This week, it was reported that Facebook would soon be announcing updates to their policy on Page commenting. Dose of Digital detailed the finalized plans for those updates. What we’d like to do here is outline the implications for pharmaceutical companies who have – or are planning to start – a Facebook Page.
To sum up what is changing:
- Previously, any Page admin could disable user-generated posts to their Wall, but they could not disable user comments to company-generated Wall posts. Pharmaceutical companies could request an exception to that latter case, so that all user-generated comments could be disabled.
- After this policy change, a Page admin can still disable user-generated posts to their Wall, but there will no longer be a by-request exception to disable user comments to company-generated Wall posts. The only exception to disabling user comments will be for Pages that are solely dedicated (in Facebook’s opinion) to a prescription drug.
When will this change take place?
For any newly created Pages, this policy will go into effect immediately. For any existing Pages, this will go into effect on August 15, 2011.
As we said earlier, we don’t see this as a bad thing. We all expected this day would come, where we’re expected to be “social” in social media. It’s just a matter of now getting your ducks in a row to be prepared for this change. If your current or planned Page is dedicated to a drug, then you can still request commenting be disabled. If, however, your Page’s focus is corporate, disease state, patient community, or campaign-driven, you will need to be prepared for users commenting on your Page’s posts. This means close and constant moderation of your Page.
Additionally, once this change affects your Page, any of your old Wall posts (pre-policy change) would then be open for user comments. If you would rather not allow your old posts to be open for user comment, your options are to delete those old posts or have Facebook transition your Page to a new instance of the Page, whereby you would retain your fans, but you lose any of your old Page content (posts, photos, videos, custom tabs, etc.).
Based on the wording of the proposed policy, it does not appear that simply having your drug’s ISI on a disease-state Page would qualify your Page for an exception. Again, for the exception, your Page must be “solely dedicated to a prescription drug,” and this would be at Facebook’s discretion.
Another option that has been bandied about is the use of a custom app Wall to allow for comments to be pre-screened. While that is an option, it’s important to note that 600 million Facebook users are not used to interacting with Facebook in this way — they see something, they comment, instant gratification. Plus, your relevance and presence on Facebook is measured by the level of social engagement with your Page (liking, commenting, sharing, etc.). If your only means of social interaction is a custom app Wall, you will lose that relevance and presence and, thereby, start to disappear from your fans’ newsfeeds, which is the primary way that your fans “see you.” A custom app Wall can be developed to have fans opt in to receive your updates, but it would be without the benefit of liking or commenting on the updates. Similarly, with Facebook’s search tool being a social-based search (and not solely a text-based search), your lack of social engagement on Facebook would exclude you from search results.
This policy change, while significant, is still manageable. It will simply require a fair amount of counsel and preparatory work between now and August 15.
Here is an updated presentation with more details on this.