Data Strategy Briefing — February 13, 2024

Executive briefing: On 13 February 2024 the European Commission adopted Implementing Regulation (EU) 2024/481 to operationalise Article 40 of the Digital Services Act (DSA), setting out standard forms, timelines, and security requirements for vetted researcher access to platform data.

Key data governance checkpoints

Request triage. Align intake workflows with the regulation’s mandatory request template, ensuring teams can validate research purposes, legal bases, and confidentiality commitments.
Secure environments. Prepare controlled processing environments with logging, access controls, and export restrictions that comply with Article 40 safeguards.
Documentation. Maintain registers of granted, modified, or refused requests with justifications to satisfy reporting duties to the Commission and national Digital Services Coordinators.

Operational priorities

Role assignments. Designate cross-functional teams spanning legal, privacy, security, and data engineering to process requests within the regulation’s one-month decision window.
Template updates. Refresh contractual clauses, NDAs, and data dictionaries to align with the implementing regulation’s disclosure requirements.
Escalation playbooks. Establish decision trees for denying requests due to trade secrets, security risks, or disproportionate burdens.

Enablement moves

Train policy and trust & safety teams on the distinction between public DSA transparency reporting and vetted researcher access obligations.
Integrate Article 40 workflows into enterprise data inventories to ensure only approved datasets are exposed.

Sources

Zeph Tech helps digital platforms operationalise DSA researcher access, from vetting workflows to secure data environments.