Social Media Channel for Regulated Industries

I can't listen, even if I want to! Source: Flickr

Pfizer tomtomed about what they call as the first slideshare channel from a regulated industry player and many social media pundits have taken up arms against this claim & termed the channel as not social at all since Pfizer is not interacting, but rather only using it again as a channel to publish its materials - a very one way communication.

I thought it would be prudent to make it plain about some of the aspects of social media that is not conducive to the regulated industry, especially Pharma. Of course there are far better informed people than me in this area, but this is just for my audience. Also, these are only my limited understanding, what I have gained by working with clients in these industries as well as attending seminars & being a panelist in their industry meetings.

Importantly, I am not a lawyer or an expert in these areas. You should not hold me responsible for anything that you do with the information I write in this post, if you are ok with that, please continue reading more after the jump. (If anybody from Pharma industry gets to read this & there are any factual mistakes, please do leave a comment & I will make the corrections).

First of all, we need to understand that before a Pharma can publish any material about its products, whether promotional or educational, it has to adhere to some stipulations from the FDA which fall under DDMAC, for example they cannot just mention about the benefits but also have to explicitly mention about the risks of their drug. Well there are far more, but its all about the content, not the channel. So as a simple thumb rule, if you are a Pharma marketer, just be aware of the FDA/DDMAC rules that apply to your traditional promotional/education content, be it text or video or audio. Similar rules apply to the content of the video irrespective of whether that gets aired on TV or gets published on youtube.

So we have some clarity on the content creation part. If not, go on, hit this link and listen into the podcast with an FDA official to hear about it. And do you realize that FDA is a regulator only for the USA & that in the EU Pharma companies cannot do promotions about their prescription medicines? The rules are stricter there.

So, it is no wonder that Pfizer's SlideShare channel has so less about its products and has more about its corporate functions &/or performance.

Ok, now we all know that social media is not only about publishing content but also about listening & responding/engaging with the audiences/community. Heres the issue for Pharma (and I believe for Financial too, not too sure) - if ever a pharma employee gets to hear about an adverse event about a drug their employer produces (comments like, you know I used XYZ for my headache & I think my mouth was going dry) they have to immediately get more information about that adverse event & file it with FDA (similar rule exists for Europe too).

And the FDA guidelines (or are they rules?) for Adverse Event reporting state that you have to get the patient details, the doctor details, the ailment details, the drug & the adverse event details before you can even submit them to FDA. Thanks to countless lawsuits & fines, etc. the Pharma companies typically have it like a code of conduct that they should follow up on the conversation or whatever & dig out the information if they come across adverse events. Anywhere. Including social media.

So if there is somebody writing on the Pfizer Viagra website using Google Sidewiki that their arm fell off after taking their medication, what is Pfizer to do?

It is an adverse event, not spam! Sorry, you and me can argue about it until the cows come home, but that's the Pharma industry for you Mr. Social Media Guru/Pundit (whatever other term you use to blaspheme these exalted roles).

I am given to believe that in the financial industry, if you hear about a complaint you are bound to service it. I am not too sure about it & its all hearsay.

The point I am trying to make is listening (& engaging) in social media is not an easy job for the regulated industry. There are various factors in play that can help them, mainly technology, but also importantly educating its employees about these aspects as well as getting clarity from the regulatory bodies about the implications of this new channel that can talk back on the existing policies.

These are just a few of the pains of the regulated industry. I have already blogged about the social media archival requirements in the financial industry. If you are aware of any more such issues, please do share it with us via the comments. :)

Update: John Mack (@pharmaguy) points us to this report on how Pharma can overcome the listening problems and also shares why Pfizer would win his "Close, but no Cigar Award".

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• Pfizer Channel a First for Regulated Industries, a Must for Business (slideshare.net)
• Pfizer's Adverse Event Reporting Warning Letter: Those Who Don't Learn History... (invivoblog.blogspot.com)
• Social Media and Pharma: Adverse Events Reporting Revisited (biojobblog.com)
• CORRECTED - Pharma seeks FDA clarity on risky drug safeguards (reuters.com)

Is @oldspice engaging with the social customer - PR or SCRM?

Flintlock pistol flashes. Source: Denver Direct

If you are from the US & watch TV or follow twitter, facebook and/or youtube closely to catch the fleeting memes as they unfold, you must have obviously noted the exalted buzz around the recent ad campaign to revive P&G's Old Spice brand, first on TV and then on the aforementioned social media channels.

Its been a hugely successful PR/Marketing campaign and I hear it to have proven ROI too already! I will not get too much into the details of the campaign & what worked and if it can be replicated or not, etc. You can get those from other sites far better suited to the purpose than mine. (some links provided below). I did not get into the discussions initiated by Jacob Morgan either (who initiated me to Sushi when I was in SF in May 2010 & is an up & coming Gen Y dude in the Social CRM arena).

What prompted to post me this commentary on that awesomely brilliant & tough campaign (Imagine 200+ videos within 2 days, can you script it all? Or even act in those many short clips?) is the editorial pick by CustomerThink.com of a post by old colleague Harish Kotadia (and currently an independent consultant) claiming this to be the best ever Social CRM campaign.

I was intrigued & confounded. I believed that this ad campaign was a brilliant stroke of genius & hard work that leveraged the power of social media & networking sites to make a marketing campaign viral. I however did not think of the campaign as a holistic Social CRM campaign. Many people claimed that the brilliance was in the engagement that the campaigners had with the social media users (lets call them social customers here because they are social media users who are potential customers of Old Spice).

I am a huge proponent of businesses listening & engaging on social media (in addition to influencing, measuring, analysing) and this should have stoked me. But it put me into deeper confusions! So I asked on twitter:

"So the ad agency did the listening, corresponding, engaging act on behalf of @oldspice. Did P&G or its LOB engage w/ customers?"

To which good friend & star analyst exemplar Esteban Kolsky responded:

"why does it matter who did it? somebody did. customers got what they wanted / needed. outsourcing is not bad just because"

And then added:

"however, that may just be the difference between SCRM and PR/Marketing efforts"

And thats exactly I had wanted to know from the cacophonous cognoscenti (again thanks to Esteban for this term, I think its brilliant!) that interacts on twitter, just to check if I was the lone person with those thoughts.

For me Social CRM is a step ahead (above?) Social Media Marketing (read this post for more) and SCRM entails the involvement the whole organization, not just Marketing/PR. The feedback loop did not encroach much within the organization (check out Esteban's experience continuum).

So when its merely the Marketing/PR that listens & engages on the social media, for me, its just the mouth piece talking. Its not a visceral response. How many other departments within the Old Spice brand/LOB (whatever they call it) of P&G get involved in this? The campaign itself was scripted & executed by an ad agency Wieden & Kennedy.

Another friend, ex analyst, currently head of social channel at huge PR agency, Natalie Petouhoff said that the campaign made big ROI & why would I not consider it Social CRM? To which I responded "high ROI for the company & flash in the pan entertainment for the customers."

Meaning, that there is nothing with a staying power in it for either the organization or the customers. Its something that kick started the brand again for Old Spice and brought it back into the current psyche of the social customer. And thats a great thing to do!

Did this campaign in any way lend to autopoiesis between the externally & internally facing teams of Old Spice &/or P&G?

So, end of long rant & bottom line: IMHO, this is an example of a brilliant social media marketing campaign, just not social CRM.

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• Never Mind, Old Spice Is Actually Selling Like Beefcakes [Corrections] (jezebel.com)
• What the Old Spice Guy teaches us about measuring viral marketing [del.icio.us] (buzz.ducttapemarketing.com)
• New Oldspice Campaign: Social Media or Social CRM? (jmorganmarketing.com)
• The Ultimate Social CRM Resource Guide - 1st Edition (customerthink.com)

Social Media Archiving

Pain in the neck? Source: Flickr

“Every firm that intends to communicate, or permit its associated persons to communicate through social media sites must first ensure that it can retain records of those communications.”

– FINRA Regulatory Notice (January 2010)

I cannot comment on a regulatory policy of USA, IANAL and I am an alien to boot. But this sure adds a layer in the social media communications that makes the businesses slightly slower to adopt/use. What the above means is that we have been ignoring the specific needs of the various regulated industries in Social CRM, Social Media Marketing, etc.

We now need to not only monitor the social media or have CoTweet/Hootsuite kind of tools, but also be able to provide archiving solutions for the communications happening via social media. Audit Trails from a programmatic perspective & archiving from a infrastructure perspective. Kind of makes sense why Dell claims that 90% of data saved by enterprises are not read again! ;)

However, we do not need to archive each & every tweet or friending happening on the social web, just those that emanate from the company & its people as its employees (am still not clear if an employee can use their personal account for personal reasons without having to archive).

Some vendors have cropped up to take advantage of this situation and the ensuing FUD:

• http://www.advisormail.com/social-media-archiving.asp
• http://compass.socialware.com/
• http://www.marketwire.com/press-release/LiveOffice-Socialware-Partner-Offer-Enhanced-Social-Media-Archiving-Compliance-1289404.htm

Social Media Archiving is not an optional need in BFS, yet the current options (AFAIK) are cloud based (SaaS) offerings and BFS might not be ready for it yet. I am not aware of the complete industry, but the few biggies that I do know of, would not like to put such communications data into the cloud.

You can listen in to this podcast on guidance on the use of blogs and social networking sites for business communications.

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From Team work to Autopoiesis in the Social Firm

Drawing Hands by M.C. Escher. Source: Wikipedia

Humans have always been social & until they were in villages, everyone knew everyone in their communities. With the growth of cities, and the rat race, a lot of that social aspect of humans is left underutilized. You know what happens to your muscles when you don't any longer use them as you used to? Yeah. But thanks to the Internet & especially whats now called the Web2.0 tech, which gave rise to social media & social networking sites, and the ever increasing computing capabilities in the mobile phones, people can find some help in re-exercising their social 'muscles'.

But this post is not about that. I wanted to talk about the Social Firm or the Social Business or the Social Enterprise (some call it the socialprise) and what potentials I see in them (mostly at a very high level, so high that its more like wishful thinking / philosophical).

Ever since I came across this wikipedia article on Autopoiesis (don't remember how) I have been fascinated by the concept & have wished it w.r.t. the internal & external use of social technologies by a business/enterprise/firm.

Many organizations have now warmed up to the idea of leveraging the social media to reach out to ever growing number of people on the Internet and is mostly driven by either the marketing or customer service departments. Whats also interesting in this increasing adoption is that the tools required are mostly available in the cloud (or as SaaS if you prefer that term) and that means that the CMO (or whoever funds it) gets the subscription directly from the vendors and do not have to go to IT (CIO/CTO, whoever manages the enterprise IT) for help. This leaves the IT in the blind and they are not at all aware of the use of these tools by the business teams. Many a times, these tools are used more as an experiment - to dip the toes in the social media water, so to say. These pet projects are easy to sponsor since the subscription costs are usually within the budgets of many people in the business teams. Thus you might even see multiple teams using social media in the organization for different purposes! (This leads to a whole range of issues, lets not get into them now).

Many enterprises, the large ones especially (and per my own experience, mainly from the regulated industries) are increasingly interested in the role of social technologies inside the organization's firewall. Well, for one, they are realizing its great potential in improved collaboration across the organization (and these are usually large in head count as well as geographically dispersed ones) and for another, they are channelizing the employees need to use social tech by providing a platform within the safe confines of the organization's firewall. More use inside is correlated to less use outside (in public social media) and thus lesser risk. (Risk is lessened/mitigated in many number of ways, but lets not get into the details right away). Bottom line, these collaborative social technologies are finding increasing interest from an organizational initiative perspective. Since these are organizational initiatives and its IT, the initiative is driven by the IT department with heavy integration with all the business units.

And from my own experience in the last quarter of the first decade of this new millennium (the past 2-3 years) I can say that most clients who come to us seeking help with this internal use of social technologies they are aware that something is being done from a Social Media Marketing &/or Social CRM perspective but they are not interested in that and they don't see it of being any relevance to the collaborative social technologies (also limitingly called as Enterprise 2.0).

I started my time with social technologies by implementing them for internal use, back in 2005-2006 and then slowly but surely covered ground with social media and eventually social CRM too. So I am very comfortable with which ever aspect you are looking at, technically speaking.

And I am worried about this cognizant (excuse my use of the word) avoidance of each other by the teams working on the external & internal use of social technologies in an organization.

Make no mistake, they both will have to integrate pretty soon in the game (say next 5-10 years, but thats just wishful thinking on my part, not any stab at predicting the future) but most probably they will end being like this:

Some might go to this stage:

But you know, the goal is Autopoiesis, the canocial example of which is the biological cell. :) As wikipedia puts it:

The eukaryotic cell, for example, is made of various biochemical components such as nucleic acids and proteins, and is organized into bounded structures such as the cell nucleus, various organelles, a cell membrane and cytoskeleton. These structures, based on an external flow of molecules and energy, produce the components which, in turn, continue to maintain the organized bounded structure that gives rise to these components.

So how do we get from the current state of cognizant avoidance to an autopoietic system? Thoughts?