New Danish guidelines include company responsibility for employee activities on the social media

According to an updated version of Danish guidelines on digital medias for promotion of medicinal products, companies may now be held responsible for their employees’ activities on social media.

By Susanne Tovborg-Jensen

A highlight of the changes

If an employee “likes” or “shares” a post on a public media regarding a new medicinal product or shares information about a prescription-only product, this may be considered illegal promotion towards the general public.
It is the Ethical Committee for the Pharmaceutical Industry in Denmark (ENLI) who has issued the updated version of the guidelines regarding the usage of digital medias for promotion of medicinal products aimed at Healthcare Professionals (HCP).
According to ENLI, the rule is that an employee in a pharmaceutical company is representing the company, when communicating on the social media including the internet, regarding subjects related to the company. This is because the place of employment appears from e.g. the employee’s LinkedIn profile.

A specification to the broad interpretation of promotion
According to ENLI, the background for the new guidelines is the broad interpretation of “promotion” being “any form of door-to-door information, canvassing activity or inducement designed to promote the prescription, supply, sale or consumption of medicinal products” and because information about a medicinal product communicated by a third party could be regarded as advertising even though this third party is acting on its own and is independent of the manufacturer or seller of the medicine.

About ENLI
ENLI is a self-regulating body established by the Danish Association of the Pharmaceutical Industry (Lif), The Danish Generic Medicines Industry Association (IGL) and The Danish Association of Parallel Distributors (PFL).

Get guidance to get it right

For questions in regards to Danish legislation and guidelines regarding promotion please contact Susanne Felumb.

Contact information

For an initial talk, please feel free to contact Susanne directly at: +45 4450 3206, or via

Susanne FelumbCEO and QA Manager, MSc. Pharm.
Susanne is the owner and CEO of PharmAdvice, and has more than 20 years of experience in the international pharmaceutical industry with QA, and regulatory affairs.