Digital Insights: Roche Treads Where FDA Has Not

While the Agency has not established formal guidelines for manufacturers' social media activity, Roche's own attempt serves as a model.

By Michele Vaccarello Wagner, Senior Digital Editor

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Not too many of us have been waiting with bated breath for FDA to release formal guidelines for social media after last fall’s “Promotion of FDA-Regulated Medical Products Using the Internet and Social Media” hearing, and nine months out I am still not convinced drug manufacturers will ever get clearcut guidance on what is and isn’t appropriate online behavior for marketing and other activities.

The industry has begun to take matters into its own hands. (In fairness to FDA, maybe this is what it hoped would happen.) Some companies have established marketing guidelines regarding their brands’ social media activity. Roche has just instituted company guidelines not only for professionals performing work under Roche brands but also for employees’ personal and professional social media pages. We should all take note.

One excellent social media rule of thumb which Roche outlines: “It is important that you always remember who you are or who you are representing and what your role is in the social media community.” As we struggle to maintain personal Facebook profiles, professional Linkedin pages, and Twitter accounts which lie somewhere in between, establishing what your intentions are and which self you are representing is key. Mixing your personal and professional lives is a risky operation and must be done, if at all, with the highest level of consideration.

Other takeaways from Roche’s social media guidelines:

7 Rules for PERSONAL online activities Speaking “about” Roche
• Be conscious about mixing your personal and business lives.
• You are responsible for your actions.
• Follow the Roche Group Code of Conduct.
• Mind the global audience.
• Be careful if talking about Roche. Only share publicly available information.
• Be transparent about your affiliation with Roche and that opinions raised are your own.
• Be a “scout” for sentiment and critical issues.


7 Rules for PROFESSIONAL online activities Speaking “on behalf of” Roche
• Follow the Roche Group Code of Conduct and Communications Policy.
• Follow approval processes for publications and communication.
• Mind Copyrights and give credit to the owners.
• Use special care if talking about Roche products or financial data.
• Identify yourself as a representative of Roche.
• Monitor your relevant social media channels.
• Know and follow our Record Management Practices.


Digital media is constantly evolving and even if set guidelines are established, they should be continually updated and revised. Take a look at your presence online and ensure that your digital footprint is something you will be comfortable archiving into the web for years to come. If your company hasn’t established social media rules, borrow from those who have and strive to make your online profile one you’re proud of, both personally and professionally.

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