The client develops a platform that provides researchers with access to data collected from social media platforms for research projects into online harms and other topics.
Social media platforms shape discourse, influence elections, and can amplify harmful content. It is therefore important that independent researchers have access to publicly available data from these platforms to help identify potential risks, from disinformation campaigns to child exploitation, while using such data responsibly and ethically.
AWO was asked to carry out a data protection impact assessment of the platform and draft template data sharing agreements governing researcher access to data.
The AWO compliance team conducted a thorough examination of the client’s technical infrastructure to map out the relevant data flows. This formed the basis for the risk analysis carried out for the DPIA which in turn informed the key matters to address in the data sharing agreements. We were able to draw on previous experience working on the intersection between platform data access and data protection compliance, including in the context of the EU's Digital Services Act.
Our work covered important risks and concerns regarding access to platform data by researchers, providing measures to ensure that the use of data complies with the requirements of data protection law. This included recommending the appropriate safeguards needed to rely on legitimate interest as a lawful basis for processing as well as measures for improving the transparency and accountability.
Access to platform data for independent research is a rapidly developing area. Researchers need clarity on the data protection compliance work expected of them and how they can meet the requirements of GDPR. We hope that our work with the client constitutes a positive contribution to the research community in this regard, enabling it to continue with important research that serves the public interest.