Protect Data Donation Research
This open letter was submitted to the European Commission on December 15, 2025. For our current position, see the GDPR Omnibus letter.
Read the full letter and signatories →
The Issue
The proposed GDPR Omnibus amendment to Article 12(5) would allow data controllers to refuse access requests if deemed for “purposes other than data protection.” This seemingly technical change would effectively end data donation research, one of the few independent methods for studying digital platforms in Europe.
Why This Matters
Data donation research enables critically important studies on topics such as:
- Digital well-being of minors
- Unhealthy or addictive behavior on platforms
- Content exposure and user behavior on social networks
- Political polarization
- Algorithmic systems in gig work platforms
By requiring individuals to exercise their Article 15 GDPR rights to access and voluntarily donate their data, data donation research empowers citizens through participatory knowledge generation. The proposed amendment would give platforms veto power over this independent research.
The Open Letter
The open letter, coordinated by the DSA 40 Collaboratory, calls on the European Commission, European Parliament, and Council of the European Union to reject this amendment.
Initial Signatories Include:
- Anja Bechmann, Aarhus University, Denmark
- Claes de Vreese, University of Amsterdam, The Netherlands
- Daniel Oberski, Utrecht University, The Netherlands
- Florian Keusch, University of Mannheim, Germany
- Jakob Ohme, Weizenbaum Institute, Germany
- Laura Boeschoten, Utrecht University, The Netherlands
- Natali Helberger, University of Amsterdam, the Netherlands
- Theo Araujo, University of Amsterdam, The Netherlands
- Valerie Hase, University of Klagenfurt, Austria
- And many more…