Your assessment is correct in that help-seeking messages, which are reviewed as DTC information, cannot be linked to DTC branded advertising as this would render all content subject to advertising regulations. The key here is understanding how linkages are created. To assess this we consider a number of factors, including:
- appearance (e.g. using branding colours or images)
- proximity (e.g. side by side presentation)
- sequence (e.g. a rep presenting unbranded disease information followed by branded product information)
- context (e.g. positioning a branded consumer banner ad on an unbranded disease information website)
If any of these factors would create a link between the two campaigns, such as concurrent airing/viewing of the messages, it would violate the regulations.