This paper looks at two search components (from an optimisation perspective and a pharama compliance perspective) that are publicly visible in search engine results: the ‘Title Tag’ and the ‘Description Tag’. Search results are important because they are the first piece of information a person sees before clicking and entering a web property and should comply with FDA and PMCPA regulations.

1. Pharmaceutical Companies and Search Results Compliance
May, 2014

2. Pharma and Search Compliance – Marcos Richardson
Introduction
Pharmaceutical and healthcare companies own websites to impart information about their company,
products and services. With strict country regulations on how medicines can be promoted to public
consumers and Health Care Practitioners (HCPs), the contents of these websites are carefully targeted
at either consumer or doctor and must abide by country regulations (FDA, PMCPA etc.).
One specific and basic principle of an online presence is, however, being overlooked, ‘Search Engine
Results’.
This paper looks at two search components (from an optimisation perspective and a compliance
perspective) that are publicly visible in search engine results: the ‘Title Tag’ and the ‘Description Tag’.
What are Search Engine Results and Why are they Important?
A search engine result is the information a person sees after performing a search query and it looks
like this:
Search results are important because they are the first piece of information a person sees before
clicking and entering a web property. This is a billboard of advertisements enticing people into
taking the next step and choosing which site to visit.
From a regulatory compliance perspective, this is the information that describes what a searcher is
looking for based on their query and what the searcher is likely to see if they continue on into the
website. This public information needs to be complete, accurate, and considerate of the mixed
audience that will see the promotion.

3. *source: http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm338405.htm
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/EnforcementActivitiesbyFDA/WarningLettersandNoticeofViolationLettersto
PharmaceuticalCompanies/UCM221325.pdf
Components of Search Results
Title and Description tags control what becomes visible in the search results. Both the Title Tag and
Description Tag are individual components within the HTML of a web page. Companies can govern
what is displayed in the search results by controlling what is placed within these two elements.
Title Tags are widely known to have search engine ranking value, whilst Description tags have less
influence on ranking results but are the main mechanism for endorsing the web page prior to
entering the website.
Effect on Regulatory Compliance
‘Metadata should reflect the content of the site and not be promotional’ (*PMCPA and ABPI), The FDA
expects submission of metadata and Failure to submit is not acceptable.
The FDA’s implied knowledge of Metadata is based on two cases (1. *FDA warning letter sent to
Medical Doctors Research (MDR) 2.) * FDA's letter to Novartis citing violative content in a Facebook
‘Share Widget’ that Novartis created as part of the Tasigna website metadata.
Google is an advertising platform and directory. You can either choose to pay for your advertisements
and receive guaranteed clicks/visitors or, by allowing your website/content to be available on Google,
you list all of your web pages free of charge for the public to see. Either way you are promoting your
content.
Doctors, medical writers, legal specialists, brand specialists and specialist agencies are employed to
make certain that the right information on a website or social channel is made available to the right
audience.
The same due care and diligence needs to be given to the metadata that is visible to the public prior
to entering the website.
PMCPA
Title Tag
Description Tag

4. Pharma and Search Compliance – Marcos Richardson
Pharma Search Results Examples
Pharma companies are ignoring Metadata and the result is quite often an incomplete message and, in
many cases, a non-balanced promotion.
Here are some good and bad current (May 2014) examples where descriptions are not complete and
the message unbalanced (N.B. These are all prescription drugs that carry warnings of potential fatality
if taken). Note in many cases the message is truncated (cut off) this is not a deliberate fault of the
content suppliers but an inadvertent result of not applying search engine best practices.

5. Pharma and Search Compliance – Marcos Richardson
How to Fix Meta Data
As part of the content creation and the regulatory compliance sign off procedure, include the Title
and the Description of each page.
There are certain pages that require more diligence than others, such as product safety information,
product characteristic, product description, dosing information, adverse reactions and side effects.
The Title has a maximum limit of 80 characters before the copy is truncated and the description has a
limit of 155 characters before the message is cut off.
Element Optimised Character Limits
Title Tag length 65-80
Description Tag length 140-155
Within the description, if there is mention of brand and generic names, no claims or representations
(or product indications) should be made.
If diseases or conditions treated by the product are mentioned, no claims should be made.
Whilst regulations in the EU vary, they can be more restrictive and therefore the suggestion is to over
comply.
Example
Element Optimised Character Limits
Meta Title Brand (generic) [section of website] Official Website [uk]
Meta Description
Information for patients about ‘Brand’. View product and
important safety information, including black box warning.
provide links to product, important safety information

6. Pharma and Search Compliance – Marcos Richardson
Interesting Facts
Lawsuits are on the increase in the Pharma industry and the majority are based on marketing claims.
Between 2000 and 2012 the industry paid more than $30billion to settle 226 violations in the USA.
183 patent settlements between originator and generic drug makers were concluded in the European
Union (EU) in 2012, compared to 120 in 2011.
77% 84%
*Health seekers begin their
research at a search engine
*HCPs Use Online
Resources Daily
*Source: Google and HIMSS Analytics, “Hospital Decision Makers Study,”
*Source: Google & CEB’s Marketing Leadership Council, B2B Digital Evolution, February 2013

7. Pharma and Search Compliance – Marcos Richardson
Interesting Facts
Whilst there is a general understanding and acceptance that Paid Search (PPC) has restrictions for
Pharma companies, no such restrictions are in place for Natural (Organic) Search engine listings.
… and 94% of visitors click natural ‘Title’ and ‘Meta’ description results compared to paid results
*Natural Traffic Share
94%
Google AdWords restricts the promotion of healthcare related products and services. We have
different requirements for advertising healthcare-related products based on the product you're
advertising and the country you're targeting.
“We do not generally allow the use of prescription drug terms in ad
text, landing pages or keywords, though there are country-specific
exceptions that only apply to registered pharmacies and licensed
pharmaceutical manufacturers”
https://support.google.com/adwordspolicy/answer/176031?hl=en#country
*Source: GroupM UK and Nielsen

8. Pharma and Search Compliance – Marcos Richardson
Recap and Takeaways
Consumers and Healthcare practitioners are searching for information online and they look at natural
search engine listings when they are making decisions on what content to view. Regulators are
increasingly becoming aware of metadata. When Healthcare companies choose to take part and use
websites and digital assets to promote products, all publicly visible content should be regulated.
Develop regulatory compliant Metadata (Title tags and description meta tags) If there is mention of
brand and generic names, no claims or representations (or product indications) should be made.
Similarly, if diseases or conditions treated by the product are mentioned, no claims should be made.
Add metadata to your content approval process1
Work within the allowable search engine character limits for Descriptions and Titles2
Take a priority approach and apply regulated metadata to sensitive content pages such as
proscribing information and indications.
3
Meta descriptions should be written to either include fair balance, or to omit the drug indication
(i.e. a generic, non-product related statement.)
4