Social Media Dos and Don’ts for Pharma Employees
Why it matters
As an employee of a pharma organisation, whether large or small, you are seen as ambassadors for your company. Think about your LinkedIn profile; the “Experience” section normally contains your company and role title. And your LinkedIn profile, and everything you post, is visible worldwide.
In a highly regulated environment, such as pharma, personal posts can unintentionally breach regulatory requirements. Laws and codes vary by country; what’s acceptable in one region may pose a compliance risk in another.
What’s the highest risk area?
The most significant global difference, and hence the highest risk, are the rules for advertising prescription-only medicines (POMs) to the general public. The US and New Zealand are often quoted as the only two high-income countries in the world that permit direct-to-consumer advertising without legal restrictions on linking the product name with the indication (the disease it treats). In both countries, there are, however, rules, such as ensuring the advertising is truthful, balanced, and not misleading, so it’s far from a free-for-all.
In the UK, EU, and most of the world, direct marketing of POMs is strictly prohibited by law. Promotion can only be targeted at healthcare professionals (HCPs) and even then, advertising material must contain specific, non-negotiable information, ensuring the message is balanced and supported by science.
Social media dos and don’ts
The following table outlines some social media dos and don’ts for employees working in the pharma industry:
|
Category |
Do |
Don’t |
|
Identification |
Do state clearly that you are speaking for yourself, not your employer e.g. “views are my own” |
Don’t use your professional title or company name in a way that suggests you are an official spokesperson unless specifically authorised |
|
Confidentiality |
Do share publicly available information about the industry, general health awareness, or your professional experience e.g. attending a non-confidential conference |
Don’t disclose any non-public information, including clinical trial results, internal policies, financial data, or patient-specific information |
|
Professionalism |
Do maintain a professional and respectful tone, even in personal discussions. Your personal brand reflects on your professional life. |
Don’t engage in arguments, make disparaging remarks about competitors, or post content that is profane, political, or overly controversial. |
|
Accuracy |
Do fact-check any health or scientific information you share. Stick to well-established, peer-reviewed facts. |
Don’t post misinformation or unsupported claims about any medication, disease state, or public health issue. |
The reposting question: Can I share company content?
Reposting company content, whether through sharing, commenting, or liking, is a grey area that requires caution! You should check your company policy first and follow their guidelines.
It’s generally OK to share posts about the company’s culture, corporate social responsibility (CSR), recruitment/jobs, or general disease awareness. These posts are non-promotional and align with supporting your employer brand.
However, you should never repost product-specific or promotional content. Promotion is any communication intended to increase the prescribing, supply, sale, or use of a medicinal product. You should never add a comment that references a product’s benefit or efficacy as this immediately makes you a promoter and personally liable for meeting regulatory requirements.
It’s also worth noting that pre-approval promotion, any activity intended to advertise or represent that an investigational medicine is safe or effective before it has received official approval from the regulatory body (e.g. MHRA, EMA, or FDA), is generally prohibited worldwide.
And you should be careful when you repost, comment, or like third-party posts. Examples include third-party posts such as a news article on your recent clinical trial outputs, materials produced by patient advocacy group, or financial/business news that mention your company and its products. This is another of the high-risk actions a pharma employee can take on social media. You will be seen as a representative and you are “adopting” that content on behalf of your organisation. The original post owner may not have the same restrictions on what they can and cannot say. On sharing, you and your organisation become responsible for the regulatory compliance of the content and the stricter pharma rules apply.
Closing thoughts
The digital world blurs the line between personal and professional, but for those of us in pharma, the regulatory line remains rigid. To simplify this complexity, consider these three core principles:
- Restrict: Do not talk about specific products, benefits, or risks on your personal pages. Avoid mentioning the product name and its indication in the your post. These two pieces of information published together this would be promotion in the UK.
- Report: If you see any mention of a potential side effect (an Adverse Event) on your feed (or anyone else’s feed), report it immediately to your Pharmacovigilance team. And, if you see any inaccurate or defamatory posts about your organisation, speak to your Communications team.
- Regionalise: Be aware of the location of your audience. Sites such as LinkedIn have a global reach. A post that is acceptable in one country could be viewed as illegal promotion in another. Don’t assume that, because it’s OK here, it’s OK elsewhere.
I’ve built these principles, Restrict, Report, Regionalise, from global regulatory guidance including the PMCPA, FDA, and EFPIA codes. I hope you find them useful!
Social media can be a powerful communication and advocacy tool, but it can also be a compliance minefield. Always consult with your company’s official social media policy first.
And, when in doubt, don’t post!
Our services
GRC Catalyst helps organisations stay safe and confident by setting clear, practical expectations for how employees show up online. We create accessible guidance and training that help employees understand what’s appropriate, what’s risky, and how to protect both themselves and the company. The result is a culture where employees can engage responsibly without exposing their organisation to regulatory or reputational harm.
Disclosure
The concepts and ideas in this article are mine or have been referenced; I developed the body of the text and conducted the final editorial check. I used AI as a tool for research, to improve the flow and grammar of the article, and to check for factual inaccuracies.
