TGA Permission Guidance for a Compliant Communication Environment (2021)
Consumer perception of a product/service is greatly influenced by communication via digital media. As a result, pharmaceutical companies are constantly evolving in order to strike a fair balance when advertising their products. Regulators, on the other hand, keep a close eye on the quality and authenticity of the data that is published. The importance of communication was critical in the case of COVID-19 vaccines. Monitoring the source and authenticity of diverging information became overwhelming after the first EUA was granted (within 8 months of development). The government encouraged various private organizations to launch campaigns to avoid miscommunication and educate patients about the efficacy and importance of vaccination. TGA released permission letters in 2019 as a roadmap for advertisers to navigate amidst the noise, outlining the guidelines across uniform communication and vaccine promotion.
In Australia, TGA (Therapeutic Goods Association) proposed a series of permission documents as a revised set of guidance based on Therapeutic Goods (Restricted representation-Commonwealth campaigns) permission 2018. A recent update to the permission guidance includes detailed instructions for vaccine promotion as well as a list of restrictions. The 2021 guidance ability to consistently that it does not apply to ads and promotional activity created in accordance with the 2019 permission document.
TGA encourages private individuals or organizations to promote vaccination as a way to support vaccination efforts. However, detailed instructions have been put in place to keep communication consistent across platforms.
To legally promote COVID-19 vaccines, follow these steps:
Using government-created promotional material – According to the stated guidelines, any party may use promotional material produced by the Australian Government or an Australian state or territory government to promote COVID-19 vaccines. The material should not be altered or supplemented in any way for promotional purposes. It is permitted, however, where the material has provided space for the advertiser to add specific information.
Self-developed Material – Keeping the importance of proper communication at its core, the TGA has issued subsequent legal permission (the 2021 permission) that allows advertisers such as health professionals, participating vaccination sites, corporate entities, media outlets, and others to develop their material as long as it remains compliant with the stated guidelines.
Incentives – Under the stated guidelines, any party may offer valuable consideration (cash or other rewards) to people who have been vaccinated under the Government’s COVID-19 vaccination program.
Factual and balanced information that does not constitute advertising – Any party may publicly present factual and balanced information about the COVID-19 vaccines that are not promotional and thus not subject to the advertising rules.
For businesses that facilitate workplace vaccinations – Australian businesses that partner with approved vaccine providers can inform their employees about the said brand and, in certain circumstances, promote any brand name.
Health professionals’ information – In general, the Health Authority does not allow health providers to endorse medicine or other therapeutic goods. The restriction has been lifted under the 2021 permission document since the COVID-19 pandemic.
Through this initiative, the Health Authorities, in collaboration with private organizations, ensured that the information being circulated is filtered through optimal stages of scrutiny and is thus reliable. Promoting vaccination drives around the world with the goal of achieving complete protection against the COVID-19 pandemic and ushering in the ‘Next Normal.’ Our seasoned Regulatory experts can provide a quality review of your promotional material in accordance with the guidelines of your local Health Authority.
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