Hi, I wanted to confirm whether an unbranded disease awareness website that does not speak about treatment would need to be a gated site? The website would be targeted to HCPs and we would have campaign emails and digital banners linking to the website. Would this website also be considered PAAB exempt because it doesn't mention treatment?
If the website is disease state only and there is no direct/indirect mention of treatment, it may qualify as exempt. The promotion of the website would also need to have no mention of treatment. Mentioning treatment in a linked tool would be linking advertising to non-advertising (the exempt piece) and render it all advertising and subject to review. Note that there should be no branding elements such as colours or images that would link it to advertising. If the site is targeted to HCPs but there is no gate, DTC regulations would apply as well as HCP regulations. We would suggest this piece be reviewed for use in both audiences.
One additional caution. A disease state piece or campaign which focuses on a pathway or therapeutic area for which no products currently exists or the sponsor has a product coming for, may be perceived as pre-NOC advertising. See Pre-NOC Corporate/Editorial Communications.