Navigating Pharmaceutical Targeting in a Regulated Landscape

Pharmaceutical targeting is a powerful tool in digital advertising, but it’s also one of the most heavily scrutinized. Marketers in the healthcare space must strike a careful balance between relevance and responsibility. That means understanding how regulations like HIPAA and industry codes shape what’s possible.

If you’re unsure what’s compliant when using health data in campaigns, or how to guide your clients through the grey areas, this article is for you.

Who Makes the Rules?

Let’s start with the basics. The Health Insurance Portability and Accountability Act (HIPAA), enacted in 1996, was designed to protect patient health information. But HIPAA doesn’t cover every marketing scenario, and when it comes to digital advertising, the lines get blurry.

That’s where self-regulatory organizations step in. Bodies like the National Advertising Initiative (NAI), Interactive Advertising Bureau (IAB), and Digital Advertising Alliance (DAA) provide frameworks to help advertisers navigate ethically and legally. Among these, the NAI is especially influential for pharmaceutical marketers.

Founded in 2000, the NAI established a code of conduct, updated regularly and supported by the FTC, that outlines how advertisers should manage user data. Recent updates include definitions for “Sensitive Health Information,” giving pharmaceutical advertisers more specific guidance.

Understanding Sensitive Health Information

The NAI classifies sensitive health data in two ways:

1. Data derived from a sensitive source (e.g., electronic health records)
   
2. Data related to certain conditions, regardless of how it’s collected
   

Examples of sensitive conditions include:

• Mental health
• Drug addiction
• STDs
• Pregnancy termination
• Cancer
• Pediatric conditions not treated by over-the-counter medications
  

However, the NAI doesn’t offer a comprehensive list. That’s why internal alignment between agency and client is crucial. At Coegi, we recommend using available guidance as a conversation starter, not a final verdict.

Discussing the brand’s condition category up front helps ensure both compliance and strategic clarity throughout the campaign.

Platform-Specific Compliance Standards

Even if a campaign passes the NAI test, it must still meet the standards of individual ad platforms.

For instance:

• The Trade Desk, an NAI member, uses a multi-factor process to categorize conditions as high, medium, or low sensitivity.
  
• Meta (Facebook) requires advertisers to apply for special permissions when promoting prescription drugs or targeting health-related audiences.
  

Every platform has nuances. Partnering with teams who understand these policies, and vet their data sources accordingly, is essential.

Tactics for Compliant Pharmaceutical Targeting

Once you’ve classified a condition as sensitive or non-sensitive, you can evaluate which targeting strategies are appropriate. Here’s how to approach both consumer and provider targeting while staying compliant.

Consumer Targeting Strategies

Behavioral Targeting

Generally, this is not compliant for sensitive conditions, unless the data is de-identified and verified. Some third-party data providers offer NAI-compliant audience segments, but it’s critical to assess how that data is collected and modeled.

Questions to ask:

• Is the seed data sourced ethically?
• What modeling attributes are applied?
• How strong is the match rate between input and output?

If you’re unsure, conduct a third-party audit or consult with your agency partner.

Contextual Targeting

Contextual ads, served based on page content, are widely accepted for reaching patient and caregiver audiences. There are currently no restrictions on this method, making it one of the most compliance-friendly options.

Geotargeting

Using precise location data (like visits to a specific doctor’s office) requires opt-in consent under the NAI code. Broader geographic targeting may be acceptable but still needs to be vetted to avoid inadvertently crossing into sensitive territory.

Retargeting

For sensitive health segments, retargeting is only permitted with explicit opt-in. Even for non-sensitive conditions, it’s wise to align with the client beforehand. Missteps here can erode trust and compliance.

Healthcare Provider (HCP) Targeting

Since you’re targeting based on profession, HCP campaigns have fewer restrictions. These methods can be executed compliantly:

• Dx Targeting: Reach providers by diagnosis code (ICD-10)
  
• Rx Targeting: Target by prescription behavior
  
• Specialty Targeting: Narrow your audience by medical specialty
  
• List Match Targeting: Use National Provider Identifier (NPI) lists for 1:1 targeting
  

Even here, due diligence matters. Data sources should be verified for quality and accuracy. Coegi recommends having open conversations with brand teams before executing HCP campaigns, especially when retargeting is involved.

Align Early, Execute Confidently

Pharmaceutical targeting doesn’t need to feel like a compliance minefield. The key is early alignment, transparent processes, and a firm understanding of evolving best practices.

Here’s how to keep your strategy on track:

• Understand the sensitivity classification of your brand
  
• Choose compliant targeting tactics based on that classification
  
• Vet third-party data thoroughly
  
• Stay up to date with platform-specific policies
  
• Maintain open communication with clients at every stage
  

Following these steps can help you deliver high-performing campaigns that don’t compromise on ethics or compliance.

Looking for more guidance on healthcare media strategy? Explore our white paper on pharmaceutical and healthcare marketing best practices or check out these related insights from the Coegi team:

• How AI is Transforming Contextual Targeting
• HIPAA Compliant Healthcare Marketing and Ad Targeting