Is it acceptable to have both promotional and non-promotional content on a website?

  • 28

    Clause 28 - The Internet and other Digital Platforms

    28.1 Promotional material about prescription only medicines directed to a UK audience which is provided on the Internet must comply with all relevant requirements of the Code.

    Unless access to promotional material about prescription only medicines is limited to health professionals and other relevant decsion makers, a pharmaceutical company website or a company sponsored website must provide information for the public as well as promotion to health professionals with the sections for each target audience clearly separated and the intended audience identified. This is to avoid the public needing to access material for health professionals unless they choose to. The MHRA Blue Guide states that the public should not be encouraged to access material which is not intended for them.

    28.2 Information or promotional material about medicines covered by Clause 28.1 which is placed on the Internet outside the UK will be regarded as coming
    within the scope of the Code, if: 

    • it was placed there by a UK company/with a UK company’s authority, or
    • it was placed there by an affiliate of a UK company, or with the authority of such a company and it makes specific reference to the availability or use of the medicine in the UK.

    28.3 Information about medicines covered by Clauses 28.1 and 28.2 which is provided on the Internet and which is intended for members of the public must comply with Clause 26.2.

    28.4 A medicine covered by Clause 28.1 may be advertised in a relevant independently produced electronic journal intended for health professionals or other relevant decision makers which can be accessed by members of the public.

    28.5 Public assessment reports (European or UK), summaries of product characteristics, package leaflets and reference material for prescription only medicines may be included on the Internet and be accessible by members of the public provided that they are not presented in such a way as to be promotional in nature.

    28.6 It should be made clear when a user is leaving any of the company’s sites, or sites sponsored by the company, or is being directed to a site which is not that of the company.

The first consideration is the intended audience for the website. If it is to be solely for health professionals then the website must be restricted to health professionals only and how this is achieved is for companies to determine. If the website is for both health professionals and the public/patients the website must be clearly sign posted for each audience, with sufficient content, volume and detail, in each area to provide adequate information. See Clause 28.