Programmatic advertising – or advertising that runs according to an algorithm or in an otherwise semi-automated way – is one of the most powerful and effective methods available to marketers today. Yet even as programmatic continues to make up nearly 80% of ad spend in most other industries, pharma is still lagging behind. 

The main reason for this is somewhat self-evident: advertisements that target users based on data about them, in the healthcare space, run the risk of violating HIPAA or other privacy protections, including those instituted by advertising platforms themselves (see: Facebook’s changes to available interests and Partner Categories). Pharmaceutical advertisements are also, of course, subject to FDA requirements and draft guidance, just as they would be in any other format – and the digital space can be somewhat murky, which means compliance requires a more careful hand than one might see with a typical programmatic campaign.

There are some other reasons, of course – including that TV continues to be an effective medium for pharma advertising, perhaps more so than in other industries – and it’s unlikely that most brands will drop their current strategies to adopt the latest and greatest features available in digital marketing. But the power and opportunity in this type of advertising means pharma brands ought to give programmatic a second look – particularly when looking ahead to the future.

There are signs that programmatic might be trending up in the healthcare space. Healthcare digital spending as a whole is going up, and according to a report from Pulsepoint, 37% of digital spending in healthcare is programmatic. But that’s still far behind nearly any other industry, so there’s still a lot of room for expansion.

Is All Programmatic Advertising Dangerous?

While any patient-focused programmatic campaign is going to carry some risks, it’s important to be aware that there are actually a number of programmatic approaches to digital advertising that avoid them. Here are some of the strongest examples: 

HCP Marketing

An easy way to avoid expensive HIPAA violations with your advertising campaigns is to focus primarily on HCP’s. HCP-targeted ad campaigns already make up a substantial percentage of pharma ad spend – as the traditional model of advertising products to doctors first has yet to be overtaken by DTC advertising, despite significant growth in that category in recent years – so a healthy emphasis on this share of the market should fit well within an updated digital strategy. 

Because the interests and other user data attributed to HCP’s correspond to their line of work, as opposed to representing any personal health information (PHI), targeting them programmatically doesn’t risk running afoul of the main HIPAA concerns about patient privacy. This should make it a lot easier both to target the right audiences using the tools available with platforms like Google Ads and Facebook, and to show them relevant content that doesn’t insinuate or imply that they have a certain medical condition (as might be the case with a patient). 

Search Engines

Search engine marketing (SEM) – namely through Google, but also with Bing Ads – has long been an effective and safe method of programmatic digital advertising; arguably, one of the very first. The reason advertising through search, as with most any inbound tactic, is safe from privacy violations is that it relies on user intent (revealed through keywords) to determine what content to show. This is still, of course, very much an algorithmic and automated process – as both the ad auction and organic search results have always been – but it doesn’t use identifiable information to determine relevance; simply the keywords users have already entered.  

Granted, platforms like Google are moving toward using user data to refine ad results, and of course, display advertising through Google is going to be shown based on relevance. But in those cases, there is still a heavier emphasis on interests demonstrated through web behavior and the nature of the content on placement pages than on data collected about a given user over a period of time. And generally speaking, Google is bound by tight privacy rules as well, so it’s unlikely that the search giant would reveal or use sensitive personal information to target ads that are somewhat based on user data.

What Platforms Are Best For Programmatic Pharma Advertising?

Facebook Ads

Although Facebook has had its share of bad press about user privacy violations – some of it well-warranted – the platform has done a lot recently to ensure that it is not inappropriately sharing user data or otherwise providing information to third parties that could run afoul of regulations. While it may have come at the cost of some useful interest targeting categories, marketers in the healthcare space especially can breathe a little easier now that there is extra scrutiny on Facebook’s privacy adherence, both internally and externally. And with Facebook’s ad targeting platform being as powerful and cost-effective as it is, that is great news for brands looking to expand their spend on programmatic ad buys. Particularly with HCP-targeted campaigns, the reach and precision of this platform can’t be matched elsewhere, so pharma marketers would do well to give Facebook Ads a closer look when planning or updating their digital strategies. 

Google Ads (Search & Display)

Again, the inherently programmatic but user-driven nature of Google search ads makes them a great and indispensable option for pharma brands looking to take advantage of the most powerful ad platforms available today. Carefully executed Google Ads campaigns can reach tens of thousands of users at a time, intersecting at all steps of their online search journey, and delivering relevant and informative results to help answer their questions at the exact moment they’re asking. 

Google Display ads are another powerful programmatic option, and even retargeted ads (based on previous user behavior) can be executed effectively without relying on protected user information to be relevant. Placement pages naturally operate as interest proxies, so if a user is visiting a given page about a certain health condition or treatment option, it’s not out of place for there to be some related advertising, nor does that require the use of individual data to show the ad at a relevant time. 

“Connected” TV (Netflix, Hulu, YouTube TV etc.)

TV continues to be highly profitable for pharmaceutical advertising, and its enduring dominance as a share of advertising spend reflects that. Fortunately for digital advertisers, “connected” TV options like Netflix, Huli, or YouTube TV offer a middle ground in which users still consume TV in a similar fashion (thus yielding many of the same benefits) but their advertising choices are driven by available data points, such as web use, purchase behavior, and preference in shows. That means advertisers can increase the relevance of their targeting while not losing out on a valuable, tuned-in audience, and still avoid concerns about privacy because the ad platforms are already bound by regulations to not reveal any personal or health-related information– if they even have access to it. 

How Pharma Brands Can Use Programmatic Advertising Safely

Even as privacy protections online become more and more stringent, there will always be some risk involved in automating advertising based on user data – and it may still be a difficult sell to executives who’ve been in the game for a long time. Nonetheless, here are the best practices we recommend for staying in the clear and safely taking advantage of this powerful (and likely inevitable) method of digital advertising.

Never Use Personally Identifiable Information (or PHI).

It should go without saying, but advertisers should avoid using personally identifiable information at all times. While in most cases, targeting criteria would not require that to begin with – at least with most platforms – but there are some exceptions, such as Facebook’s “Custom Audiences” feature, which allows advertisers to target people based on their previous interactions with a business or page (including, potentially, lists of existing customers using their email addresses to match with their accounts). One possible workaround to this might be generating a Lookalike Audience based on a Custom Audience, which would by definition be anonymous.

Adhere to draft guidance and “fair balance” rules.

Along with HIPAA privacy protections, advertisers online should pay attention to the applicable guidelines regarding digital content, including the draft guidance issued by the FDA for pharma brands using social media. While it’s worth revisiting the exact provisions there, the most important concept is adhering to the “fair balance” rule, which stipulates that brands include just as much positive information about a product as negative information. This can be challenging in character-limited formats, but it’s a necessity for compliance, so ad copy and content should always be created with that requirement in mind. 

Use Neutral Messaging And Avoid Speaking “To” Patients.

One of the most important things to remember when crafting copy targeted at patients who may have a related medical condition (or be connected to someone who does) is that the messaging itself should not suggest knowledge of a user’s medical information or history. You can direct users to a page to learn more about a given condition or treatment, but the messaging should be applicable to anyone who may have even a passing interest in the topic, not just someone who has the disease. Along with this, avoid using “second person” language or asking questions of the users, such as whether or not they’re experiencing certain symptoms. These messaging tactics can be somewhat engrained for some marketers, but in the world of programmatic advertising they often make people feel personally targeted and uncomfortable.

Focus On Providing Information vs. Selling.

An easy and helpful way to ensure ads are not straying into dangerous territory is to gear most copy and advertising toward informing people, rather than pitching a product. Of course, product advertisements should be as informative as possible, but, especially given that users tend to engage with healthcare-related content for a longer period of time, it’s in advertisers’ best interest to build their strategy around quality educational content as much as (if not more than) actual advertisements. This has the added benefit of appealing to a broader segment of users and thus not precisely targeting people based on a condition.

Concentrate On Inbound Methods To Attract Users.

As always, inbound marketing tactics are powerful for their ability to earn traffic without needing to “reach out” to users, which helps cut against the risk that they might feel their information is being used to target them. And in general, inbound tactics tend to focus on some of the tactics outlined above, like high-quality content, which means they are likely to help you stay in the clear.


It seems that no matter what, programmatic will only become more and more commonplace in advertising, so as long as this reality holds true, pharmaceutical and other healthcare advertisers would be wise to take advantage of this rapidly growing technology. As long as best practices are followed and great care is taken to protect patient privacy, there’s no reason pharma can’t catch up to the rest of the advertising industry and share in the considerable benefits.


Digital is good https://www.capgemini.com/wp-content/uploads/2017/07/The_Digital_Advantage__How_Digital_Leaders_Outperform_their_Peers_in_Every_Industry.pdf

Mobile is big: https://www.mdgadvertising.com/marketing-insights/the-state-of-healthcare-advertising-4-key-digital-spend-trends/ 

More on programmatic: https://www.pulsepoint.com/data-trends




HCP focus: https://www.bulletinhealthcare.com/understanding-programmatic-platforms/