Data Protection Compliance for DSA Data Access

AWO supports researchers and civil society organisations seeking access to platform data under the EU’s Digital Services Act (DSA). Under the Article 40, researchers can obtain data from very large online platforms and search engines (VLOPSEs) to detect, identify and understand the systemic risks arising from the design or functioning of online platforms available in the EU. In exchange for that access, researchers must demonstrate that they can handle platform data securely and in full compliance with the General Data Protection Regulation (GDPR).

For many organisations, this can be a significant undertaking. As access requests face growing scrutiny from both regulators and platforms, data protection can no longer be an afterthought. Research objectives must be scoped with precision and supported by a robust data protection posture.

We offer data protection compliance services designed to strengthen your data access application and the research behind it. Our bespoke methodology is tailored to help you:

Bespoke method

We help you articulate the purposes of the research, the key research questions, the specific DSA systemic risk it addresses, and the data required to answer it.

We assess your organisation-wide compliance, including governance, policies, security and accountability, to establish where you stand before you apply.

We trace how personal data will be accessed, analysed, stored and deleted for the research project.

We benchmark the project against the GDPR requirements relevant to data access and produce a gap analysis setting out evidence of compliance, gaps and recommended measures.

We identify an appropriate legal bases and, where sensitive data is involved, a valid exception, supported by a legitimate interest assessment or a data protection impact assessment (DPIA) where required.

We pinpoint where the project may fall short of compliance, along with the data protection risks specific to how the data will be used, and how to remediate them.

We set out prioritised, workable steps and application-ready documentation (such as records of processing, data subject information notices and third-party reviews) to support your reasoned request to the Digital Services Coordinator.

We help you articulate the purposes of the research, the key research questions, the specific DSA systemic risk it addresses, and the data required to answer it.

We assess your organisation-wide compliance, including governance, policies, security and accountability, to establish where you stand before you apply.

We trace how personal data will be accessed, analysed, stored and deleted for the research project.

We benchmark the project against the GDPR requirements relevant to data access and produce a gap analysis setting out evidence of compliance, gaps and recommended measures.

We identify an appropriate legal bases and, where sensitive data is involved, a valid exception, supported by a legitimate interest assessment or a data protection impact assessment (DPIA) where required.

We pinpoint where the project may fall short of compliance, along with the data protection risks specific to how the data will be used, and how to remediate them.

We set out prioritised, workable steps and application-ready documentation (such as records of processing, data subject information notices and third-party reviews) to support your reasoned request to the Digital Services Coordinator.

Our compliance specialists are GDPR experts and former data protection officers with extensive experience of complex, cross-jurisdictional processing environments and novel technologies, including social media monitoring and platform research. They combine deep legal expertise with the technical and organisational understanding needed to make compliance meaningful and workable, not box-ticking.

Get in touch. Send an email or book a call directly with our specialists.