and you have editorial control.
Why this Script-safe wording works
Qualifiers reduce the impression of unverified superiority and preserve authenticity. Framing outcomes as experience (“in my experience…”) avoids implying universal results, while still sounding human.
Safer swaps (keep the meaning, drop the risk)
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“The best inhaler” → “An effective option for many patients”
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“Works for everyone” → “Some patients have shown meaningful improvement”
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“Always my first choice” → “A treatment I often consider when appropriate”
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“Better than X” → “Has shown benefits in certain studies (where appropriate), with clear context”
Micro-script you can brief to camera
“In my experience, for some suitable patients, I’ve seen improved symptom control. I consider it alongside other options, in line with the SmPC.”
Words change risk — choose them deliberately — Dr Anzal Qurbain
Conclusion: mentor-style takeaway and next steps
If you take one thing from this Case Summary (PMCPA CASE/0360/11/24), let it be this: an HCP “experience” video is still promotion. The Panel treated AstraZeneca’s hosted Trixeo film as a certifiable asset, not casual content—so a single “best” in a patient quote became a superlative (Clause 14.4), missing balance meant the video didn’t stand alone (Clause 6.1), and editorial control raised the bar on what stayed in the final cut (Clause 5.1). Process, wording and evidence context together decide whether a testimonial crosses into a breach.
My mentor-style next step for every ABPI Final Signatory and marketer: build compliance into the creative timeline, not the edit suite. Brief HCPs on Code principles (qualification, SmPC cautions, no implied superiority), lock the safety “must-say” lines early, and capture final sign-off in writing linked to the hosted asset for evidence. Don’t rely on PI links to do the balancing work—your video must carry it.
Turn process into protection — Dr Anzal Qurbain
If you want the templates I use (briefs, checklists, script-safe wording), follow AskAnzal Insights. Turning cases into culture — Dr Anzal Qurbain | AskAnzal.
TL;DR: • HCP testimonials are promotional claims — editorial control means high standards and briefing matters. • Superlatives like “best” and unbalanced patient stories trigger Clause 14.4 and 6.1 breaches. • Brief, script and certify: include balance, SmPC cautions and avoid hanging comparisons.
