White Guide and Orange Guide Formatting Project - Pfizer

Proper Use of HCP Prescriber Data
Orange Guide – Chapter 8: Privacy: Protecting Personal Information
Certain states have enacted legislation that limits the use of prescriber data in certain contexts,
including marketing and promotional activities. Pfizer adheres to all applicable state laws regarding the
use of prescriber data.
From time to time, Pfizer may use de-identified prescriber data to facilitate effective marketing
communications with HCPs. HCP prescriber data serves a variety of purposes, including the tracking of
Pfizer-product adverse events. In addition, the proper use of prescriber data can help you to focus your
activities on those HCPs who would most likely benefit from a promotional presentation on one of your
products. It is vital, however, not to use the data in a manner that compromises its confidential nature
or your integrity as a Pfizer colleague.
You may engage in an on-label discussion directly with the HCP to solicit and learn information about
his or her clinical approach and use of specific products in order to tailor your promotional presentation;
however, you may not directly convey the data you possess on his or her prescribing. You are also
prohibited from sharing an HCP’s prescriber data with other individuals and entities outside of Pfizer.
Within Pfizer, you should discuss an HCP’s prescriber data only with your manager, other colleagues
who call on the same HCP in developing your team’s promotional strategy at other appropriate Pfizer
colleagues on a strictly need-to-know basis. Using prescriber data inappropriately not only
compromises your credibility with the HCP, but it is also a violation of Pfizer policy, may subject you to
disciplinary action up to and including termination, and may violate state laws limiting the use of such
data.
The American Medical Association (AMA) administers a program by which physicians can opt-out of
having their prescriber data released to pharmaceutical companies for use in marketing. Pfizer is
required to check the opt-out list quarterly and has 90 days to comply with a prescriber’s request. If an
HCP has opted-out, Pfizer will respect that preference and will not use his or her prescriber data in
connection with promotional activities. If you learn that an HCP whom you call on has asked for his or
her prescriber data not to be released, even though you would not have access to the HCP’s prescriber
data, you should be especially careful to avoid any discussion of prescribing habits in your promotional
presentations to the HCP. The AMA program allows physicians to report specific instances of
inappropriate behavior by pharmaceutical sales representatives or companies. Thus, it is important
that you familiarize yourself with these rules and conduct your activities accordingly.
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Rev. 09/12
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