ISD provides feedback to the EU Commission on data access for researchers under the Digital Services Act


As a research-driven organisation, ISD believes that meaningful access to social media data for public interest research must serve as the foundation of any evidence-based digital policy initiative that aims to create a safer and more open online environment. However, the relationship between tech companies, governments, researchers and the public remains defined by an information asymmetry due to a lack of sufficient data access regimes and infrastructure. We believe that emerging data access regimes in the EU (and beyond) should help to overcome this asymmetry. Ahead of the Digital Services Act (DSA) implementation on designated social media platforms and search engines, the European Commission (EC) held a public consultation period (25 April 2023 through 31 May 2023) on data access under the DSA “in order to provide details in secondary legislation.” ISD’s submitted feedback, shaped by discussions with key government and regulatory stakeholders in ISD’s Digital Policy Lab network, outlining our key recommendations for the EC as they finalise the delegated act that will determine how Article 40 of the DSA is implemented, and ultimately whether it proves effective.

ISD also collaborated with the Mozilla Foundation and other civil society experts in crafting a joint statement that was submitted to the EC under the same call.

ISD’s full submission is available on the EC website.

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