Klick Health

Social Moderation: Layers of Safety

Senior Director, Social Media

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Moderation of social platforms is a critical piece of any social program in any industry but is especially important in pharma. The FDA's guidance on the ownership of user-generated content is fairly clear by the regulator's standards and places the ownership of user-generated content (UGC) on the pharma company when it "influences" the content.

Much digital ink has been spilled on the FDA’s approach to social media, just a few of our posts over the years:

This issue of ownership has created the requirement in pharma social platforms for very diligent moderation. The way we look at moderation here at Klick is in four phases: two machine-based and two or three human-based.

Comment lifecycle on (some) social properties (varies per platform)

If we think about the life of a comment on a pharma social property, it goes through a number of phases:


The user has decided that the content presented is interesting enough to comment on. This user is automatically higher value than others and is almost certainly targeted by the platform for further messaging (no social platforms reveal their targeting algorithms).

Automated Moderation

This moderation is performed by tools such as the platform itself (think the “moderator blocklist” on Facebook) and tools like Klick Comment Moderator (KCM). The automated moderation tries to ensure that the content being posted adheres to the property terms of use. Because the terms of use for pharma are a bit more restrictive than other industries these posts are often hidden by default, depending on the capabilities of the platform.

One note about comment moderation… the range of options for comment moderation really favors Facebook. There is no other platform that provides the same level of control and flexibility. For our full POV see Facebook First for Pharma.

Human Moderation

The machines run 24/7 helping the human moderators who come in and do their magic on a human, and humane, schedule. By using pharma professionals for moderation a brand can ensure that each interaction is handled correctly according to the response rules outlined in the brand’s platform documentation.

The best practice, from Klick’s perspective at least, is to provide a multi-layer moderation envelope on a brand platform that includes:

Providing multiple layers of response based on comment sensitivity provides the best-in-industry moderation solution and using automation allows Klick to do this with a local team who stay on top of FDA regulations and industry best practices.

We can see the breakdown of comments something like this:

Volumes of comments and their final disposition


Not all comments need a response, in fact with an active community the moderators should only be engaging for the most robust comments. When a comment is needed though it must be either pre-approved from a list or created inside an agreed upon framework. We have seen both approaches in the industry.

Klick believes that best practice here is to have two sets of eyes review the reply before posting. Most of the time this is redundant, but sometimes those second eyes can see something that the first set did not and the platform is made stronger because of the process.

End State

In the end the brand property gets what it needs: user comments added to it’s material that are relevant, spontaneous, and within FDA guidelines.


More About the Author

Brad Einarsen

Brad is Klick's Senior Director leading the social practice. His group ensures that clients get the best bang for their buck on the social platforms.

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