Metadata, which is invisible to anyone viewing a website in a browser, is part of the underlying page code. Search engines use this metadata: they pull the page title tag and description and display them on their results page. Anyone can view the site’s metadata by right clicking on a page. If you choose “view page source” from the menu that appears, you will see the code for the page, including the meta title and description.
Here’s an example of the metadata that has been written into the code for the homepage of Baxter’s ThereForYou.com:
Here is how it looks when Google pulls the metadata to display the title and the description in their organic search results:
Why Should Pharma Care?
The U.S. Food and Drug Administration (FDA) sent a letter to Novartis dated July 29, 2010, regarding a Facebook Share widget on their brand website, Tasigna.com. This widget pulled the content from the metadata. The FDA letter noted that this content did not contain fair balance.
Are There Guidelines for Metadata?
In the absence of specific guidelines for pharmaceutical advertising on the internet, we apply the FDA’s guidance for product claim, help-seeking and reminder ads.
Since there is not enough room for safety information within the 140-160 character limit set by search engines and social sharing tools, these cannot be product claim ads. Meta descriptions must be written in the style of help-seeking ads (disease or condition content but no product name) or reminder ads (product name but no indication). For black box drugs, only help-seeking ads are acceptable. These are the same guidelines followed for pay-per-click ads.
The FDA letter also states: “the shared content was not submitted to FDA 30 days prior to the intended time of initial dissemination or initial publication as required by 21 CFR 314.550, and was not submitted to FDA under cover of Form FDA-2253 at the time of initial publication, as required.”
Since metadata is used by search engines to generate organic search results and by social media tools, such as the Facebook Share widget, the appropriate site metadata should be included in internal medical/legal/regulatory review and as part of FDA submissions.
As stated in a previous post on this topic, it’s not the medium it’s the message. Whenever pharma marketers are creating content we must keep fair balance in mind – and this is partly why I find this industry so fascinating.
This post was contributed by Eileen O’Brien, Director of Search & Innovation for Siren Interactive. You can connect with her on Twitter at @eileenobrien.
(Image courtesy of dickdotcom on Flickr)
- 21 February 2013 at 4:02pm
- FDA Letter Mentions Internal Site Search | SIRENSONG
[...] don’t really know. The problem has been fixed on the site. The FDA has previously addressed that metadata needs to be compliant via a 2010 ...