The nation's largest pay TV provider operates across a complex portfolio of satellite, streaming, and IPTV properties. Millions of subscriber records. Multiple billing systems. Distinct technology stacks that evolved independently over years of acquisitions and platform expansion. The privacy team had OneTrust in place, but the implementation was not keeping pace with where the industry was heading.
State privacy regulations were multiplying. The Global Privacy Platform (GPP) was becoming the new standard for signal-based consent. And the organization's existing consent architecture, built around a single customer identifier, could not support the unified view of subscriber preferences that regulators and customers increasingly expected.
FLLR was engaged to architect a privacy infrastructure that could connect across systems, scale across properties, and adapt to regulatory frameworks still being finalized. This was a multi-workstream engagement spanning system integrations, identity architecture, and GPP signal compliance, with ongoing work to position the organization for continued evolution.
The Challenge
The organization's privacy infrastructure had reached an inflection point where incremental improvements would no longer suffice.
Disconnected Core Systems
- Consent preferences lived in OneTrust but were not connected to the downstream systems that needed to act on them
- Five core platforms (CDO, Video Service, OM, Evergent, and others) operated independently, each with its own view of the customer
- Changes to consent in one system had no reliable path to propagate to the others, creating gaps between what customers requested and what actually happened
Single-Identity Limitations
- The existing consent framework relied on a single identifier (BAN, the billing account number) to link preferences to customers
- Customers interacting via phone or email had no clear way to connect those touchpoints to their consent record
- The privacy team lacked a unified view of preferences across the multiple ways subscribers engaged with the brand
Emerging GPP Requirements
- State privacy laws were evolving toward signal-based consent mechanisms that the current implementation could not support
- GPP compliance required geolocation-aware rules and organizational purpose mapping that had not been configured
- The USNAT framework was live, with USNatV2 on the horizon, and the organization needed to be ready for both
The Bottom Line
- Without connected systems, expanded identity resolution, and GPP readiness, the organization faced mounting regulatory exposure across its largest subscriber base
- The complexity of the technical environment meant this work required careful design, not just configuration
Our Approach
We approached this engagement as three interconnected workstreams, each with its own deliverables but designed to function as a unified privacy architecture.
The guiding principle was interoperability. OneTrust had to become the system of record for consent, but that only mattered if every downstream system could receive and act on that information in real time. Design sessions were held onsite with the technical teams responsible for each platform, mapping data flows and identifying the integration patterns that would actually work in production.
For linked identities, the work centered on expanding how the organization thought about customer resolution. A billing account number is one way to identify a subscriber. Phone numbers and email addresses are others. Building a multi-identity framework meant the privacy team could finally see a complete picture of subscriber preferences, regardless of how those preferences were expressed.
For GPP, we worked closely with the compliance team to map organizational purposes to the framework's requirements, configure geolocation rules aligned with USNAT, and prepare the architecture for USNatV2 once OneTrust published the updated regulatory framework. This was forward-looking work, designed to position the organization ahead of where regulations were heading rather than scrambling to catch up.
Implementation
Bi-Directional System Integrations
We designed and configured integrations between OneTrust and five core systems, enabling consent preferences to flow in both directions. Each integration required its own functional and technical design, accounting for the unique data structures and API behaviors of each platform. Workflows were built and tested in UAT environments, with production connections staged for final validation once test data was available. The result is a consent infrastructure where OneTrust serves as the authoritative source, and downstream systems receive updates in real time.
Linked Identities Framework Expansion
The existing single-identifier model was expanded to support multiple identifiers per customer. Working with the client's technical team, we modified the integration workflows to accept BAN, phone number, and email as linked identities within OneTrust. This means a subscriber who opts out via a call center interaction now has that preference reflected across their entire relationship with the brand, regardless of which identifier was used at the point of contact.
GPP Signal Activation
GPP signal processing was activated in OneTrust with USNAT geolocation rules configured to ensure compliance with state-specific requirements. We built the organizational purpose mapping table, aligning internal data collection categories with GPP's standardized purposes. Testing procedures were developed and validated in UAT, confirming that signals were being processed correctly. The architecture was designed with USNatV2 in mind, so the transition to the updated framework will require configuration updates rather than a fundamental redesign.
Functional and Technical Documentation
Each workstream produced its own functional and technical design documents, capturing the integration architecture, configuration decisions, and operational requirements. These deliverables ensure the client team can maintain and extend the implementation independently. Knowledge transfer sessions were conducted to walk through the documentation and answer questions from the teams who will own the systems going forward.
Multi-Identity Preference Center (In Progress)
Design work is currently underway for a Multi-Identity Preference Center that will give subscribers a unified view of their consent choices across all linked identifiers. This positions the organization to offer a modern, customer-friendly preference experience that reflects the reality of how people interact with the brand across channels.
Results
System Connectivity
- Before: Consent siloed in OneTrust with no downstream propagation
- After: Bi-directional integrations with five core systems enabling real-time consent updates
Identity Resolution
- Before: Single identifier (BAN) limiting unified preference visibility
- After: Multi-identifier framework supporting BAN, phone, and email linkage
GPP Readiness
- Before: No signal-based consent capability
- After: USNAT geolocation rules configured with organizational purpose mapping
Regulatory Positioning
- Before: Reactive posture toward emerging state requirements
- After: Architecture designed for USNatV2 readiness as frameworks evolve
Operational Knowledge
- Before: Configuration knowledge held by implementation team
- After: Comprehensive documentation and knowledge transfer for long-term self-sufficiency
Subscriber Experience
- Before: Fragmented preference management across touchpoints
- After: Foundation in place for unified Multi-Identity Preference Center
The technical complexity of this engagement was significant. Five system integrations, each with distinct API patterns. An identity model expansion that touched core data architecture. Regulatory requirements that were still being finalized as the work progressed. The organization now has a privacy infrastructure that matches the scale and complexity of its business.
The Bigger Picture
By connecting OneTrust to the core systems that power subscriber relationships, expanding identity resolution beyond a single identifier, and configuring GPP compliance before regulatory deadlines forced the issue, this organization moved from a fragmented consent posture to a unified privacy infrastructure capable of scaling with the business.
If your organization operates across multiple platforms with distinct customer data systems, and your privacy team is spending more time reconciling consent across systems than actually managing it, the path forward requires integration architecture designed for how your business actually works. If this sounds familiar, our team is ready to help.
