Submission to the European Commission Delegated Regulation on Data Access Provided for in the Digital Services Act Technical Paper 2024.4

The IPIE submission argues for the reduction of bureaucratic barriers and the strengthening of researcher rights under the Digital Services Act's data access framework. Based on a survey of scientific affiliates, the document identifies risks such as political capture of Digital Services Coordinators (DSCs), lack of transparency in data inventories, and restrictive interpretations of 'other sources' of data. Key recommendations include the implementation of a fast-track process for time-sensitive data, mandatory researcher participation in dispute settlements, and the requirement for DSCs to use English as a mandatory communication language to ensure cross-border scientific coordination.

• Researchers identified significant barriers to data access, including the use of closed APIs associated with low data quality, a lack of transparency and consistency in policies, and the denial of requests without justification.
• The IPIE warns that the implementation of the DSA may be hindered by overly bureaucratic vetting processes, platform resistance based on proprietary data arguments, and the risk that Digital Services Coordinators (DSCs) in different Member States could be subject to political capture.
• There is a specific concern that platforms may use the vague definition of "other sources" in Article 8(3)(6) of the DDR to block data requests by claiming data is theoretically public even when it is not practically accessible.
• The IPIE recommends that the DDR be amended to require DSCs to communicate in more than one EU language, specifically making English mandatory, to align with the operational language of the global research community and VLOP engineering teams.
• To ensure a balanced regime, the IPIE proposes that principal researchers be granted mandatory participation in dispute settlement procedures and the right to appeal DSC decisions to a cross-national appeals panel.

APA

Glenster, A. K. (2024). Submission to the European Commission Delegated Regulation on Data Access Provided for in the Digital Services Act Technical Paper 2024.4. International Panel on the Information Environment. https://www.ipie.info/research/tp2024-4

Chicago

Glenster, Ann Kristin. Submission to the European Commission Delegated Regulation on Data Access Provided for in the Digital Services Act Technical Paper 2024.4. International Panel on the Information Environment, 2024. https://www.ipie.info/research/tp2024-4.

Wikipedia

{{cite press release |last1=Glenster |first1=Ann Kristin |title=Submission to the European Commission Delegated Regulation on Data Access Provided for in the Digital Services Act Technical Paper 2024.4 |publisher=International Panel on the Information Environment |date=2024 |url=https://www.ipie.info/research/tp2024-4 |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{glenster2024submission, author = {Glenster, Ann Kristin}, title = {{Submission to the European Commission Delegated Regulation on Data Access Provided for in the Digital Services Act Technical Paper 2024.4}}, publisher = {International Panel on the Information Environment}, year = {2024}, url = {https://www.ipie.info/research/tp2024-4}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }