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:
- FDA draft guidance on social reporting
- FDA draft guidance on ISI in space-limited channels
- FDA draft guidance on correcting misinformation
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.
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).
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.
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:
- Machine identification and response
- Social team management
- Editorial, second-level, management
- Optional third-party management
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:
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.
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.