Joint EU letter calls for robust risk assessment for children’s rights under the DSA
5Rights, alongside 24 children’s rights organisations and 5 Members of the European Parliament, has sent a letter to the Executive Vice-president of the European Commission for Technological Sovereignty, Security and Democracy, Henna Virkkunen, calling on the European Commission to provide further guidance on the structure of the risk assessments that VLOPs (Very Large Online Platforms) have to submit according to the Digital Services Act.
The letter argues in particular that the European Commission should:
- Establish a minimum time frame. Online platforms should submit risk assessments that cover a period of at least one year.
- Provide a common framework for risk assessment and mitigation. Online platforms should ground their risk assessments in children’s rights as outlined in the UN Convention on the Rights of the Child and General comment No. 25.
- Establish benchmarks for indicators of risk and its mitigation. Online platforms should not redact information unnecessarily.
- Ensure children and civil society can participate in the preparation of the risk assessment reports. This will guarantee that the risk assessments truly reflect children’s lived experiences and are based on the best available information and scientific insights.
- Include minimum accessibility requirements. Online platforms should publish their assessments in a machine-readable or easily accessible format.
When carried out thoroughly, transparently and through a child rights lens, risk assessments could provide crucial information for regulators, researchers and civil society to hold platforms accountable. The European Commission should therefore ensure that online platforms fulfil their obligations to assess and mitigate risks to children under the Digital Services Act (DSA).
