As GDPR approaches on 25 May 2018, pharmaceutical companies throughout Europe are scrambling to ensure that they can stay in touch with their HCPs via digital means. This is only possible if the HCP gives the pharmaceutical company explicit consent to proactively send them material. Our recent whitepaper discussed the background, the legal situation and reviewed multiple approaches for collecting such consent, also known as opt-ins. In this article we’d like to look at the opt-in collection process as a campaign.
Let’s take a fictitious pharmaceutical company: IsarLife. Of course, if you’d like to follow this template, you’ll obviously want to modify the parameters to meet the specifics of your business.
IsarLife specializes in oncology products. They have 40 field sales reps to support 4,000 HCPs in this area. IsarLife has collected opt-ins at various times in the past. They are unsure if the previous opt-ins are compatible with GDPR so, as their compliance officer has insisted, they will try to renew these opt-ins and collect new ones as well. IsarLife is launching a skin cancer product later this year and is also sponsoring an important conference on brain cancer.
IsarLife set a target of collecting opt-ins from 1.600 HCPs over the next 12 months. This represents 40% of all relevant HCPs. Broken down by sales rep, the numbers become quite reasonable. In order for IsarLife to reach this target, each sales rep needs only to collect 40 opt-ins or just over 3 per month. IsarLife defines a team incentive if the company reaches the goal by the end of the year.
IsarLife chose not to ask for blanket opt-ins covering any and all material but rather topic-specific opt-ins. IsarLife expects that this will increase the likelihood that the HCP gives consent. IsarLife will ask for two types of consent in the first wave:
- Permission to send news related to skin cancer treatment
- Permission to send news about the brain cancer conference
The sales reps typically deal with only one therapeutic area. In any case, they can see in their CRM which HCP is involved with which therapeutic area.
IsarLife then defined two opt-in templates. The templates describe for what the HCP is giving consent: topic, channel and duration. IsarLife chose to make the opt-in topic somewhat narrow however they are asking the HCP to agree to all channels. In other words, if the HCP is interested in the brain cancer conference, he or she will agree to receive information on the conference via digital channels, phone calls and post. Furthermore IsarLife decided not to have a predefined expiration date for the consent. Of course the template explains to the HCP how they can unsubscribe at any time.
IsarLife sales reps downloaded a consent management app on their tablets. Using this app, the sales reps can look up the HCP and then choose the appropriate consent template, which the system administrator has already designed and uploaded. In an ideal situation, the app is integrated with the CRM in order to save valuable time for the sales rep.
So now the sales rep is all set to begin collecting consent. At every visit, the sale rep tries to bring up the question of consent at the appropriate moment. The right moment is usually not at the start of the conversation, but rather after the sales rep has already sparked some interest in either the skin cancer treatment or the brain cancer conference. He or she may follow up with a question such as: “I’d love to send you more information about the skin cancer treatment. Unfortunately new rules require me to ask for your consent so that we can send this to you. Would you mind confirming your email address, checking this box and signing your name on this tablet?”
At this point, the sales rep can hand the tablet to the HCP, who can then digitally sign with a finger or a stylus. If the HCP chooses not to sign, the sales rep can mark the HCP with the status “denied consent”. This way, IsarLife can track who has been asked already and the sales rep doesn’t need to ask again, unless a new topic of interest emerges in the future.
Some HCPs are not visited in person. Either they have requested not to have face-to-face visits, their locations are too remote or they are lower priority. In these cases, the inside sales reps at IsarLife may still phone the HCPs. In the course of the phone call, the inside sales rep may ask for consent. Should the HCP give a verbal consent, IsarLife follows up with an email for the HCP to confirm. This fulfils GDPR’s double-opt-in requirement.
Most apps keep statistics on opt-ins. So at any point, IsarLife can track the progress of the campaign on a campaign dashboard. See example below.
- Collect consent in the framework of a campaign in order to structure the process and increases the success of achieving the goal.
- Don’t ask for general or blanket opt-ins. This may scare some HCPs away. It’s better to ask for a limited opt-in so the HCP does not feel he or she will be spammed
- Set achievable team goals and incentivise the team to reach the goal
- Use software to ensure GDPR compliancy and support your sales reps
- Measure the campaign along the way