Commentary

Trust Me, You'll Want to Ask These 5 Privacy Questions About Your TV Data

It’s certainly not 2014 anymore. We’re living in a time when just four years ago can feel like, “back then.” And, back then, our understanding of TV data was still in its infancy. TV data is now more widely available than ever before, but we’re learning that not all TV data is created equal. For instance, there are quality differences in accuracy, timeliness, breadth, and depth of the data. Set-top box-based (STB) TV data is generally more accurate than Automatic Content Recognition (ACR)-based TV data (due to false positives with concurrent broadcasts or advertisements). ACR-based TV data is typically timelier than STB-based TV data (near real-time versus typically next day). STB-based TV data has better breadth (more local market channels) and depth (more accurate DVR-playback and potentially Video-on-Demand data).

The most important thing to understand about your licensed TV data in today’s world is privacy.

Some companies – such as TiVo -- take privacy very seriously, but that’s not always the case with other providers. Therefore, I thought it would be helpful to provide you with five questions you should be asking your TV data partners. If they can’t answer these simple questions (and prove it), it might be time to find a new partner altogether. 

#1 - “What does the consumer know about how their viewership data is being used and shared by the data partner I hired?”

Ask your TV data provider what the viewer knows about the data being collected. Whatever device or software is collecting the subscribers’ behavioral viewership data should plainly disclose via an EULA (End User License Agreement) or Privacy Statement that:

  1. the viewership data is being collected
  2. being shared with non-affiliated third-parties
  3. the collection software may have nothing to do with the service being provided. 

Make sure your data provider can prove this with screen shots or actual documents. Don’t cut corners here. 

#2 - “What choices does the consumer have to opt out?”

Ask your TV data provider if viewers are able to exclude themselves, or opt out, from the dataset. As part of the EULA or Privacy Statement disclosure mentioned above, the viewer should be able to easily opt out of having their data shared with non-affiliated third parties that do not use the data to provide the service to the subscriber. Instructions on how to do this should be easy to access, easy to follow, and simple to execute. Best practices include email opt-out, phone call opt-out, and --in rare cases-- mail-in opt-out. Again, make your data provider prove this with screen shots, flow diagrams, or actual documents from all of their device or software platforms. Dig in here, don’t get buried. 

#3 – “How is the data being collected?”

Know your partners’ collection methods. Is it through the primary software on the device, or is it through secondary software on the device? Is it through a separate device entirely? The best answer is through the primary software on the device that is delivering the core service to the customer.  It that’s not the case, then questions #1 and #2 are going to be much harder to prove.

#4 – “Are you attaching an IP address to TV data?”

Ask your TV data provider if they are co-mingling IP addresses with TV data. IP addresses are a personally identifiable information (PII) gray area. Though IP addresses are not currently considered PII, this could change anytime, making your dataset unusable. Make sure your data partner is prepared for the long haul – you don’t want to be caught half-way through a campaign without a dataset. 

#5 – “What is your opinion on VPPA?” 

Ask your TV data provider if they know what VPPA (Video Privacy Protection Act) is – especially if they are ACR-based TV viewership data sources or a company claiming to provide OTT / non-linear data. If they respond with “what’s VPPA?” – run. VPPA is a law that could have a significant impact on how video-on-demand viewership data is lawfully collected and distributed. If your TV data provider doesn’t have a defendable stance on VPPA, you know you’re dealing with an amateur data source. Best to look elsewhere.

 For those who love to know the right answers to a quiz, here are the best answers to the previous five questions:

 #1 – “Lots. Here’s the evidence.”

#2 – “Here’s how to completely opt out”

#3 – “The software that collects the viewership data is the same software that enables the viewership.”

#4 – “No.”

#5 – I’ll leave this as a cliffhanger for another article…

 As always, the more you know, the better. Don’t be afraid to ask.

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