There has been a lot of discourse around VPPA in current months regarding the legality of tracking user's watch history in digital format and sharing or selling that information without consent. To comply with the Video Privacy Protection Act (VPPA), here are some key steps to follow:
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Obtain Consent: Before disclosing an individual's video viewing information, obtain their informed and voluntary consent. This consent can be obtained through written, electronic, or oral means.
CMP Best Practices
Use Osano Cookie Consent Manager to obtain explicit consent for the above functionality. Ex. If using the Meta Pixel, obtain explicit consent by classifying the pixel appropriately and disclosing the purpose for use.
Allow for ease of opting out by providing links to change cookie preferences throughout the customer journey as well as whenever sensitive or video viewing information might be collected.
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Provide Clear Notice: Inform individuals about their rights and the types of information that will be disclosed. Clearly state the purpose of the information disclosure and provide an easy way for individuals to revoke their consent at any time.
Disclose within your Cookie Consent Manager which trackers you are using for this purpose and why AND be sure to clearly lay these out in your privacy policy or cookie notices documentation.
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Limit Information Disclosure: Only disclose video viewing information that is necessary for the intended purpose and only to authorized parties. Avoid unnecessary sharing of personal information.
Where possible, limit your tracking of video viewing content to only what is necessary for your business (ex. YouTube Privacy Enhanced mode)