AlgorithmWatch’s input on New EU Data Access Rules

The response builds on AlgorithmWatch’s broader work on the Digital Services Act (DSA) and its implementation, alongside ongoing efforts to access and utilize data for public interest research. It also reflects practical experience with an Article 40(4)-style request under the DSA Election Guidelines.

The response is divided into three parts: 

1. A background section on the DSA & Research in Practice, building on AlgorithmWatch’s experiences;
2. Specific proposals for improving on the Draft;
3. An Annex with input from other researchers about the types of data that should be included for inclusion in Recital 12.

The Delegated Act is a strong starting point, but needs some clarification and specification. AlgorithmWatch’s response includes proposals to strengthen the draft, focusing on:

• Enhancing data accuracy: Integrating best practices and expertise from beyond the DSA to ensure companies report data accurately under the new rules.
• Expanding access for researchers: Ensuring a wide range of researchers and research methods can be used to study online platforms and search engines effectively.
• Empowering regulators responsibly: Supporting regulators in leveraging expert insights while ensuring their powers are used fairly to assist researchers.

The real test will be in how these rules are implemented and function in practice. Read the specific proposals here:

Download as PDF