Contributed By Jones Day
Generally, the same laws, regulations and self-regulatory codes concerning pharmaceutical advertising will also apply to advertising on the internet for medical products. In addition, the Commentary to the JPMA Promotion Code provides specific rules concerning access restrictions on internet-accessible information related to prescription-only medicines.
As advertising prescription-only medicines to the general public is prohibited under the Standards, when a pharmaceutical company provides healthcare professionals with product-related information concerning prescription-only medicines through the internet, the company must restrict access to the relevant websites so that only healthcare professionals have access to such information.
The question, therefore, is what is considered a sufficient access restriction. In this regard, the Commentary provides the conditions set forth below; if all these conditions are satisfied, then an access restriction will be considered sufficient:
As long as a pharmaceutical company uses a sufficient access restriction, it is not required to use any particular method of establishing passwords.
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