If patients have registered for a branded patient website (which has a gated landing page) and opted in to receive emails, can the emails direct them to a page behind the gate? Would this page need to be gated? Or, do they need to be directed to the gated landing page?

Yes the emails can direct them to a page behind the gate however you have to ensure they are still patients. Thus you should either have a revalidation process or a disclaimer telling recipients that they can enter if they are still patients. The onus is on the sponsor to ensure the target audience are patients prescribed the drug to avoid illegal DTCARx promotion. See Code s6.5 and the guidance document “Online Activities”.


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