In a torrent of tweets, our HCSM chat group considered Roche’s latest foray into the social media arena with its newly minted Social Media Principles. While this is the first public announcement (to our group’s knowledge) by a pharmaceutical company of its intent to encourage responsible social media activity by its employees, there were several concerns raised as to whether this framework created more confusion than clarity.
There are two sets of guidelines, one for employees officially acting on behalf of Roche (called 7 Rules for Professional Online Activities) and one set for employees who in their personal capacities speak about Roche (called 7 Rules for Personal Online Activities). Let’s tackle the Professional Rules first.
The Professional Guidelines are clear in that they instruct employees to follow their Code of Conduct and Communications Policy and require identifying themselves as Roche representatives. It also admonishes employees to be sure to take care about reporting financial data or speaking about Roche products, referring them to check out the company’s public domain information and to get legal approval. No surprises here. They take a proactive stance in advising that relevant social media sites be monitored so that the employee can respond.
Oddly, then Roche suggests that the employee have rules in place (not Roche) to handle possible Adverse Event reports or illegal content, adding that the employee should preserve data “for possible legal hold” should they bear such an obligation. These rules of AE reporting are not transparent, but given that this set of guidelines pertains to Roche employees on the clock, every department that is charged with SM duties is now on notice for creating AE reporting rules in place. Let’s hope they consolidate their AE reporting rules for uniform application.
Now on to the hornet’s nest: The 7 Rules for Personal Online Activities. Here they are in full:
- Be conscious about mixing your personal and business lives.
- You are responsible for your actions.
- Follow the Roche Group Code of Conduct.
- Mind the global audience.
- Be careful if talking about Roche. Only share publicly available information.
- Be transparent about your affiliation with Roche and that opinions raised are your own.
- Be a “scout” for sentiment and critical issues.
The first rule is very confusing. It appears to give some latitude to express one’s self, but in the accompanying detail, it ends up denying that liberty entirely. Roche states, “There is no separation for others between your personal and your business profiles within social media.” Well then, wouldn’t it be clearer to say: Do not speak about Roche negatively in your private lives. That is the stance taken by Mayo Clinic in its guidelines to its employees, where it states: “If your blog, posting or other online activities are inconsistent with, or would negatively impact Mayo Clinic’s reputation or brand, you should not refer to Mayo Clinic, or identify your connection to Mayo Clinic.” So Roche needs to speak more clearly about what it wants.
Rule #2 reinforces rule #1 in making clear the employee is responsible for his/her actions. Alas, the additional detail Roche offers in explanation isn’t helpful, but rather intimidating: “Anything that brings damage to our business or reputation will ultimately be your responsibility.” Really? Anything? Tell legal they flunked the part about proving damages.
Roche goes on to clarify that they want people to exercise common sense, but they could have said that without the bullying tenor. Here’s how Vanderbilt University tells its employees to use good judgment, though it is a bit heavy on the melodrama, “What you say can and will be used against you… FOREVER. Everything you say or do online is likely to be stored forever, even if you delete it.” I would have preferred they feature a photo of Dragnet’s Officer Joe Friday next to their admonition, but it gets the point across.
Rule #3 is clear in asking employees to abide by their Code of Conduct (e.g. no insider trading on social media, be respectful of all people, etc.). Nothing to complain about here.
Rule #4 is asking a bit too much from anyone without a fully staffed legal team at the ready to review your tweets on the fly. When Roche says “mind the global audience,” it goes on to explain that, “While your message may be accurate in some parts of the world, it could be inaccurate or violate regulations in others.” How is someone from the mailroom going to know that? This rule makes the solution offered concerning the first rule moot. Roche is really saying it would rather its employees not speak about the company at all. The best way to stifle discussion is to toss a global burden of confusion on employees who might want to discuss a new drug development pursuit by Roche (all public info), but now must consider if any statement falls into legal limbo on some other continent. Patently absurd. A better tactic would be to encourage employees to couch their statements as bearing on their stance as natives from their country: “As an American, I think that…”
Rule #5 actually provides helpful direction albeit within a straight-jacket. It advises employees to share only public information and to only speak on topics on which they are knowledgeable. So far, so good. However, where there is any uncertainty about that information being public, the employee is instructed to consult the Communications Dept. for approval. That is a bit of a restraint.
I prefer Mayo Clinic’s tone and approach: “Ask the Dept of Public Affairs if you have any questions about what is appropriate to include in your blog or social networking profile. Remember that if you wouldn’t want your manager or others at Mayo to see your comments, it is unwise to post them to the Internet.”
Roche finally provides a concrete example of what to do when it describes Rule #6, requiring transparency in the employee’s affiliation with Roche: “Example: I work for Roche. All opinions expressed are my own and do not necessarily represent the position of my employer.” Clear as bell and reasonable too.
And now for the rule that raised hairs on everyone’s neck, Rule 7. Roche requests that employees act as “scouts” for “sentiment and critical issues.” It doesn’t demand this activity, but notes that employees can help the company out by looking for online material that can help or hinder it. In its explanation, Roche asks employees to consider sharing “positive or negative remarks about Roche… by forwarding them to your local communications department.”
This seems appropriate until the next two sentences in its guidelines that shift from asking to mandating behavior of an off-the-clock employee. Roche states:
” This is most important in the case of so-called “Adverse Events”: When you come across information where somebody mentions side-effects after having taken one of our drugs in a credible and identifiable way, you have to immediately forward such information [my emphasis] to the global Drug Safety Team for further action.”
So, in an off-the-clock capacity, the employee is not only burdened with understanding global regulatory structures/impacts, but is now charged with flagging AEs to the Roche Drug Safety Team? And what if they don’t? How is the employee responsible? I won’t address how this employee would credibly assess some AE online, as the detective skills needed might not meet Roche’s requirements.
While the basis for SM guidelines usually stems from a need by employees to have direction and assistance in what they can achieve online, I sense that the Roche Guidelines do more to stifle activity than inspire it. No where in their rules is there a point of view that encourages employees to talk about their successes at Roche in helping patients, or how by listening to patients Roche is adapting its programs or drug development aims. The guidelines have lost the social in social media. Perhaps if better informed from the clinical perspective, Roche could really use social media in a way that instructs its institution on how to improve patient relations and ultimately the treatments these patients need.