Control of company website and social media

[RobertMMolinaro]

Hi all,
My company is a small, US-based medical device manufacturer. We have a mature quality system with effective documentation management. We are re-doing our website to strengthen our internet presence, and we have somewhat active social media accounts on Facebook and Twitter. We want to ensure that Quality has approval powers over what the commercial team publishes to our website and social media, but this is new territory for us and we aren?t sure of the best way to manage it. Has anyone incorporated control of websites and social media into their change control process, or written dedicated SOPs for managing them? If anyone has any advice I would appreciate it!
Thanks!

 

[PaulJSmith]

Re: Control of website and social media

Exactly what controls does Quality need regarding your company's web content?

 

[RobertMMolinaro]

Similar to how we review and approve internal documents (work instructions, batch records, specs, etc...), Quality wants to review and approve website content and possible social media posts before they are uploaded/posted. We want to ensure that content and links on the website are vetted by Quality. We are still hashing out what controls Quality should have over social media, which is part of the reason why I wanted to ask for advice.

 

[Michael_M]

Similar to how we review and approve internal documents (work instructions, batch records, specs, etc...), Quality wants to review and approve website content and possible social media posts before they are uploaded/posted. We want to ensure that content and links on the website are vetted by Quality. We are still hashing out what controls Quality should have over social media, which is part of the reason why I wanted to ask for advice.

One of the issues I see with Quality vetting the social media is 'time'. I don't know anything about social media (I don't use any of it), but the people I know who use it say they like it because of the speed with which you can get information/answer/updates.

If your procedures slow this down too much, you may have a negative result. I personally would not want to have to approve social media posts. Does quality have to approve all e-mails that get sent out? I think social media and e-mail is pretty much the same thing.

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[RobertMMolinaro]

Thanks for your comment Michael_M. Time is important for social media, but I think that social media is more akin to advertising than email.

An email is specifically sent to one or more intended recipients. They may choose to forward it or not, but email is generally meant as a communication between a sender and a specific recipient or group of recipients. Social media posts are broadcast so that anyone can view them, like an advertisement. In addition, an email may represent the views of the sendor or of their company (depending on context), but social media gives the appearance that any views expressed are those of the company, rather than the individual who wrote them.

 

[QSMLauren]

I have to agree with Michael M.; I see it more of a marketing/communication function than quality; however if you are small perhaps you don't have separate people. Another example - Is Quality involved in approving various advertisements/brochures that go out? The only place I see it making sense is approving product specifications or a customer survey that is posted on the web.

 

[DCinOKC]

At the previous medical device company I worked for, we also required Quality approval of the content of our website. It was a bear to manage, but with FDA inspecting more and more websites, we had to ensure that product claims and information were correct and did not differ from what we had submitted to the FDA. But the product claims are all Quality was concerned with. All claims made had to be identical to what was approved in our product information literature - IFUs, user manuals, labeling, etc. If those were changed, then the website was captured in Change Control and changed as well. We had a great Marketing department that was very aware of regulatory requirements. I'm still not sure that was the most effective way to control the website, but it worked for us. We didn't have a presence on Facebook or Twitter, so I'm not sure how you would handle that.

 

[deanbell]

In agreement with QSMLauren, that social media content is related more to marketing and public relations strategy than quality.

This said, it would be prudent for your quality function to be involved in the development of a corporate social media policy. This would include:
- Which SM technologies will be used, and how memberships/subscriptions will be managed (I.e. registrations, administration of passwords).
- Protocols for who can create SM content, and whether separate approval is required prior to publication (if so, it is up to you to define who is the most appropriate authority for this).
- What type of content is intended to be broadcast using your SM policy, and whether different SM platforms should be used for different types of publications.
- Any forms that are to be used for the drafting and recording of intended SM content, including approval (this may not be required for your organisation, but I have seen internal templates for this from a couple of businesses).
- Whether internal audits will be conducted to ensure that published SM content is consistent with your policy.
- Processes for how to remove or respond to detected inappropriate SM content.

As stated in ISO9001, define your processes, document, implement, and audit as necessary.

 

[isoalchemist]

I'm with DCinOKC on this one. The FDA does look at the website and checks for what is posted and if any uses are claimed or implied that are not approved. Within the scope of ISO 9001 I had to have our marketing guys pull both wording and images that would have gotten us in trouble with our registrar.

Ideally someone is the marketing group is knowledgeable about the requirements and can serve as the checkpoint. In most companies that is not the case and should fall into the Quality and/or Regulatory group. In either case a system should be in place and audited.