Consent, recording, questions, adverse events and captions
In health, a webinar is a recorded, transcribed, shareable conversation between a company, its experts and the people who prescribe, dispense or take medicines. Every rule that applies in a meeting room applies here, plus a few that only exist because of the record button.
The Adelo teamAdelo Guides
Published 3 November 2026
The rules by region, a question triage and a checklist
Across the pharma and agency teams who run sessions on Adelo, the pattern we see most often is this: a team plans a good session, the compliance review arrives late, and half the plan gets cut. Running fewer webinars doesn't solve that. Building the rules in from the first week does, because compliance then shapes the plan instead of cutting it.
This guide is a map of the rules and isn't legal advice. Your medical, legal and compliance colleagues own the decisions. What follows is what we would put in front of them, with the primary sources, so the conversation starts from the right place.
1
Know which rules apply to your webinar
The rules depend on who you are, where your audience is and what you talk about. For a pharmaceutical company in the UK, the 2024 ABPI Code covers events, including virtual ones. Its supplementary information on meetings even suggests using technology such as webinars to avoid travel outside the UK.1 The same Code requires promotional material to be certified before use, and says staff must be fully conversant with the pharmacovigilance requirements relevant to their work.1
Where
What governs the webinar
What it mostly affects
UK
2024 ABPI Code (PMCPA); UK GDPR and the ICO
Events and hospitality, certification, privacy notices
EU
EMA good pharmacovigilance practices; GDPR
Adverse event capture and reporting, privacy
US
PhRMA Code; FDA guidance; HIPAA
Speaker programs, off-label questions, patient data
Everywhere
WCAG 2 success criterion 1.2.4
Live captions
Fig. 1The map
Twelve compliance checks across three phases
Adelo Guides · based on the checklist in this article
2
Not pharma? What applies to consumer health
Most of what follows was written for pharmaceutical companies, because that is where the rules are tightest. But consumer health companies run expert webinars too, and the question we are asked most is whether any of this applies. More of it applies than most people expect, and how much depends on what you sell.
If you sell
For example
What applies to your webinars
Prescription medicines
Pharma companies
Everything in this guide
Licensed pharmacy or OTC medicines
A company like Maxwellia, which switches prescription medicines to pharmacy
Medicines advertising rules, and adverse event reporting in full
Wearables, apps and devices
A company like WHOOP
Health claims, the line between wellness and medical device, privacy
Supplements and foods
Wellness and nutrition brands
Authorized health claims only, and the evidence behind them
If you hold a license for a medicine
A pharmacy medicine is still a medicine. In the UK, advertising of over-the-counter medicines is governed by the Human Medicines Regulations, the MHRA's Blue Guide and the PAGB's Consumer and Professional Codes, rather than the ABPI Code, and consumer materials from PAGB members are submitted for approval before they run.9 Pharmacovigilance is not optional either: the obligations in section 7 attach to the marketing authorization, not to whether the medicine needs a prescription. If someone in your webinar chat says the product gave them a rash, that is a report.
If you sell a wearable, an app or a supplement
You probably have no adverse event reporting duty for a medicine, but the claims rules are real and getting sharper. In July 2025 the FDA sent WHOOP a warning letter saying its Blood Pressure Insights feature was a medical device because estimating blood pressure is closely tied to diagnosing high or low blood pressure; the letter states that blood pressure estimation "is not a low-risk function."10 In the US, the FTC expects health claims to be backed by competent and reliable scientific evidence and can hold expert endorsers liable alongside the brand.11 In the UK, food and supplement brands can only use health claims authorized on the GB register.12
Brief your expert on what the product is cleared or evidenced to do, and what it isn't.
Treat "is this a diagnosis?" as a held question, answered carefully and in writing after the session.
Keep recording, privacy and captions exactly as tight as pharma. Those rules apply to everyone.
3
Tell people what you're doing with their data
Registration is where personal data enters the system. Under UK GDPR's right to be informed, the ICO lists what people must be told, including who you are, the purposes of the processing, the lawful basis, who receives the data, how long you keep it and the rights they have.2 Put a short, plain-language version on the registration page and link to the full notice.
Say who is really collecting the data. If an agency runs the event for a sponsor, name the sponsor.
Say what the recording is for and who sees it. Internal training, on-demand publication and sharing with a sponsor are different purposes.
Say how long you'll keep it, then keep to it.
Ask only for the fields you'll use. Every extra field is more data to protect and fewer sign-ups.
4
Get a clear choice about recording before anyone joins
People need to know they're being recorded before the recording starts. A line of small print after the session is too late. The cleanest way is a gate: a short notice that states what is recorded and who will see it, with a real choice. Whether you rely on consent or another lawful basis is a decision for your privacy team. Either way, the notice goes first.
Say what is recorded and who sees it, in plain words, in one paragraph, before anyone joins.
Make agreeing a real choice. A decline option that works: if someone declines, they don't join.
Keep the record. Who agreed, and when, sits with the attendance data.
Speakers and panelists too
Your experts are being recorded as well. Put recording, on-demand publication and any clips you plan to cut in the speaker agreement, and tell them before the session where the recording will live.
5
De-identify every patient case
Clinical education runs on cases, and cases are where patient data leaks. The US HIPAA Privacy Rule offers the clearest checklist. Its Safe Harbor method lists 18 identifiers that have to be removed, including names, all dates other than the year, medical record numbers and full-face photographs or comparable images.3 Outside the US the lists are different, but the principle holds: if a colleague, a relative or the patient could recognize the case, it isn't de-identified.
Strip dates to the year. An admission date plus a rare condition can identify someone.
Crop or replace images. Faces, tattoos, and anything with a name or number on it.
Check the slides and the speaker's notes, because both are recorded.
Ask your speaker to confirm in writing that any case they present is de-identified or consented.
6
Triage every question before the audience sees it
Live questions are the most valuable part of a health webinar and the riskiest. Three kinds arrive, and each needs a different route.
Fig. 2Question triage
Answer, hold or capture
Adelo Guides · routes based on FDA draft guidance and EMA GVP Module VI
Questions about unlicensed uses
FDA's draft guidance on unsolicited requests for off-label information draws a line between private and public requests. A question asked in a public forum, such as a live presentation, should get a public reply that is limited to the company's contact information and includes no off-label information. The detailed answer goes to the person who asked, one to one.4 The guidance also recommends that responses come from medical or scientific staff, with sales and marketing having no input on the content.4
The moderator reads every question before the audience does.
Adelo Guides · 04
7
Treat chat and Q&A as a place adverse events arrive
In the EU, good pharmacovigilance practice is explicit. Marketing authorization holders should regularly screen the internet or digital media under their management or responsibility for potential reports of suspected adverse reactions.5 A webinar you run, with its chat, Q&A, polls and recording, is digital media under your management.
The same guideline sets out what makes a report valid: an identifiable reporter, a single identifiable patient, a suspected medicine and a suspected reaction.5 Once that minimum information reaches the company, the clock starts, and serious cases must be submitted within 15 calendar days of receipt.5
Fig. 3A valid report
The four details that make a valid report
EMA, Guideline on good pharmacovigilance practices, Module VI (Rev 2)
Brief the moderator and producer on what an adverse event looks like. In chat it often reads as a casual aside.
Capture, don't debate. Thank the person, take the four details, and move on.
Send it the same day. Your pharmacovigilance team needs every day of the 15.
Review the transcript afterwards. The recording is part of the media you manage.
15days
to submit a serious adverse reaction report in the EU
4
details that make a report valid
18
identifiers to remove under HIPAA Safe Harbor
AA
the WCAG level that asks for live captions
8
Keep speakers, hospitality and audiences within the codes
A webinar removes most of the hospitality questions that come with a dinner meeting, but not the principles behind them. The PhRMA Code, as revised from January 2022,6 is clear that companies should not pay for or provide alcohol at speaker programs, that any meal should be modest and incidental to the education, that attendees should have a bona fide educational need, that repeat attendance at substantially similar programs is not appropriate, and that significant others and guests are not.7 Speakers are paid fair market value for their time, and never in a way that reflects past or future prescribing.7
In the UK, Clause 10 of the ABPI Code does the same job for events and hospitality.1 For a webinar, the questions that remain are simpler: is the content certified, is the speaker contracted properly, and is the audience the right one?
9
Caption it live, then correct it
Success criterion 1.2.4 of the Web Content Accessibility Guidelines, at level AA, states that captions are provided for all live audio content in synchronized media.8 Live captions also help the many people watching on a phone in a noisy place. Book them, then correct the transcript before the on-demand version goes out. Automatic captions are unreliable with drug names and dosing, which is exactly where accuracy matters most.
10
Make compliance a workflow, with AI doing the first read
Everything above can be done by hand, with a moderator, a spreadsheet and a good memory. Most teams start that way, and it stops working once the program grows. A program of twenty sessions produces thousands of questions and chat messages and hours of transcript, and every one of them is something your medical, legal and pharmacovigilance teams may need to see.
A better approach is to make compliance a workflow with three stages, and let AI do the first read so people can make the decisions.
Stage
What happens
What to ask of your platform
Prepare
Consent, access and the information people must see before they join
Consent shown before entry, recorded with a timestamp and linked to the session
Manage
Questions and chat reviewed before the audience sees them; anything concerning flagged live
Moderation before display, and a one-click flag for hosts and speakers
Review
Recordings, transcripts and flags checked afterwards; decisions recorded
AI that flags potential adverse events and off-label mentions for human review, an audit trail and a full export
Three things make the difference in practice. First, set alert rules before the session, such as off-label discussion of your product or mentions of specific terms, so every processed session is checked against them automatically. Second, make every flag point back to the exact moment in the session, so a reviewer can watch the ten seconds that matter instead of the whole hour. Third, keep the decision with people: AI should sort and surface, and your medical, legal, regulatory and pharmacovigilance teams should decide.
Close the loop after the session
Some obligations continue after the session ends. Within a day, review the transcript and chat for anything that should have been captured. Edit the recording before you publish it on demand: remove any off-label discussion that slipped through and anything that identifies a patient. In the UK, an on-demand recording of promotional content is material that needs certification like any other. Then keep the data for as long as your notice said, and no longer.
Compliant webinar checklistAdelo Guides · 04 · Tick as you go
Before
During
After
None of this should slow a good session down. Build it into the plan from week one, as set out in our guide to running a webinar, and your experts can concentrate on the thing clinicians actually came for. For the other half of the problem, read how to get healthcare professionals to attend.
Frequently asked questions
Does webinar compliance apply to consumer health companies?
Yes, in part. Companies with licensed pharmacy or OTC medicines have medicines advertising rules and full adverse event reporting duties. Wearable, app and supplement brands usually have no medicine reporting duty, but health claims rules from the FTC, FDA, ASA and others apply, and an expert on camera can make a claim on your behalf.
What should a compliant webinar platform for pharma include?
Consent recorded with a timestamp before anyone joins, moderation of questions and chat before the audience sees them, a way for hosts to flag a contribution live, AI that flags potential adverse events and off-label mentions for human review, an append-only audit trail, a transcript and recording for every session, and an export of the full record for regulatory review.
Do you need consent to record a webinar?
You must tell people before the recording starts what is recorded, who will see it and for how long. Whether you rely on consent or another lawful basis is a decision for your privacy team, but a clear notice before anyone joins, with a real choice to leave, is the safest practice.
What should you do if someone reports a side effect during a webinar?
Capture it, do not debate it. Note who reported it, the patient details given, the medicine and the reaction, and pass it to pharmacovigilance the same day. In the EU, a company should regularly screen digital media it manages for such reports, and serious cases must be submitted within 15 calendar days.
Can a speaker answer an off-label question on a webinar?
Not in front of the audience. FDA draft guidance says a public reply should be limited to the company's medical information contact details. The detailed answer goes one to one, from medical or scientific staff, with no input from sales or marketing.
Do webinars need captions?
WCAG success criterion 1.2.4, at level AA, asks for captions on all live audio content in synchronized media. Book live captions, then correct the transcript before you publish the recording.
Can you show patient cases on a webinar?
Yes, if they are properly de-identified. Under the HIPAA Safe Harbor method, 18 identifiers have to go, including names, dates other than the year and full-face photographs. Outside the US the lists differ, but the principle is the same.
Adelo Guides are written by the Adelo team, the professional video event platform for health. They draw on the sessions pharma, agency and consumer health teams run on Adelo every week, and on the research cited in each guide.
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