ARTICLE 19 joined other organisations in the European Digital Rights (EDRi) coalition to present a submission to the European Commission’s consultation on the template related to the reporting on consumer profiling techniques. Gatekeepers – a designated group of large online platforms – collect a wide array of data to profile users. Effective reporting and subsequent auditing of the reports that designated gatekeepers will have to submit as part of their obligations under the Digital Markets Act (DMA) is key to protecting user privacy.
The DMA’s strength lies in its ability for the enforcement authority as well as for the public to obtain independent, reliable information about the gatekeepers’ business conduct in the EU. The use of profiling techniques and the related intrusions into people’s right to privacy are of particular importance as those intrusions are often invisible and the techniques used incomprehensible and opaque to non-expert eyes.
ARTICLE 19 welcomes the European Commission’s draft template, which takes a clear stand against deep consumer profiling and considers enhanced transparency as one of the main ways to achieve the DMA’s objective.