DCU FuJo and the UCD Centre for Digital Policy have made a joint submission to the Public Consultation on the draft delegated act (article 40) on access to online platform data for vetted researchers under the Digital Services Act (DSA).
Article 40
With the Digital Services Act, researchers will for the first time have access to data to study systemic risks and to assess online platforms’ risk mitigation measures in the EU. It will allow the research community to play a vital role in scrutinising and safeguarding the online environment.
The draft delegated act clarifies the procedures on how researchers can access Very Large Operating Platforms’ and Search Engines’ data. It also sets out rules on data formats and data documentation requirements. Lastly, it establishes the DSA data access portal, a one-stop-shop for researchers, data providers, and DSCs to exchange information on data access requests.
The UCD-DCU submission
Overall, our submission recommends:
- The inclusion of specific examples of shared datasets and access modalities relevant to systemic risks.
- A dataset categorization system to streamline safeguards and access modalities for each category, facilitating collaboration between researchers and DSCs.
- Standardization of data-sharing agreements (e.g., data access and non-disclosure agreements) to reduce negotiation complexities and enhance efficiency.
- Enhancing the documentation of data inventories to ensure comprehensive listings.
- Creating clearer processes for mediation, including enabling researchers to initiate it.
Specific recommendations include:
- Recital 2: Broaden the scope of accessible platform data to include societal research beyond the effectiveness of the DSA.
- Recital 9: Clarify criteria for independence of researchers funded by platforms.
- Recital 13: Include user consent requests as access modalities for highly sensitive private data.
- Articles 6, 9, 10: Improve data inventory transparency and streamline procedures for dataset updates and extensions.
- Article 7: Allow flexibility in the 21-day review timeline for DSCs during the initial implementation phase.
- Article 14: Establish a transparent body of independent experts with clear roles to advise on systemic risk research.
