Seyed Mahdi Taheri - Associate Professor, Department of Knowledge and Information Science, Allameh Tabataba’i University, Tehran, Iran
Negin Shokrzadeh Hashtroudi - Ph.D. student, Department of Information Science, Alzahra University, Tehran, Iran.

The purpose of this study was to investigate the of metadata elements of Digital Rights Management (DRM) comparatively in different regions and the approach behind. This research was conducted using qualitative content analysis method. The data was gathered through documentary method and searching in databases to identify the best practices of DRM solutions. The results revealed that Different metadata elements are utilized in the DRM projects. These metadata elements are practical in different stages of content trading and greatly depends on the technology, law, and business models. As stated before, Digital Rights Management (DRM) is an important tool for digital contents. This tool is implemented in various countries and regions. The United States is known for its strong intellectual property laws. DRM in the United States is mostly based around the Digital Millennium Copyright Act (DMCA). Canada, takes a more balanced approach to DRM systems which reflects Canada's commitment to promoting access to information while protecting intellectual property rights. In contrast, the UK Copyright, Designs, and Patents Act of ۱۹۸۸ suggests that it differs significantly with regard to DRM and a more flexible approach is considered in digital rights management.This law gives the owners of the rights of copying works control over them, yet it contains some exceptions like research, private study, and criticism. British government has also taken measures to promote the use of DRM technologies, for example, the Creative Content Online initiative that promotes legal distribution of digital content. In France the DRM projects are France comply with the French Intellectual Property Code (Code de la Propriété Intellectuelle) and consider Commission Nationale de l'Informatique et des Libertés – CNIL. The main components of DRM solutions in the France are data protection, privacy concerns, permissions, managing user data, usage rights, and etc. Germany has a similar approach to DRM as France. In Germany the implications of the German Data Protection Act (BDSG) is considered when managing user data through DRM solutions. The DRM solutions of this country implement strong access controls and techniques to protect content rights. based on legal frameworks, cultural norms, and infrastructures there is significant differences in approaches to the protection of digital content and this affect the selection of right metadata components in the DRM systems. When it comes to copyright, the US tends to be more pro-owner, while the UK prefers a balanced perspective that includes user activities. France and Germany have adopted strict measures in this respect, having legal provisions for sanctioning offenders. Switzerland has a more relaxed approach to DRM systems, while Australia, China, and Russia have a complex legal framework for legal protection, access controls, permissions of copyrighted content. Rights metadata have various functionalities such as Identifying and describing the content, to manage secure content distribution, access control, content protection, and usage tracking, monitoring changes, facilitate discoverability, within DRM systems the extent to which they protected content remains secure and accessible only to authorized users. In conclusion, it could be said that based on context-based approaches, cultural norms, and infrastructures there is significant differences in approaches to the protection of digital content and this affect the types and functionalities of right metadata elements in the DRM systems.

Keywords: Digital Rights Management, DRM, Rights metadata, metadata functions