Google+ Pages for Prescription Medicines

November 17, 2011 Analyst: Dale Cooke

Regulatory Alert

EXECUTIVE SUMMARY
On November 7, 2011, Google+ launched Pages. This is the ability of companies to maintain a presence on Google+ analogous to brand pages on Facebook. Currently, Google+ is not making any special accommodations for medical product companies, but Google representatives say that new features are under development. Until then, Google+ poses a very similar regulatory risk to Facebook, and just as with Facebook, people exploring Google+ need to understand how it works to ensure their intended efforts are compliant. The use (and limitations) of circles and hangouts are unique to Google+ and companies seeking to use Google+ should appreciate the nuances these features bring and make sure their plan for using Google+ takes these features into account.

BACKGROUND
Google+ is a social networking site analogous to Facebook. The basic functionality of the two sites is very similar, though there are some minor differences, primarily with terminology. For example, rather than having a Wall as in Facebook, users have a Stream in Google+. One key distinction is that as of today, Google+ has not made any special accommodation for companies making prescription products that want to create a page. Facebook, for example, enables pages that are dedicated to product discussions to be whitelisted, which prevents their pages from receiving any comments on posted content. Google+ representatives have said1 that there are plans to enhance pages in ways that pharmaceutical manufacturers, among others, might find useful for communication in a tightly regulated industry. As of today, no such exemptions exist. Launching a brand page on Google+ commits a company to engaging openly in full dialogue with anyone who follows the page, with the option of moderating such dialogue only after it is posted publicly. Two features distinguished Google+ from Facebook at launch: the use of circles and the ability to create hangouts. Both features are particularly relevant to medical product companies.2 This alert looks at those features in greater detail and highlights some of the key issues for companies considering a Google+ presence.

RELEVANT FACTS
Circles Circles are the central organizing principle for connections on Google+. Every connection resides in a circle, and Google+ starts users with certain default circles for Friends, Family, and Acquaintances, but users are able to add or change whatever circles they want (co-workers, ex-coworkers, alumni, workout buddies, etc.). All interaction on Google+ is organized around your circles. Posts are always shared with a specified circle(s)

up to and including the entire group using Google+, and you see posts from others that have been shared with a circle you are in. Users always know who is in the circles they create, but they never know what circles someone else has put them in. So, for example, I might put a friend from college (Joe) in my Close Friends circle and also my College circle. Joe, however, might have only put me in his Alumni 3 circle. If so, Joe will see everything I share with either my Close Friends or College circle, but I will only see the information that Joe posts to his Alumni circle.

The use of circles makes it possible to share information with all and only those people you want to have that information. For example, I might want to discuss my plans to re-visit a popular restaurant while at my college reunion with my College circle but dont necessarily want to share that information with all of my Close Friends. Currently, commenting cannot be disabled, limited, or moderated (except ex post facto) by anyone using Google+, including makers of prescription medical products. Comments on a post can be seen by the group with whom the initial post was shared. So, returning to the example above, Joe and everyone in my College circle can see and comment on my post about my plan. Joe also can see any comments made by anyone else I shared my initial post with, but no one who is not permitted to see the initial post will see it or any of the comments, unless someone Reshares that post. Resharing a post is when a person reads a post and decides that she would like to share it with additional people.4 Perhaps Joe shares a post with his Alumni circle that I decide would be interesting to people in my Close Friends circle. I can reshare that post, unless Joe has prevented me from doing so. When an initial post is created and shared, it is possible to prevent others from resharing that post by Locking the post. Locked posts can still be viewed and commented on by the circle(s) with whom the post was originally shared, but none of those users are able to reshare that post. Circles make it possible for people to have different conversations with different groups. In the context of prescription medications, the most obvious application is to enable different conversations with doctors from the conversations with patients. A brand page wanting to do so could set up two circles (Patients and Doctors) and share different information with each circle. Of course, certain information might be interesting

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Regulatory Alert: Google+ Pages for Prescription Medicines

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to both audiences, and then the post could be shared with both, or even made Public and shared with everyone using Google+. Hangouts Hangouts are group video chats. Anyone on Google+ with a webcam and microphone can initiate a hangout by simply clicking a button. Several features distinguish a hangout from a standard video chat.5 First, a hangout can have more than two people participating. Up to 10 people (including the person who initiated the hangout) can participate in the video chat session simultaneously. Second, all of the participants are visible to each other. The current speaker is in the center of the frame, while the video feed of the other participants appear below them. As the person speaking changes, the Hangout automatically changes who is in the center.

Individual participants can mute their microphone or video to prevent themselves from being seen or heard by others. The person initiating the hangout invites others by posting a message to her circle(s) announcing that a hangout is taking place or by making the hangout public, which means anyone using Google+ can join. Of course, its also possible to schedule a regular hangout in advance, e.g., every Wednesday from 4 5 p.m. Importantly, although you can restrict who is initially invited to a hangout by only inviting specific circle(s) to participate, you cannot prevent other participants from expanding the invitation beyond that select group.6 So, for example, if I initiate a hangout and invite my circle of Close Friends and Joe (who is in my circle of Close Friends) joins that hangout, Joe can extend the invitation to the hangout to his Alumni circle, even if there are people in his Alumni circle who are not in my Close Friends circle. The one exception to this is that users can block specific individuals from ever participating in hangout with them. If you block specific individuals then those specific people will never be able to enter a hangout you are participating in, even if they are invited to the hangout by another participant. Once a company is participating on Google+ it is also possible to participate in hangouts initiated by others if that page is invited to the hangout (or the hangout is public).

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RECOMMENDATIONS 1. Companies that are already comfortable using Facebook with commenting enabled should be comfortable using Google+, as the functionality is very similar with only minor differences. 2. If companies choose to permit their posts to be reshared, then the general principles for developing shared content should be followed.7 3. As part of developing any content for posting on Google+, companies must determine three things: a. What content will be shared b. What circles it will be shared with c. Whether the post will be locked or resharing will be permitted. 4. Hangouts offer a potential service, but they are not mandatory and have limitations of their own. Specifically, companies must be prepared to address the issue of uninvited participants as there is no way to guarantee that only invited participants will attend. SUPPLEMENTAL MATERIAL Digitas Perspective on Google+
http://www.scribd.com/doc/72081838/Noah-Mallin-Google-Rolls-Out-Brand-Pages

Google+ Official Page for Businesses on Google+

https://plus.google.com/115200251016762857369/posts?hl=en

ENDNOTES
1

In private email communication with the author of this alert, Google representatives have said that Google is working to add features specifically for pharmaceutical companies, but no timeframe for implementing such changes has been provided. 2 This alert is focused on two features of Google+ that separate it from Facebook. It does not provide a complete overview of Google+ Pages. Readers interested in that should consult the Perspective provided by Digitas at http://www.scribd.com/doc/72081838/Noah-Mallin-Google-Rolls-Out-Brand-Pages 3 Note that for illustration purposes, Ive intentionally named the circles differently to emphasize that the creation of circles is completely up to each individual. Who is in what circle, and what those circles are called are up to each user. 4 See http://www.google.com/support/plus/bin/answer.py?answer=1297219 for Googles description of Sharing, Resharing, and Locking posts. 5 See http://www.google.com/support/plus/bin/answer.py?hl=en&answer=1215273&topic=1698291 for Googles description of Hangouts. 6 See http://www.google.com/support/plus/bin/answer.py?hl=en&answer=1216372&topic=1257349 for Googles discussion about others extending the invitation to hangout. 7 See for example, Digitas Healths Online Sharing: What Pharma CAN Do, released on August 17, 2010, and available at http://www.scribd.com/doc/36090621/Updated-Digitas-Health-Online-Sharing-POV

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Regulatory Alert: Google+ Pages for Prescription Medicines

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