Do you consider Search Engine Optimisation (SEO) and Search Engine Marketing (SEM) as push technology? These are processes of optimising online content to improve the quality and quantity of traffic to a website or web page from search engines. Such a process in itself does not seek to encourage consumption of a particular service.
Search Engine Optimisation (SEO) and Search Engine Marketing (SEM) are not considered to be push technology under Regulation 6(4)(a) of the HCS (Advertisement) Regulations. However, the contents of the advertisement associated with the use of SEO / SEM must comply with the requirements under the HCS (Advertisement) Regulations.
As SEO (e.g. on-page, off-page, technical) serves to optimise online content to improve the quality and quantity of traffic to a website / webpage from search engines, SEO is not considered as “advertising” as the process itself does not seek to encourage the consumption of a healthcare service. However, if the SEO platform utilises patient reviews and ratings, then such information listed is considered as an advertisement and must comply with the HCS (Advertisement) Regulations.
The use of SEM is governed by the HCS (Advertisement) Regulations, as SEM involves paid advertising that increases a website’s visibility on search engines, which is akin to paying for advertising space for greater visibility.
Related questions
Do Healthcare Service (Advertisement) Regulations (HCS (Advertisement) Regulations) cover advertisements of non-licensable healthcare services (e.g. Traditional Chinese Medicine, physiotherapy, chiropractic)?
Are flyers and mailers from nearby clinics allowed? Are we allowed to distribute leaflets containing only the factual details of the licensee’s licensable healthcare service?
Are we allowed to advertise services on online shopping platforms?
Can we allow insurance companies to have a hyperlink to a licensee’s website, as part of their value-added service for their policy holders
