Drug Marketing Moves to Digital: How Pharmaceutical Companies Pitch Consumers Online

For the past 25 years, pharmaceutical companies have been permitted
to market their products directly to consumers. More recently, in the years following
the Food and Drug Administration’s relaxation of direct-to-consumer (DTC)
advertising guidelines in 1997, spending on such promotion grew more than six-fold,
reaching $5 billion by 2008.

In the traditional media of print and broadcast, those DTC ads come
with lots of fine print, including warnings of possible side effects that most
consumers. But now that ever-increasing
amounts of pharmaceutical marketing have moved online, there is another kind of
fine print—the truth about invasive and potentially misleading pharmaceutical
advertising—that consumers may never see at all.

The Center for Digital Democracy recently shared these concerns in a
formal filing to the FDA, the highlights of which follow:

1. Personal Data Collection and Privacy

pharmaceutical and health marketing companies have developed an extensive data
collection and interactive targeting apparatus. Few U.S. health consumers are
aware that they are being identified, labeled, profiled, and tracked on the
Internet while they search or access information on specific conditions or

2. “Condition” and
Behavioral Targeted Advertising

targeting enables health marketers to stealthily follow consumers online—sometimes
across many different websites—gathering details on their interests and
activities, and then offering them marketing messages precisely honed to their
behaviors related to an illness or condition. Digital marketers employ online
“ad networks” to help track and then target individual consumers seeking
health-related information. There are also a number of specialized health
portals and networks specifically created to target consumers based on particular
conditions or concerns.

3. Neuromarketing

It should perhaps come as no surprise that many of the companies
whose products are rooted in scientific research have turned to neuroscientific techniques in an effort
to influence health consumers’ subconscious decision-making processes. Called
“neuromarketing,” such techniques are increasingly employed to research,
design, and implement online advertising campaigns—including those for health
and medical products. NeuroFocus, for example, a firm that specializes in the
application of brainwave research to advertising, programming, and messaging,
uses “neurological testing [that] delves down to the subconscious mind,” far
below such “corrupting factors” as education, language, and cultural variances.
Measuring as many as 64-128 sectors of the brain at 2,000 times per second,
NeuroFocus promises results that are “unambiguous, accurate, and actionable”—results,
we should add, that are achieved without the consumer’s knowledge or consent.

4. Social Media Monitoring
and Marketing

Perhaps most alarmingly, marketers have
developed applications that allow
companies to eavesdrop and analyze conversations by and among health consumers,
taking advantage of users’ networks of friends to orchestrate peer-to-peer
brand promotion. These new surveillance tools monitor conversations among
social network users to identify what is being said about a particular issue or
product. Marketers then work to insert brand-related messages into the social
dialogue, often by identifying and targeting individuals considered brand
“loyalists” or “influencers,” and encouraging them to generate buzz through
their networks of friends. Increasingly, advertisers are using Facebook’s
marketing apparatus—which is largely invisible to its users—to develop a brand
presence on its pages so companies can strongly connect to the social
communications of a very large pool of consumers. Heartbeat Digital’s BuzzScape, for example “allows clients to
monitor discussions that flow in and out of the tens of thousands of message
boards, forums, blogs and social networks that increasingly dominate the online
environment.” As Heartbeat CEO Bill Drummy admits, “In a sense, we eavesdrop on
public conversations among people with a shared interest, then use what we
learn to create interactive marketing campaigns that address the identified
needs, wants and gaps in knowledge of target audiences.” Perhaps the biggest
gap in audience knowledge, of course, is awareness of the fact that online
conversations concerning the most sensitive health concerns have become just so
much grist for the pharmaceutical marketing mills.

5. Unbranded Sites

Another common practice among pharmaceutical companies is the use of
online video and websites to raise the awareness of a particular disease or condition—often without
clear disclosure of sponsor relationships. Ostensibly designed as educational
sites, where individuals can share their experiences with various treatments
for certain maladies, sites such as LivingWithEpilepsy.com or ParkinsonsHealth.com
are also useful to pharmaceutical companies as a “soft sell” opportunity, free
of FDA-mandated risk-disclosure and other advertising requirements.

6. Ad Exchanges

These commercial
arrangements allow companies to auction off individual users to specific
advertisers in real time for ad targeting. Increasingly, the targeting is
accompanied by so-called “data optimization,” which draws on various
information resources to compile more complete profiles of individual users.
For example, Google/DoubleClick’s Ad Exchange Health focus has 36 categories,
from Arthritis and Diabetes to Respiratory Conditions and Sleep Disorders.
Another advertising network, ADSDAQ, offers 50 health-related categories, from
A.D.D. and Alzheimer’s Disease to Weight Loss and Women’s Health. Again, consumers are never apprised of the
way their personal data—including intimate health-related information—is being
sold to the highest bidder.

7. Audience

The division of
consumers into much smaller affinity groups (e.g., Business Travelers, Sports
Fans, Technophiles) for the purpose of targeted marketing is a longstanding
advertising practice. Its use by pharmaceutical marketers, however, especially
in the digital context, raises a number of critical issues. The segments into
which pharmaceutical companies divide their audiences go far beyond demographic
and lifestyle categories to include highly personal and sensitive information
relating to one’s health. For example, as Mark Miller, senior vice president
for healthcare marketer Epsilon, explains, “Segment profiling dimensions
include (but are not limited to): market size, geo-demographic characteristics,
medication usage, self-care behaviors, bio-metrics, insurance coverage/ usage,
needs/attitudes/behaviors and media consumption.” The goal of these data
collection and analysis efforts, moreover, is to influence consumer behavior in
some of the most personal and profound decisions they will ever have to make,
concerning their own and their family’s health.

8. Mobile Campaigns

Many of the same consumer data collection, profiling, and
behavioral targeting techniques that have raised concerns in the more
“traditional” online world have now been brought into the mobile phone
marketplace. As U.S. consumers increasingly rely on their mobile devices for a
wide range of services, including sensitive transactions related to health, the
expansion of behavioral targeting into the mobile world (where it will be
combined with precise user and location data) is especially troubling. “Not
only does Mobile have a ubiquitous presence—with us 24/7,” boasts Peter Nalen,
CEO of Compass Healthcare Communications, “—it can also reach more people, more
efficiently, and with greater targetability.” That’s not the kind of
personalized service, however, that consumers may want or need in the
healthcare arena.

And that’s why CDD has called upon the FDA to remedy this
situation, first by conducting a comprehensive investigation into the use and impact
of digital health marketing techniques and technologies, and then by working with
the Federal Trade Commission and other appropriate agencies to develop a set of
policies for regulating the use of behavioral targeting, data collection, and
other digital techniques in the marketing of drugs and health-related products.