As discussed many times in recent days by FUV and people like Dr. V and Lauran Driver, SXSW is in full swing.  The days leading up to the annual meeting of the geeks was prefaced this year by the first Social Health 2010 (aka SXSH) – the brainchild of Shwen Gwee and Dana Lewis – two very bright, motivated people with a passion for all things social and all things health.

I envisioned myself spending time with both Shwen and Dana, among others, and was really looking forward to hearing Eric Qualman and meeting e-Patient Dave.  Heck, I might’ve even laid down some freestyle with @datboikhaki.

But, alas, duty calls – in the shape of an important client meeting that required my attendance in person.

Fear not, though… what I’ve discovered over the last few days is – you can learn a lot by not going to a conference.  In fact, not attending might be the ultimate unconference.

With great coverage and updates from Mashable, Rohit Bhargava and others, I’m keeping up with the good, the bad, and the ugly going on in ATX.  Oh, the hashtags help too (#SXSW, #SXSH, #SXSWi, #ER20, #selfpromosaveworld).  So here’s some of the things I’ve learned by not attending SXSW 2010…

The other important reminder of this week – client service and prioritizing client needs trumps BBQ, boots, and geeks (regardless of my love for all three).

Did you miss SXSW this year?  Are you following it?  If so, who are you following and what have you learned?  Alternatively, have you learned/experienced something that you would have missed if you were in Austin?  Share your thoughts with me here.

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Facebook recently released new Promotions Guidelines, which will likely have huge implications for brands and companies engaging with their customers on the platform.  This newest policy update applies only to contests and sweepstakes — however, it is yet to be seen whether or not Facebook will extend such guidelines to other promotions such as coupons.


Perhaps coincidence, but it’s interesting to note that these new guidelines come only weeks after the FTC’s Guides Concerning the Use of Endorsements and Testimonials – which  we’ve discussed here and here, and on the heels of the FDA’s public hearing on promotion via the internet and social media, summarized here by Bob Pearson.


Although Facebook’s new guidelines do not prohibit companies or brands from running promotions, this is a significant change in that Facebook is moving towards monetizing yet another stream within the platform (e.g., advertise or bust).  In a way, it’s not unlike moves that YouTube made, only they did it earlier and it was predicated by the technological requirements of running a video (only) platform.


The complete Facebook guidelines can be found here.  To save you the click, I’ve included a few key highlights below.  You can also check out Michael Richter’s (Deputy General Counsel for IP at Facebook) blog post, in which he explains their thinking about the changes:

Section 1 General

1.3 You will not in any way use our name, trademarks, trade names, copyrights, or any other of our intellectual property in the rules or any other materials relating to the promotion, without express written consent.

While this isn’t new to Facebook, I’ve noted it here as I believe it will tie into point 3.6 below, so worth keeping in mind for planning purposes.


Section 3 Administering a Promotion through the Facebook Platform

You may not administer any promotion through Facebook, except that you may administer a promotion through the Facebook Platform with our prior written approval. Such written approval may be obtained only through an account representative at Facebook. If you are already working with an account representative, please contact that representative to begin the approval process. If you do not work with an account representative, you can use this contact form to inquire about working with an account representative. If we provide you such approval, you agree to the following:

3.1 You will only administer the promotion through an application on the Facebook Platform, as directed by us.

3.2 You will only allow users to enter the promotion in the following locations on Facebook:

3.2.1 On the canvas Page of an application on the Facebook Platform.

3.2.2 On an application box in a tab on a Facebook Page.

3.3 You will include the following language in a clear and conspicuous manner adjacent to any promotion entry field: “This promotion is in no way sponsored, endorsed or administered by, or associated with, Facebook. You understand that you are providing your information to [recipient(s) of information] and not to Facebook. The information you provide will only be used for [disclose any way that you plan to use the user’s information].”

3.4 You will not mention “Facebook” in the promotion’s rules except in the following ways: (i) “You can enter the Promotion through the [application name] application on the Facebook Platform. You can also find the application on the [tab name] tab on the [Page name] Page on Facebook.”; (ii) to fulfill your obligations under Section 3.7.

3.5 You will designate an individual to act as a primary contact to address any communications from us with respect to the promotion.

3.6 You must submit materials for any promotion you plan on administering through the Facebook Platform to your account representative for our review and approval at least 7 days prior to the start date of such promotion. Promotions not approved in writing within such time period will be deemed unapproved.

3.7 You will include the following provisions within your official rules for the promotion:

3.7.1 Acknowledgement that the promotion is in no way sponsored, endorsed or administered by, or associated with, Facebook.

3.7.2 Complete release for us from each entrant or participant.

3.7.3 Any questions, comments or complaints regarding the promotion will be directed to you, not us.

The most important section of these guidelines – outlining specific requirements on where you can run a promotion, what specific disclaimers you must attach, and the fact that you must get approval of promotional materials at least 7 days in advance – through your Facebook account representative (e.g., you’ll need to establish an account representative (code for: you need to advertise!)

Section 4 Publicizing a Promotion on Facebook

4.2 In the rules of the promotion, or otherwise, you will not condition entry to the promotion upon taking any action on Facebook, for example, updating a status, posting on a profile or Page, or uploading a photo.

This mandate seems to directly target the more recent, growing trend with contests and promotions to require a Facebook status update.  Hat tip to Facebook’s attorneys for foreseeing future litigation and putting this on paper now.


While these guidelines provide some additional hurdles, the good news is that they don’t shut the door on promotions done right.  The bad news is that added steps and (no doubt) advertising costs will prohibit many companies from running repeated, small prize contests, which are often more effective than one time contests with big payouts.   What do you think?  Is Facebook making itself a more or less attractive channel for contests and promotions?

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The other day my son was suffering from a case of what I call the “Yeah Buts” and “What Ifs”.  I was trying to explain the list of things we were going to do that day and, at every turn, he fired back with a “yeah but…” or “what if…”.  I eventually won out, but it helped that I expected resistance and was prepared to respond.

In reflection, this scene was not entirely different from the discussions pharma communicators and agency staff are having with legal and regulatory colleagues as we discuss social media engagement.

Many of us have been in meetings to discuss a program or concept review and, no matter how well-intentioned, thought-out, or supported by case studies and competitive examples, the response we hear is often akin to a “yeah, but”.

There’s hope on the horizon.  Maybe.

There’s been a lot of buzz regarding the pending FDA Meeting on internet and social media use by regulated medical products.  The enthusiasm, speculation and predictions about the outcomes are all over the pharmasphere.  Suffice it to say, I think all involved would agree that the time has come for the FDA to address the internet – and social media specifically – and that FDA guidance needs to evolve to reflect the variables of new technologies and mediums.   However, as my colleague Brian Reid alluded to here (see Myth #3), this is not going to happen overnight.

So what do we do in the meantime?

Well, for starters, expect more yeah buts and what ifs to come.  Here are a few things you can continue to do to prepare for those conversations:

  • Drill home the importance of developing appropriate social media strategies for your company or brand(s).  Not every brand needs to be on Facebook or Twitter.  But, at the very least, every company and brand should know where the relevant conversations are happening and who is involved.
  • Educate – Often times, I find that the same colleagues offering “yeah buts” are, themselves, not at all involved in social media.  Part of our challenge will be to educate them on the medium – providing easy-to-understand explanations of communities, file-sharing sites, microblogs, etc.
  • Share examples – Don’t just send a “look what competitor X is able to do” email.  Pull together relevant examples – both good and bad.  (Hat tip to Jonathan Richman for this list of pharma companies and brands engaged in social media.)
  • Enlist support – Internally, your commercial leadership needs to be aligned with your plans and informed about the barriers ahead of you.  Enlist their help in making the case.

Finally, like my discussion with my son, be prepared and be persistent!

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