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CONTENTS
WHAT ARE THE ADVERTISING PLATFORMS COVERED UNDER THE ACT?
WHAT ARE THE SPECIFIC REQUIREMENTS FOR THE CONTENT OF ADVERTISEMENTS?
CAN ACCREDITATIONS, CERTIFICATES, OR AWARDS BE DISPLAYED?
WHAT IF MY TARGETED AUDIENCE IS OUT OF SINGAPORE
ARE YOU INTERESTED IN DIGITAL MARKETING WHICH COMPLIES WITH PHMC GUIDELINES?
PHMC compliance for clinics and aesthetics in Singapore | Cleverly

26 February 2024

IS YOUR DIGITAL MARKETING IN COMPLIANCE WITH PHMC GUIDELINES?

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What are the digital marketing guidelines of PHMC?

 Digital marketing and advertising are the go-to choices when it comes to the promotion of products and services. However, for those who fall under the Private Hospitals and Medical Clinic (PHMC) Act, there are several regulations that must be followed to avoid the risk of a fine, or in extreme cases, having their licences revoked.


WHAT ARE THE ADVERTISING PLATFORMS COVERED UNDER THE ACT?

Traditional printed media

 Platforms which are covered under this section include newspapers, journals, magazines, brochures, leaflets, and pamphlets. Licensees under the PHMC Act can pay for their ads to be displayed on these mediums, but advertisements which are not displayed in their premises can only appear in printed media. However, when it comes to pamphlets and brochures, you are not allowed to place them into mailboxes without the homeowner’s consent or have them available in newspaper deliveries.

 

Messaging services

 The usage of advertisement through messaging services such as push notifications on SMS, Facebook Messenger, and WhatsApp is prohibited unless you obtain prior written consent from the recipient.

Social media platforms

 Social media is a popular avenue of advertisement in Singapore, as they have millions of users, with each platform catering to a certain demographic. The PHMC Act does not prohibit the use of ads on social media, but licensees need to adhere to the regulations governing their content.

 

Search Engines

Push technology usually involves sending information directly to a user’s device, without them actively requesting it. For example, a notification popping up on your phone is a form of push technology.

SEO is about making sure a website shows up in search results when people look for certain things. SEM involves paid advertising to appear in search results. These are ways to make a website more visible when people are searching for related information.

The PHMC Act makes it clear that SEO and SEM do not fall under the category of “push technology”, providing you with the option to utilise these methods to boost organic traffic.

What are the exceptions to this?

If it is within your premises, you can use any type of medium when it comes to advertising. For example, you can hang a banner behind your front desk, or have TV screens showcasing your services on a private channel.

WHAT ARE THE SPECIFIC REQUIREMENTS FOR THE CONTENT OF ADVERTISEMENTS?

PHMC compliance specific requirements | Cleverly

Your advertisements must be factually accurate

 When creating healthcare advertisements, there should be sufficient evidence to support and validate the information presented. In other words, you should be able to prove the accuracy of claims made at the time of publication. Exaggeration of facts and figures may draw attention but can lead to fines and reputational damage.

This includes peer-reviewed journals as well as sources that are deemed acceptable by the medical or dental community. Keep in mind that the citations must be provided to the Ministry of Health upon request. Failure to provide the required evidence and information could be considered a violation of the regulation.

Your advertisement must not be offensive or in bad taste

 Shock advertising is where the boundaries of social values and acceptability are pushed. It is designed to catch the audience’s attention through the use of provocative, or controversial elements. Striking a balance between creativity and sensitivity is crucial when it comes to adhering to the PHMC Act.

To provide a clearer picture, advertisements should steer clear of any words, statements, images, or information that might be considered demeaning, provocative, distasteful, or indecent. This includes avoiding anything that could undermine the honour and dignity of the medical, dental, or nursing profession.

Your advertisement must not create unjustified expectations

 Standing out from the crowd is a want of every business in an industry, and you may want to consider doing so by promoting the results of your services. However, you will need to avoid creating advertisements which may give rise to unjustified expectations.

Examples provided in the PHMC Act include phrases such as, “immediate teeth whitening”, “straight teeth in 2 weeks”, and  “see results after 1 treatment session”. The reason for this restriction is that every individual is different and you are unable to guarantee that all will have the expected results within the same timeframe.

Your advertisement must not contain “before and after” images

 What’s a more convincing way to draw attention than providing photographs of the results that have been achieved? However, this move has been prohibited by the PHMC Act. An exception to this rule is during consultation, where health practitioners are allowed to show these images to clients provided that proper explanations are given on the expected results.

Your advertisements must not contain laudatory statements

 If your healthcare institution has received several awards or is well known in a certain medical field, it is common to want to promote them. However, it is important to maintain a professional tone without using exaggerated claims or laudatory statements. While the use of words such as “best”, “premium”, “internationally renowned“, and “leader in the industry”, will certainly attract readers, it is prohibited under the PHMC Act.

Your advertisements must not contain testimonials or endorsements

Patients, caregivers, or the public can freely give feedback, including testimonials or endorsements, directly to the healthcare institution. This can happen on-site, on the institution’s website, or social media. Most importantly, this feedback must be voluntary and not coerced.

If you are thinking of including them in your advertisements to attract customers, the Act disallows such actions to ensure that ads remain factual and unbiased. There are situations where testimonials and endorsements can be shared, but only under specific conditions:

  • Displayed within the healthcare institution’s premises or social media accounts.

  • Published in the healthcare institution’s corporate publications distributed only to its employees.

  • If the feedback is given directly to the institution and has not been altered.

The regulations emphasise that there should be no differentiation between testimonials or endorsements from a common person and those from celebrities. All endorsements are to be treated equally.

Your advertisements must not solicit or encourage the use of the HCI’s services

Promotional content actively encouraging or soliciting the public to utilise the services of a specific healthcare institution is prohibited. This includes offering discounts, gifts, or promotions in exchange for choosing a certain service. While this is a common tactic, institutions should focus on providing transparent and informative content that educates the public about their healthcare options without pressuring them into specific choices.

To better understand this regulation, specific examples are outlined in Sections 5.8.1 to 5.8.3. It states that advertisements should steer clear of “before-and-after” treatment photos and promises of instant results. They should also provide pricing information transparently, avoiding misleading phrases like “as low as” or “lowest prices.”

CAN ACCREDITATIONS, CERTIFICATES, OR AWARDS BE DISPLAYED?

PHMC compliance can accreditations and awards be displayed | Cleverly

Healthcare institutions are not allowed to boast about their awards in public spaces like newspapers or on TV. However, there are exceptions. They can talk about their accomplishments within the hospital or clinic and on their official website and social media pages. 

Even within the allowed spaces (like their physical location or online platforms), healthcare institutions must be truthful. They can’t exaggerate, lie, mislead, or deceive in any way when talking about their awards, certifications, or accreditations.

It’s important to note that the rules don’t cover the professional qualifications of individual healthcare professionals working in the institution. For example, a doctor’s certificates or qualifications are separate and not restricted.

WHAT IF MY TARGETED AUDIENCE IS OUT OF SINGAPORE

Healthcare institutions licensed in Singapore have the freedom to advertise their services in any country outside Singapore. In such cases, regulations 4 to 14, which cover various aspects of healthcare advertising, do not apply.

 

An advertisement is considered “published” in the country where people are expected to see or access it. If an ad is seen in a country by chance, without it being intended for them, it doesn’t count as being published there.

 

It is important to note that if an advertisement is spread through mass media (like TV or radio) and can be seen by people in Singapore and other countries, the PHMC Act applies. However, if healthcare institutions can prove that the ad is specifically meant for people outside Singapore, they are exempt from the usual regulations. 

 

Interested with PHMC guidelines compliance | Cleverly

ARE YOU INTERESTED IN DIGITAL MARKETING WHICH COMPLIES WITH PHMC GUIDELINES?

Healthcare institutions under the PHMC Act must tread carefully when it comes to compliance with regulations. Through this article, we hoped to shed some light on what the guidelines entail. If you are still unsure whether your advertisements are in accordance with the Act, contact us to receive some help!