Promotion of medical productsPromotion of medical products

Who is responsible for employee activities on SoMe?

/Who is responsible for employee activities on SoMe?

Updated guidelines on the promotion of medicinal products

The Danish guidelines on company responsibility for employee activities on social media have been updated to be more specific and a comprehensive list of questions and answers has been added

By Susanne Tovborg-Jensen

If an employee shares or likes information on social media e.g.:

  • Approval of a new indication
  • Study results from a phase 3 clinical trial
  • Information about a drug that has no marketing authorization in Denmark, or
  • Information about a prescription-only product aimed at the general public

this may be considered a breach of the regulations on the promotion of medicinal products in Denmark.

According to the update, the employee can be held directly responsible
In contrast to the previous version, the updated guidelines now emphasize that the employee will normally be held personally responsible for any such illegal promotion on SoMe. The company may also be held liable if it has asked, or by other means encouraged, the employee to share or like the information.

The updated guidelines on the use of digital media for the promotion of medicinal products to Healthcare Professionals (HCPs) have been issued by the Ethical Committee for the Pharmaceutical Industry in Denmark (ENLI).

Make sure all employees are informed 
ENLI encourage pharmaceutical companies to ensure that all employees know about the rules and regulations on the promotion of medicinal products. They recommend companies to issue guidelines to all staff regarding posting, sharing and/or linking information related to the Company’s medicinal products.

According to ENLI, some companies have rules stipulating that employees should only share information that has been pre-approved by the company.

ENLI’s guidelines on the use of digital media for promotion of medicinal products are available (Pdf in Danish) on their website.

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).

Preparation of concise company guidelines

We help companies develop proper and concise promotion guidelines in accordance with Danish legislation.

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.
2018-09-17T11:02:57+00:00