Manufacturers and others working through the COVID-19 crisis and planning to regain their competitiveness will rely on data analytics more than ever. But they’ll need a smarter, more strategic approach to prevent the most common cause of failure. Fortunately, the problem is more human than technical in nature, and it’s fixable.
The Fourth Industrial Revolution or Industry 4.0 brings among other things IoT data visibility, fueling more and better data modeling, machine learning, deep learning and Big Data. For purposes of this discussion, I’m committing a transgression here, lumping these together as “analytics” despite the technical distinctions. In reality, things just keep converging so that instead of plain-old IoT, more attention is going to the newly-coined AIoT, or artificial intelligence of things.
When deployed in tandem, artificial intelligence (AI) and the internet of things (IoT) can bring powerful new capabilities and competitive advantages—a net effect that’s greater than the sum of its constituent parts. How much more powerful AIoT is than vanilla IoT at tackling organizational improvements? Take a look at the percentages inside the little orange circles:
Those surveyed said that among the benefits sought for their IoT efforts, increased revenue topped the list, regardless of geography, industry or company size. AI turbocharges that effort. (More details in the full article.)
AI, analytics: old news
Since my early-1990s coverage of early analytics and AI in such applications as statistical process control and machine vision, solutions have evolved with compute power and cloud services. The practice can now reach data anywhere, including networks bridging sites within single sites, across multiple sites or throughout enterprises and supply chains.
In seeking improvements, top officers of the company need to instill a pervasive culture of improvement. True, improvements can be made in the silos of R&D, engineering, production, sales, finance or other functions, but still should be guided by market signals and customer demand, not just the blind pursuit of efficiency or cost-cutting. Without that holistic approach, line managers down can fall victim to the parable of the vision-impaired persons and the elephant. In short, things aren’t always as they seem.
If such talk seems a generality, it’s also very real. Plant managers, for instance, can achieve operational excellence, but so can their counterparts in competing organizations — the technology is a known commodity available to all. This diagram from ARC Advisory Group analytics specialist and VP Mike Guilfoyle helps illustrate the scenario — which gets more play in a Smart Industry story (hitting print and online channels at month’s end):
Where are the gaps in your apps?
The market’s flooded with analytic sellers and solutions. Here are for deceptively simple considerations that might help uncover how to find growth opportunities; where to find the greatest needs; how to approach solutions and who will support a cycle and culture of improvement:
Imagining I were in your shoes, I came up with a thought exercise with four very basic questions that might be a good first step closing the opportunity gap in your application of analytics:
1. In every sector and at every level, organizations generate massive amounts of presumably (or potentially) visible IoT data — sowhere are most data generated throughout your entire digital universe that you can, or should be measuring?
2. For every area that can be measured, analytics solutions (or platforms) can be bought, adapted or created to yield greater insight — so where are there gaps in your management and automation systems across your value chain(s) that if filled, will yield the greatest visibility for tracking and potential improvement/innovation?
3. Every business and operational system in the IT/automation marketplace must include some provision for the use of analytics — so how capable are your systems to perform analytics via native functions, third-party partnerships or via a suitable level of standard integration capability?)
4. Every application of analytics requires a sustainable ecosystem of training and support for better decision-making and ongoing innovation — so do you have a sustainable culture of improvement, with suitable lifecycle support structures in place via in-house and/or reliable external resources?
How are you approaching analytics?
Can you help me support the cause of progress? Share your thoughts and anything allowable…I’ll work with you and your organization to see how we can get the word out.
Discussing digital transformation with a brilliant mind in the field of digital transformation recently, I asked: “What emerging technology do you believe will be most transformational in the industrial sector?” His answer: Video.
His focus on video stems from the growth in IT bandwidth and the ability to support video with AI-powered analytics to more effectively discern patterns when data is deployed across IoT networks. AI and the Internet of things (IoT), or the combined AIoT, is deemed critically important to digital transformation initiatives, industry leaders say. Where AI analytics are deployed depends upon the challenge to be addressed.
As an AI-focused executive with a leading firm connected to these converging technologies, the gentleman I was speaking with was fascinated by a demo he saw at a recent trade show. It depicted a factory with thousands of cameras installed, one above each employee workstation. The goal, he said, was “to effectively use a camera to ‘sensorize’ a person [and] figure out if folks are deviating from the agreed processes.”
Businesses of all types — from small machinery suppliers to large manufacturers (like Foxconn) have for decades used cameras and machine vision software for applications such as quality assurance, to recognize patterns and detect and reject off-spec products. It’s really no surprise, but a logical extension of what Henry Ford did in automaking; what W. Edwards Deming did in post-WWII Japan; and what Ray “McDonald’s” Kroc did in fast food.
What may be surprising how real-time video analytics can transcend the mechanistic aspects of how people act to discern how they feel. In video and audio applications, machine learning has already been applied to customer service call centers and doctor-patient telemedicine apps to identify such things as anger and frustration. The data inputs for A/V analytics include voice analysis, facial expressions, movements, and posture. Industrial applications are no doubt coming, if not already here.
The edge of progress
As market demand fuels technical capability, video analytics solutions will continue raining down from longer-term remote cloud applications to people-watching applications based in real-time edge computing networks on or near the production floor. Intel’s Chet Hullum and his team improved semiconductor manufacturing at the edge because addressing cloud latency issues “would be far too expensive,” as I reported for SmartIndustry. (Intel Tweet and LinkedIn post (below) give more background:
With advances in connectivity and pervasive analytics, the eye in the sky really isn’t the limit anymore.
AI disruption seems to have thinned the workforce for good. Now what?
Where would we be if wheels were still square? If the Luddites kept machines out of textile mills? If the cotton gin didn’t decimate the pre-war Confederate workforce? Today, one has to wonder how many truck drivers will be able to find new work once driverless rigs rule the roads.
With regard to the the long-term impact of automation general, I’ve been ambivalent for decades; gung-ho for progress but concerned about a gutting of the workforce. In the mid ’90s, I spent a day with an engineering leader who gave me a tour of his workplace, a refinery that stretched for miles. He showed:
Pride in his control network, which bore early AI enhancements
Sorrow for the loss of most employees at the plant and industry-wide due to automation, and
Resentment of the coming “corpocracy” in which individuals lose their humanity.
I shared my ambivalence in a column I wrote for Control magazine at about that time after a conversation with a senior engineer at another Big Petro firm folding 17 subsidiaries into one. I started the column ranting about corporate “destructuring” and “dumb sizing,” and ended with: “It’s hard to argue with the bottom line.”
Likewise, I’m mixed about the impact of industrial robots, worth about $40 billion and pegged to top $71.72 billion by 2023. Companies choose to replace people when the technology is available because they’re a better-faster-cheaper way to go. I was saddened at the demise of ReThink Robotics, maker of Baxter and Sawyer, the industry’s friendliest collaborative robots, or cobots. (collaborative robots). And I was glad the company was quickly bought-up by Germany’s Hahn Group. Rethink, a small player compared to leaders such as FANUC, ABB and Yaskawa, failed not for lack of demand, but in large part due to technical issues, if this RobotReport postmortem is accurate.
In better times (2016), I spoke with ReThink’s Jim Lawton, chief product and marketing officer, who extolled his bots’ rapid ROI (as low as 1.5 years) and quick installation time (under a month) as well as speed and flexibility. For instance, he told me of a Tier One automotive supplier that replaced 20 hours of manual labor day: “$25,000 for the robot, and a little bit for the grippers, and we’ve saved them $180,000 a year.”
Robots don’t call in sick, need healthcare, come in late or take days off. They do work when workers don’t want to, or can’t be found. And companies are bound by the need for competitive advantage and higher profits to use them if they’ll keep the shareholders happy. But again, the industrial workforce, once an engine of the middle class, is shrinking.
The U.S. middle class: Doomed?
Technology both eliminates and creates jobs, but the former appears to be winning in the U.S. marketplace.
As one Clorox exec said during a panel discussion a couple of years back, “every” manufacturing company is busy automating and “leaning-out” its lines. A Kraft Foods alum added that it’s commonplace for companies to replace upward of “100 people on a Lunchables line [with robots] picking up stacks of pre-sliced meat and pre-sliced cheese.”
What to do? Thought leaders across business, politics and industry have since given credence to the movement for Universal Basic Income, a flat payment to every citizen, to address poverty and job losses largely incurred by technological advancement.
UBI has been advocated by the Brookings Institution, given credence by Fortune (no leftist-socialist totem), and promoted by Elon Musk, Richard Branson, and many in Silicon Valley, including Mark Zuckerberg. More recently, UBI generated headlines in 2018 in Chicago with a petition by city Alderman Ameya Pawar (@Ameya_Pawar_IL) to take the city Universal:
There ain’t no “i” in TEAM
Henry Ford did it, McDonald’s did it, and now the collective, global technology hive mind is doing it: Standardizing business processes to advance the competitive mandate for greater productivity and profitability. I love to hear stories of happy employees, but below photo mesmerized me to the point of distraction. So I’m using it to illustrate a point:
The point — no offense intended to the editor who penned the caption! — is that companies can’t afford for their employees to be “themselves” in that we can’t have guitar players, poets or sewing circle meetings on the factory floor. The employees pictured are essentially identical, down to their garb (as required by sanitary food handling rules). Their jobs are the same, too: to comply with uniform standards procedures.
But if there’s no ‘i’ in TEAM,” there’s still something of a “we.” The ranks will thin, but there will remain a critical need for creative human minds to solve problems, even at the line level.
Almost a decade ago I helped a manufacturing exec, Greg Flickinger, document a cultural transformation at food firm Snyder’s-Lance in Charlotte, N.C. His team reduced scrap 40 percent; reduced customer complaints 41 percent; and, among other good stuff, slashed production changeover time to save more than $300,000 annually.
The human-machine interface, writ large over time, points to great gains and equally daunting challenges. Let’s face it: As a species, we’ve got a troubling historic myopia, and an immediate need to reconcile longstanding issues relating to our technology and economy, or techonomy.
I recently reunited with FoodOnline.com to write a story on Big Data analytics in the retail food supply chain. The first bylines I had for that site were in 1999, when I was Editorial Director for that related sites — before the big bursting of the Internet Bubble.
When the Internet was new, there were no iPods, let alone iOS, Android or Bluetooth-powered beacons; Big Data was just a gleam in its young Business Intelligence mother’s eye. And retailers had no idea what to really do with their Business Intelligence systems. Those who finally do, today, see BI as old news as analytics — predictive and now prescriptive — come into their own, powered by Big Data and cloud computing.
Today, as an exec from SAS told me, a shopper who stands in front of a Nescafé display for more than 10 seconds might just get a virtual tap on the shoulder, or rather a bzzzz in the pocket, with a coupon to get that package of coffee off the shelf and in to the cart.
My favorite interview in this story just might have been Nick Hodson, former head of strategy at Safeway Stores and current leader of the North American consumer and retail business practice of Strategy& PwC, who reminded me that the technology isn’t at all the point of progress so much as creative minds who come-up with new things to do with it. Yes, major retail marketers from Walmart and Nestlé may well fave a backlash over privacy concerns if opt-in/out issues aren’t handled correctly, but these times sure are interesting. Read all about it in my story, ” Predictive Analytics Helping CPGs Reach Individual Consumers.”
Take one of the most dynamic transformations in any form of media occurring right now—the rise of social media like Facebook, Twitter and the rest—and factor in that marketing and advertising agencies themselves are heavily vested in exploiting the possibilities of the new, digital cornucopia. Then layer in the reality that almost month by month, the “norms” of social media (if such a concept can be recognized) are changing. Now throw this tidal wave against the careful, deliberate traditions of FDA regulation of healthcare communications.
The result: a lot (a LOT!) of sound and fury, but relatively little movement by pharma companies into the social sphere. FDA, without coming right out and saying so, has postponed providing rules on pharmacos’ use of social media (and has indicated that it is likely to provide “guidance” rather than actual rules). In turn, pharma marketing and communications leaders are dabbling around the fringes of the social media movement, while mostly building more websites and buying banners through online marketing networks. Behind the scenes, though, pharmacos appear to be quite active in monitoring online discussions and commentary—itself an evolving type of marketing service for themselves.
Living without guidelines
In 2009, FDA’s Div. of Drug Marketing, Advertising and Communications (DDMAC) held public hearings over online marketing and communications (Pharmaceutical Commerce, Nov/Dec 2009, p. 6), which brought out many thought leaders among online companies, public interest groups and manufacturers. DDMAC hoped to use the commentary to develop communication standards in 2010, but at the end of that year, delayed them to this year. Social media, as such, were somewhat on the periphery then; a lot of the discussion revolved around getting fair balance into banners (which, it turned out, has become fairly easy to do). But one issue that was prominent then—and remains so today—is whether manufacturers are obliged to handle product complaints that might be expressed anywhere on the Web as reportable adverse events (AEs).
In January, the agency dropped online drug promotion, including social media, from its Guidance Agenda publishing plans for 2011, leading industry watchers like John Mack, the blogging “Pharmaguy,” to ask, “Is this supposed to be the promised guidance we’ve all been waiting for?”
For its part, DDMAC is keeping its cards close to the chest. “It is difficult to provide a timeframe for the issuance of our guidances or related ‘milestones’ due to the extensive work and review process, or GGPs [good guidance practices],” DDMAC announced in a letter. “Our goal is to provide well vetted, meaningful, and useful guidances articulating our current thinking on various topics related to Internet/social media promotion.”
Asked whether he thinks the FDA has given-up on the effort to produce guidelines, James Musick, director of social media and web communications for Genentech, says “the more I dig into social media, the more I find that it’s extraordinarily complex. So I don’t think it’s so much a back-burner issue for the FDA as it is that they’re realizing what we have realized, which is that it’s not easy to do.”
For now, he says the company is taking a “letter-of-the-law approach,” even he’s left wondering which letters to which laws to follow. Like most pharmacos, Genentech has a public statement of principles, based on parent Roche (see box, p. 34). Most of the rules are not specific to social media, except to note that comments posted in a seemingly local or private site have a way of ricocheting around the world.
Marketing agency leaders say that it’s just as well that DDMAC hasn’t come out with rulemaking, simply because the medium is changing so quickly. In just the past few months, for example:
• Google announced that it was shutting down Google Health, an early effort to get electronic health records (EHRs) organized for consumers; at the same time, it has started up Google+, its answer to Facebook.
• Microsoft, which has a service, Health Vault, that competed with Google Health, has gone ahead and acquired FDA registration for the service as a medical device.
• In April, Facebook announced that it would no longer allow users to disable comments, a rule that already affects new Pages and coming to existing pages by August 15, according to numerous agency sources. Matthew Snodgrass, director of social media for San Francisco-based agency WCG, was one of the first to dissect pre-announcement details and note the exceptions that will apply to pharmaceutical companies:
• Pages that promote, talk about, or support prescription drugs or devices
• Pages that focus on a disease state where there is only one prescribed treatment (even if the Page doesn’t mention the treatment)
• Disease-state/therapeutic area Pages that have the PI/ISI on the Page This means that corporate Pages, general disease awareness Pages, and unbranded campaign Pages will have their comments re-enabled for their Walls, photos, and videos.
Jonathan Richman, group director of insights and planning at WPP’s interactive agency arm, Possible Worldwide(www.possibleworldwide.com) notes that “whitelisting” will apply and gives a detailed explanation at his blog, www.doseofdigital.com.
So what happens after August 15? Some pharma companies may ditch Facebook as a channel, but that’s not necessary, says Joe Doyle, interactive director at Austin, TX-based agency HCB Health (www.hcbhealth.com), because the social manager will likely be using a software tool like Radian6 (www.radian6.com), or any of the dozens of competing offerings such as Nielsen’s BuzzMetrics, ThoughtBuzz, Lithium, which scan the Internet with special emphasis on social elements for all mentions of a brand and allow companies moderate, monitor and correct statements that put the company at regulatory risk because with or without DDMAC guidelines or a formal rule, the rules of engagement are “very black and white. We all know what our boundaries are, what we can and can’t say regarding standards such as fair balance and off-label content.”
One of the more recent developments from Radian6 is a partnership with Asentech (http://beta.asentechllc.com), whose new, combined system trolls a claimed 330 million sites every five minutes to offer ratings like other systems, with a difference: The partners have added a staff of physicians and pharmacists to mediate the data for pharma brand manger users before pulling the trigger on weekly or monthly reports.
Even companies who shy away from social media due to regulatory fears should still be aware of what people are saying about them. Monitoring, or as some call it, “listening,” assisting companies in their marketing and overall in pharmacovigilance efforts that can help prevent or mitigate situations that can lead to adverse events, improper off-label use and warning letters—whether or not the FDA ever offers guidance or formal rules.
Existing rules will do
“I think the longer it takes the less likely we are going to see rules from FDA,” says David Ormesher, CEO of Chicago-based agency closerlook (www.closerlook.com). He says the agency “has more to lose” by publishing regulations because “it is balancing a lot of interests, and have gotten a lot of heat over the years for even opening-up direct-to-consumer advertising TV. They’re already getting a lot of heat from people for the amount of promotion that pharma does on the web as it is. So I think they like this tension they have from Pharma right now.”
Eileen O’Brien, director of search and innovation at siren Interactive (www.sireninteractive.com), a Chicago-based agency specializing in rare disorders, says she was “very optimistic two years ago” that DDMAC would issue guidelines, but is not sure they’re needed today: “We’re still waiting for guidance for using the Internet, but that hasn’t stopped anybody from doing a website.” Pharmacos seem to be coping by following existing guidance for TV and print media promotions.
“It’s easy to get distracted by a shiny, new object,” says O’Brien, who stresses that social media aren’t a strategy “but a tactic that has to tie back to larger marketing and brand objectives. It’s not right for every brand.” Companies should first attend to higher-priority interactive tactics such as a creating a compelling, frequently-updated website and search-optimized e-mail campaign that reaches key audiences.
In the face of the evolving if amorphous nature of social networking, statistics aren’t everything; even Manhattan Research, a New York market-research company specializing in tracking new media, is sidestepping some of the frothier parts of the social media buzz. Monique Levy, VP of research, says that the firm routinely finds itself doing “a lot of explanation to contextualize the data” revolving around social media activity and that business models are still evolving. For the time being, she says, the more significant activity is focused on mobile technology at a time when consumer and physician mobile apps are surging and the research firm estimates that 91% of US physicians are using some type of smartphone, and that 75% of all physicians own some form of Apple device, such as an iPhone or iPad. The firm is now conducting a study on physicians’ opinions of sales-rep presentations using digital media.
Web or mobile Web, there’s plenty of opportunity for pharma social networking despite regulatory restrictions, as hundreds —thousands—of online social connections attest. But where to start?
Ben Curtis, a strategist at Cary, NC- based healthcare agency MicroMass Communications, (www.micromass.com), starts with a “pure definition” of social networking as “getting a community of people engaged with one another and having, for our purposes, discussions about the brand. It’s really no different than word-of-mouth marketing just that it’s happening online.” This starting point leads him to help clients facilitate one-on-one communication between two patients, “where all the pharma is doing is connect them so they can speak outside of the pharma network. One way to do this is to partner with associations to build communities, facilitating patient-to-patient or patient-to-doctor communications, as well as a “good relationship between the association and the pharmaceutical company.”
Going forward, social networking may or may not become an easily measured media segment to track. It’s not that market shares and data are top secret, but that it’s difficult to get accurate audience data beyond users and “likes” on publicly accessible sites, or–more importantly—tracking physicians on targeted, registration firewall-protected physician-only sites like Medscape Physician Connect (http://www.medscape.com/connect), Sermo (www.sermo.com) or Ozmosis (www.ozmosis.com), or any of hundreds more health-related venues. User counts don’t measure active users, nor do total user counts for which there’s likely to be plenty of overlap.
“A marketer is better off reaching physicians in a closed community because even if they’re on Facebook, they’re not consuming pharma information there,” says Tim Lewis, director of strategy for interactive and relationship management for Chicago-based healthcare agency AbelsonTaylor. Because every rule seems to have an exception, AblesonTaylor has found one group of healthcare providers using Facebook: 2600 night nurses in hospital nurseries who have special needs and can be overlooked in the nursing world. AblesonTaylor created this presence for Abbott’s Similac brand. Lewis’ associate, Bekah Locker, manager of social marketing, notes that this is “a community space where night nurses could come together, engage in conversation and connect with each other on topics they find relevant.” Abbott doesn’t push the brand, but has provided “an authentic place for that type of engagement.” The moderator shares relevant information for sleep disorder, working with patients and the challenges of working at night.
The content isn’t on the brand so much as the cause—which is exactly what prescription drug marketers say is the easiest way to build audience affinity. Lewis says “the FDA has never issued a warning letter for letting people talk about a brand on any social space. The warning letters have been associated with not providing fair/balance” when a site is controlled by a brand. And on this Facebook site, over the past tens of thousands of posts, only removed two posts have been removed. Says Lewis: “We want authentic conversation. If that authentic language includes criticism of something we posted, so be it.”
The same applies to prescription drugs: “One of the easiest ways for a brand to get involved in terms of the social space is to do cause marketing.” Pharma marketers typically gain access, and then only some, on closed physican sites, depending on their level of sponsorship, and so, Lewis says, “it’s harder to have an ongoing dialog [in a closed community that’s sponsored.” That also goes for custom sites and pages created using platforms by custom developers such as within3 (www.within3.com). But opinions diverge on such topics because the “social” market may never be a market segment that can be as easily measured as more monolithic channels.
Even mobile platforms are easier to measure, despite “huge regulatory issues,” says Manhattan Research’s Levy: “Every screen is different; fair/balance is different; platforms are different—it’s a whole other beast. People are already tackling that within pharma. It’s a bigger priority than social this year.”
Even if social becomes a stepchild to mobile, social media won’t fade into the woodwork so much as become part of the architecture of the Web. “Things are changing so rapidly,” says Genentech’s Musick, “that in 5 to 10 years, it will be increasingly difficult to make the distinction from social as distinct from Internet media. There will be socially enabled features everywhere online, as well as mobile.”
Big (Pharma) Brother?
However, there is already a debate building over online listening, which makes it one of the agenda items of the newly formed Digital Health Coalition (DHC). Founded by Mark Bard (former president of Manhattan Research), DHC brings together many leading pharma companies with Google, Epocrates (an online medium for physicians) Health Central and Digitas Health. The group is seeking to build consensus within the manufacturer community, and interact with FDA and other regulators. Bard says that the debate on behavioral tracking and digital privacy “is a major issue” to all advertisers, not just in healthcare. “There are voices out there that are saying the very premise of behavioral tracking is a bad thing. That has impact on every industry and it can also have a significant impact on the pharmaceutical industry.”
However the privacy/behaviorial tracking/mobile communications discussions play out, one thing seems certain: a year from now there will be yet other new issues bubbling out of the social media mix. PC
BOX: ROCHE’S PRINCIPLES FOR ONLINE ACTIVITY
Codified in late 2010, Roche’s guidelines apply worldwide, and are an example of how pharma companies are grappling with the changes in communications media. The company also has a Social Media Advisory Board to address new issues. The following is excerpted from the company’s website, roche.com.
I. Personal online activities
1. Be conscious about mixing your personal and business lives. There is no separation for others between your personal and your business profiles within social media. You must be aware of that. Roche respects the free speech rights of all our employees, but you must remember that patients, customers and competitors as well as colleagues may have access to the online content you post …
2. You are responsible for your actions. … Anything that brings damage to our business or reputation will ultimately be your responsibility. This does not mean that you should refrain from any activity, but that you should use common sense …
3. Follow the Roche Group Code of Conduct. When “speaking”, be compliant with the Roche Group Code of Conduct, as well as all other Roche Positions, Policies & Guidelines (i.e. Protection of Privacy, Rules on Insider Trading, etc.) …
4. Mind the global audience. Even if you are posting on a “local” platform, the information may be accessed globally. This is particularly important in our regulated business …
5. Be careful if talking about Roche. Only share publicly available information. You are not allowed to talk about the revenue, future plans, or the share price of Roche as this may have serious legal repercussions for you and the company.
6. Be transparent about your affiliation with Roche …
7. Be a “scout” for sentiment and critical issues. … If you come across positive or negative remarks about Roche or its products online that you believe are important, consider sharing them by forwarding them to your local communications department. This is most important in the case of so-called “Adverse Events”…
II. Professional online activities
The following principles outline what to consider when representing Roche as an official online spokesperson:
1. Follow the Roche Group Code of Conduct and Communication Policy. In the core of all communication engagements is our commitment to transparency, balanced information and equal treatment of all parties …
2. Approval processes for publications and communication. … Given the interactivity and speed of the new medium, however, it is not realistic to have each response undergo full approval by communications, legal and regulatory. Therefore, you should establish with your usual approval partners a common agreement on a bandwidth of topics and instances that may not require the normal process. …
3. Mind copyrights and give credit to the owners.
4. Use special care if talking about Roche products or financial data. Communication about the revenue, future plans, or the share price of Roche as well as statements about our products (“promotional information”) is reserved to experts in the field who have been trained to do so …
5. Identify yourself as a representative of Roche.
6. Monitor your relevant social media channels. Make sure you know what is being discussed, so that you can respond when issues arise. Have rules in place to deal with potential Adverse Event reports or potentially inappropriate or illegal content … Also, be mindful of any obligations to preserve data that may be subject to a legal hold.
7. Know and follow record management practices. … Keep records of our interactions in the online social media space. Because online conversations are often fleeting and immediate, it is important for you to keep track of them when you’re officially representing Roche.