Facebook will be changing how their Facebook Pages work, specifically when it comes to commenting. Currently, Page administrators have the ability to disable comments to Wall posts, photos, and videos. They will be changing that policy to open up commenting on all Pages with a few exceptions.

1. Facebook Comments IssueScenario Planning April 11, 2011

2. Situation Overview What we know: Facebook is planning to enable commenting on all Pages other than those for prescription drugs and devices. This will apply to new and existing Pages. When? This will go into effect around mid-June 2011 Contents are proprietary and confidential.

3. Facebook Pages Affected Corporate Pharma Pages Disease-state / Therapeutic Area Pages Unbranded Campaign Pages Pages that promote, talk about, or support prescription drugs or devices Pages that focus on a disease state where there is only one prescribed treatment (even if they don’t mention the treatment) Disease-state/TA Pages that have the PI / ISI on the Page Contents are proprietary and confidential. Source: Radian6 Facebook Pages Unaffected (can still disable comments)

4. Why is this policy happening? In the best interest of patients’ health, Facebook wants to allow adverse events to be mentioned openly. They were being inundated with requests for Page comments to be disabled. Principle: Having an open forum is Facebook’s way. Money: Facebook makes money when people interact with Facebook. Blocking comments prevents additional ad views and gleaning information about users’ likes/dislikes. Contents are proprietary and confidential. Source: Radian6

5. What Is Expected to Change Anyone will be able to comment on a … Page Wall 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. Source: Radian6

6. Scenario Planning Facebook Implements Open Comments in June Assemble Social Media Task Force 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 Notify affected brand and comms teams Notify your Facebook fans of these changes Implement a tool that will e-mail you whenever someone comments to your Page (Page Notifier app) Set the Moderation and Profanity Blocklists Institute rigorous human monitoring Utilize tool that features auto-removal of comments that contain certain words and phrases (WCG can recommend) Consider creation of a custom Wall, disabling the regular Facebook Wall Contents are proprietary and confidential. Source: Radian6

7. Q&A I’m a big company. Can I get an exception? Probably not. This is a change in policy that is in line with Facebook’s social openness. 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 use a service to create a custom “pre-screened” 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? Probably not, but they’re making that determination Contents are proprietary and confidential. Source: Radian6

8. 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 Can’t I just remove the Wall? Yes, by utilizing a service that creates custom Walls, but you’ll need to disable the regular Facebook Wall, which Facebook members are already comfortable with. Contents are proprietary and confidential. Source: Radian6

9. 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

10. blog.wcgworld.com