Grünenthal

An Observation

Two things changed the pharmaceutical industry in 2020. One was the pandemic, the other well……..crept up on us.

COVID-19 is a once in a century occurrence. Our lives met the pause button, milestone moments were either delayed or cancelled by the coronavirus. The hospitality and travel industries were probably hardest hit. Generally speaking the Pharmaceutical industry came out of it fairly well. We were lauded in our efforts to find a vaccine, companies opened up manufacturing plants to competitors and refitted production lines to increase capacity. Whilst physical distancing restrictions meant interventional treatments were delayed, in most cases medicines still got it to the patient.

It remains a difficult situation, the industry has become a business partner to healthcare professionals in the last 15 years. During the peak of the first wave, we found ourselves “cut off” perhaps even “surplus” to the needs of the profession. Companies asked their commercial team to respect their customers time, not to disturb them during the unfolding crisis. Our teams sat at home and filled their time with training and other skills development, some teams were even furloughed.

Allied Healthcare Professionals, Doctors, Nurses and Administrators were focused on tackling the spread of COVID-19. Time and resources were diverted, our customers had no time for us. The industry’s way of accessing our customers disappeared overnight.

It became difficult to call, we could no longer visit them in person and they were unavailable on email, therefore how do we operate?

Traditionally, a company representative will visit an HCP on site. Ideally by appointment or in many cases “On Spec” (Speculative). Either one to one, a small group or a more formal event. All this vanished during the lockdown.

A number of well-resourced companies had invested in virtual engagement. They set up small teams dedicated to remote calls; the teams were usually made up of tech savvy graduates and not your traditional sales representatives. The return on investment was hard to define. Never the less many companies tested the waters. Interestingly, I know of a few companies that stopped investing in these teams a year or so before the Pandemic.

The Other Thing

The full impact of the General Data Protection Regulation (GDPR) crept up on a lot of us. This European wide legislation went live on 25^th May 2018, many Legal and Compliance teams prepared the organisations for what was right in front of them. Tasks were undertaken to define and prepare for the directive, requirements like Article 30 were implemented (a record of processing activities), but some things were less obvious in its impact on existing operations.

"Companies thought they had time to incrementally change operating models to include digital; most did not foresee the traditional model collapse, as it had worked for decades"

Companies thought they had time to incrementally change operating models to include digital; most did not foresee the traditional model collapse, as it had worked for decades.

All had plans to engage digitally; from website redesign, smartphone apps for patients, integrating microsites etc. Some companies even divested entities to engage with remote medicine, there were so many great ideas.

Everyone thought they had time to test, refine and create these digital offerings.

The pandemic asked questions that went beyond what had been pondered. We never prepared for a scenario that we could not see, call or visit customers.

For the compliance professionals, we were only beginning to dig deep into what the GDPR could mean for commercial operations. No one ever really wanted to remove the sales force, the old adage is that people buy from people, you need social interactions to do that. How do we engage with our customers now?

Many local codes of practice drafted digital guidelines. The UK’s Association of British Pharmaceutical Industry (ABPI) introduced its first digital communications guidance back in 2016, essentially built on the traditional ways of working, with a sample of what might be in-scope in the coming years, they did ask the industry to bring forward new ideas. But as technology out-paced everything else, no new guidance was forthcoming.

What’s Next?

Think quicker than we have before, build an infrastructure and fully operationalise remote engagements. But what about the GDPR, this legislation gave individuals a new level of “control” like never before, with rights not yet fully tested. It’s been more than 3 years and regulators have only scratched the surface.

Convention 108 brought forth some protection of individuals regarding automated processing of personal data back in 1981, however the wider public really had no exposure to this, let alone any real understanding on how to exercise them when sharing their personal information.

What’s more Pre-covid companies were not compelled by market conditions, but leading software providers had been testing the waters and introduced stand-alone virtual engagements platforms aligned with customer management systems. Meanwhile, many webinar platforms were in its’ adolescence, companies tried WebEx, Adobe Connect, and then Zoom.

Pharmaceutical companies realised that digital transformation needs to be ready today and not 2025.

•Which platform do we use?

•Does a platform even exist?

•How can we secure our sensitive conversations?

•How do we comply with the GDPR and codes of practice?

•Do we need Consent or can we work on Legitimate Interest, what is our legal basis for that?

•How do we collect permissions, when all we ever had was a switchboard phone number?

•How do we categorise our permissions?

•How many do we need?

•Do our customers understand all this data privacy stuff?

•How do we convince them?

•We will just upset them!

For all of us in the compliance world, it is never dull and we will not always have the answers, but we are trying to find out.