This is an update to an earlier presentation on Facebook's planned change to their policy on disabling comments made to Wall posts. Currently, Page administrators have the ability to disable user comments to Wall posts, photos, and videos. They will be changing that policy to open up post comments on all Pages with a few exceptions.

1. Facebook Comments Issue
Scenario Planning
May 20, 2011

2. Situation Overview
• What we know:
• Facebook is planning to enable commenting to Wall posts
on all Pages other than those that are solely dedicated to a
prescription drug.
• This will apply to new Pages immediately and existing
Pages as of August 15, 2011.
Contents are proprietary and confidential.

3. Facebook Pages Affected
• Corporate Pharma Pages
• Disease-state / Therapeutic Area Pages
• Unbranded Campaign Pages
• Patient Community Pages
Facebook Pages Unaffected (can still disable post comments)
• Pages solely dedicated to a prescription drug
Contents are proprietary and confidential.

4. What Is Expected to Change
• Anyone will be able to comment on a …
• Wall post
• Video that’s been uploaded
• Photo that’s been uploaded
• You can still remove comments after the fact
• Exceptions would be photos/videos that appear within a
custom app/tab or displayed via another video player
Contents are proprietary and confidential.

5. Scenario Planning
Facebook Implements Open Comments in June
1. Assemble Social Media Task Force
2. Legal revises company’s Terms of Use for Facebook Page to include
company’s right to remove comments at their discretion
• Note cases where comments may be removed (mention of a drug name, AE, off-label
use, misuse, SPAM, profanity, malicious code)
• Once a comment is deleted, it’s gone forever
3. Notify affected brand and comms teams
4. Notify your Facebook fans of these changes
5. Implement a tool that will e-mail you whenever someone comments to
your Page (Page Notifier app)
6. Set the Moderation and Profanity Blocklists
7. Institute rigorous human monitoring
8. Utilize tool that features auto-removal of comments that contain certain
words and phrases (WCG can recommend)
9. Consider creation of a custom app Wall
Contents are proprietary and confidential.
Source: Radian6

6. Q&A
• I’m a big company. Can I get an exception?
• No.
• Can I be grandfathered in?
• No. This will apply to current, as well as new, Pages.
• Can I pre-screen comments as a compromise?
• No, but you could create a custom Wall and disable the main
Wall. However, it will need to be created in a way that posts
to it still appear in fans’ newsfeeds.
• Will open comments apply retroactively to old posts?
• Yes. Older Page posts will be open for user comments after
the change.
Contents are proprietary and confidential.
Source: Radian6

7. Q&A, con’t.
• Can I temporarily remove the Page?
• No. If you remove a Page, it’s gone for good.
• Should I just delete my Page?
• That is your prerogative, but ask yourself, “Why did we start
this Page in the first place? To engage or to advertise?” If it’s
the former, then the reason to have it remains.
• Won’t my custom tab pre-screen the comments?
• Yes, but only those comments made on that custom tab
• If I just put my ISI on my disease-state Page, can I get
an exception?
• No, the sole focus of the Page must be a prescription drug in
order to have post commenting disabled
Contents are proprietary and confidential.
Source: Radian6

8. When this happens, be mindful of …
• Dissatisfied patients/caregivers
• Current employees: remind them of internal SM policy
• Ex-employees: disgruntled or laid off
• Pharma naysayers, watchdog groups
• Patients openly discussing treatments
• “Free prescription” spammers
• Corporate/financial news
Contents are proprietary and confidential.
Source: Radian6

9. blog.wcgworld.com