Vetted researchers
Researchers sometimes need non-public data from very large online platforms and search engines for risk assessments. In order to gain access to such data, researchers can apply for vetted status with ACM. Very large platofrms and search engines are required to give vetted researchers access to the data.
On this page:
Access to non-public data
Vetted researchers are researchers that have the right to access non-public data for their assessments. Very large online platforms and search engines are required to give researchers access to that data if these researchers are vetted researchers.
This is the case in assessments of systemic risks at the very large online platforms and search engines (in Dutch). These are risks that can inflict serious harm to society or the economy at large, for example the widespread dissemination of illegal content or election interference. It can also involve assessments of the measures for mitigating systemic risks.
Requirements for vetted status
For the status of ‘vetted researcher’, the assessment itself and all current and future researchers will need to meet the following requirements:
- The researcher is affiliated with a research organization.
- The researcher is not dependent on commercial interests.
- The application discloses the funding of the assessment.
- The researcher handles the data confidentially, and is able to secure it. In addition, the researcher protects personal data. The technical and organizational measures that the researcher has put in place for that purpose have been described in the application.
- Access to the data and the time frames requested are necessary for, and proportionate to, the assessment objective. The expected results will contribute to the assessment objective. The objective of the assessment activities is to contribute towards the detection, identification and understanding of systemic risks, or towards the assessment of the effectiveness, efficiency and the effects of the measures taken by very large online platforms and search engines.
- The researcher will make the assessment results publicly available free of charge, within a reasonable period after the completion of the assessment.
Filing an application for vetted status
At a later point in time, applications will be filed via our website. Separate applications need to be filed for each platform or search engine.
Attention! At this point, researchers cannot file applications with us yet.
We are currently waiting for the publication of 'delegated acts' of the European Commission. These will offer more clarity regarding the vetted status itself and the application process. The European Commission is expected to publish these rules in the course of 2025. More information will follow soon.
If you are a researcher and you wish to apply for vetted status soon, send your contact details to acm-post [at] acm [punt] nl, and we will inform you when there is more clarity.
Researchers will soon apply for vetted status with us if one of the following is located in the Netherlands:
- The European headquarters of the platform or search engine that they are assessing
- The legal representative of the platform or search engine that they are assessing
- Their research organization
If none of these is the case, the application must then be filed in a different member state.
We will assess whether a researcher meet the requirements, and then decide whether we grant them the status of ‘vetted researcher’. The Dutch Data Protection Authority (AP) gives us advice about the protection of personal data.
If the research organization is located in the Netherlands, but the platform or search engine is located in a different member state, we will only carry out a preliminary assessment of the application. We will subsequently forward the application to the member state in which the very large online platform or search engine is located. That member state will make the final decision.
These very large online platforms or search engines are currently located in the Netherlands or have their legal representatives there:
- AliExpress International (Netherlands) B.V. (AliExpress)
- Booking.com B.V. (Booking.com)
- Snap B.V. (Snapchat)
- Wikimedia Foundation Inc (Wikipedia)
An up-to-date overview of all very large online platforms and search engines can be found on the European Commission’s website. The European Commission can designate new businesses.
Revoking the status of vetted researcher
We conduct oversight over the researchers that we have granted vetted status. We can investigate whether the researcher still meets the requirements. We can launch such investigations ex officio or following reports.
If a vetted researcher no longer meets the requirements, we may revoke the status of vetted researcher.
If you have any indications that a vetted researcher no longer meets the requirements, please file a report with us.
Access to public data
If researchers need, for their research, access to data that is publicly available, they do no need vetted status.
Very large online platforms and search engines must grant all researchers access to data if:
- That data is publicly available
- The researcher is affiliated with a not-for-profit organization
- The researcher is not dependent on commercial interests
- The funding of the assessment has been disclosed
- The researcher handles data confidentially, and is able to secure and protect this and other personal data
- The researcher demonstrates that the access to publicly available information is necessary for detecting, identifying, and understanding systemic risks
The European Commission monitors whether the platforms and search engines comply with these rules.
Sources
- Digital Services Act (DSA)