May 20, 2011

Facebook Comments Issue Scenario Planning

Situation Overview

• What we know: •  Facebook is planning to enable commenting to Wall posts

on all Pages other than those that are solely dedicated to a prescription drug.

•  This will apply to new Pages immediately and existing Pages as of August 15, 2011.

Contents are proprietary and confidential.

Facebook Pages Affected

• Corporate Pharma Pages • Disease-state / Therapeutic Area Pages • Unbranded Campaign Pages • Patient Community Pages

• Pages solely dedicated to a prescription drug

Facebook Pages Unaffected (can still disable post comments)

Contents are proprietary and confidential.

What Is Expected to Change

• Anyone will be able to comment on a … •  Wall post •  Video that’s been uploaded •  Photo that’s been uploaded

• You can still remove comments after the fact • Exceptions would be photos/videos that appear within a custom app/tab or displayed via another video player

Contents are proprietary and confidential.

Scenario Planning Facebook Implements Open Comments in June

1.  Assemble Social Media Task Force 2.  Legal revises company’s Terms of Use for Facebook Page to include

company’s right to remove comments at their discretion •  Note cases where comments may be removed (mention of a drug name, AE, off-label

use, misuse, SPAM, profanity, malicious code)

•  Once a comment is deleted, it’s gone forever

3.  Notify affected brand and comms teams 4.  Notify your Facebook fans of these changes 5.  Implement a tool that will e-mail you whenever someone comments to

your Page (Page Notifier app) 6.  Set the Moderation and Profanity Blocklists 7.  Institute rigorous human monitoring

8.  Utilize tool that features auto-removal of comments that contain certain words and phrases (WCG can recommend)

9.  Consider creation of a custom app Wall

Contents are proprietary and confidential. Source: Radian6

Q&A

• I’m a big company. Can I get an exception? •  No.

• Can I be grandfathered in? •  No. This will apply to current, as well as new, Pages.

• Can I pre-screen comments as a compromise? •  No, but you could create a custom Wall and disable the main

Wall. However, it will need to be created in a way that posts to it still appear in fans’ newsfeeds.

• Will open comments apply retroactively to old posts? •  Yes. Older Page posts will be open for user comments after

the change.

Contents are proprietary and confidential. Source: Radian6

Q&A, con’t.

• Can I temporarily remove the Page? •  No. If you remove a Page, it’s gone for good.

• Should I just delete my Page? •  That is your prerogative, but ask yourself, “Why did we start

this Page in the first place? To engage or to advertise?” If it’s the former, then the reason to have it remains.

• Won’t my custom tab pre-screen the comments? •  Yes, but only those comments made on that custom tab

• If I just put my ISI on my disease-state Page, can I get an exception?

•  No, the sole focus of the Page must be a prescription drug in order to have post commenting disabled

Contents are proprietary and confidential. Source: Radian6

When this happens, be mindful of …

• Dissatisfied patients/caregivers • Current employees: remind them of internal SM policy • Ex-employees: disgruntled or laid off • Pharma naysayers, watchdog groups • Patients openly discussing treatments • “Free prescription” spammers • Corporate/financial news

Contents are proprietary and confidential. Source: Radian6

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