498 - As a follow-up to Question 299, we would like to ask if it is acceptable to still post such a video on YouTube but make it an unlisted video.... only found when pharmacist's share the URL with a patient who need to learn how to use the product . Thank you for your help !



  • Let’s step back from YouTube specifically for a moment. For a URL to essentially be used as the password confirming that someone is a patient, BOTH of the following conditions need to be met:The only way to access the content is by entering the URL.There are controls on distribution of the URL to ensure that having the URL is a reliable differentiator between “patients” and “consumers”.If you are not confident about either (or both) of these, there is a good chance that Food & Drug Regulations C.01.044 will be contravened (perhaps inadvertently).What’s important here is the outcome (i.e. that the two conditions listed above are met), NOT the process (i.e. “I selected the unlisted broadcast option”). This is because “unlisted” means different things on different social platforms. Additionally, even within a given platform, you can often modulate aspects like ability for users to share the video with broader circles of contacts or even the ability to embed the video on any website and/or blog thus opening the video to the world. Okay, back to YouTube. For everyone’s benefit, at the time of responding to this question there are three different broadcast options for YouTube: Public: Anyone can discover and watch the video as it will come up in search results on YouTube and on Google. Private: Only users affiliated with a YouTube account which you’ve invited can view the video. There is currently a limit on the number of accounts you can authorize to view the video. Unlisted: You can think of this as being somewhere between Public and Private. The user needs the video URL to view the video (but anyone with that URL can view the video). You Tube is designed to make the sharing of videos between users and the embedding of videos into open websites/blogs extremely easy. I do not know whether there is currently a reliable way to ensure that both above requirements are met except in the context of the “Private” broadcasting option (which may not be practical due to the imposed maximum on the number of invites). Let me know if there are ways to meet the above requirements and I’ll update this answer accordingly. Some caution is warranted as there have been instances of “unlisted” videos going viral.


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