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médialab’s feedbacks on EU’s proposal regarding researchers access to social networks data

The médialab participated in December 2024 to the European Commission’s consultation regarding the implementation of researchers' access to data from very large online platforms and search engines through Article 40 of the Digital Services Act (DSA). Ensuring more accessibility, efficiency and transparency of the process are the main lines of improvements proposed by the médialab.

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Having been working on and with platforms data for the past ten years, médialab formulated its feedbacks to the consultation in the hopes of improving the modalities of access as well as the transparency of the process that will permit researchers to request data that are essential digital resources for social science research in general and to the studies of systemic risks in particular.

Problematic recent platforms reclosure

The médialab’s research, which often relies on data from social networks for instance, provides critical insights into the technological impacts on societies. However, recent restrictions on data access from a variety of platforms such as the closure of Twitter’s free API or Facebook’s Crowdtangle tool have been raising more and more concerns regarding the long-term sustainability of our work.

Possible improvements

The médialab’s researchers and engineers welcome the proposed draft regulation and recognize the significance of this regulation for advancing research, especially as it already includes parts of the recommendations proposed during earlier stages of the regulation drafting process, such as some partial transparency on data already requested by other researchers.

However, the current proposition still lacks some precisions and safeguards. It also encompasses elements which provide risks of backdoors that could allow platforms to considerably restrict the data access requests. In order to better ensure data accessibility, usability and transparency, the médialab proposes a variety of specific improvements. These recommendations, detailed in the submitted document, address key areas such as data formats and documentation, application procedures, and regulatory mechanisms.

Shared concerns

Browsing through the 108 other feedbacks submitted reveals that the médialab’s concerns are widely shared by many other research institutes and civil society organisations. The médialab would like to emphasize other important contributions such as those from colleagues of the Sciences Po Law School or DMI, as well as worldwide members of the Coalition for Transparency Tech.

Platforms close monitoring

The médialab also read with a strong interest the different contributions from platforms such as X, Meta, Google, TikTok, Snapchat or Amazon, which are all trying to limit researchers’ future capabilities to request data.

Remaining dedicated to promoting a useful regulatory framework, the médialab hopes the regulators will soon propose a final version of the regulation that actively supports social science research while safeguarding users' privacy rights.

Refer to our contribution (proposed changes to the Commission's text are marked in bold and highlighted in green for additions, and highlighted in red with strikethrough for deletions): 

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