Problem
Research questions and friction points this paper is trying to address.
Digital Services Act
fundamental rights
risk assessment
systemic risks
independent audit
Click, Branch, Audit: A Decision-Tree Toolkit for Assessing Fundamental Rights Impacts under the Digital Services Act of Very Large Platforms & Search Engines
🤖 AI Summary
本文针对欧盟数字服务法案下大型平台和搜索引擎需评估基本权利影响的问题，提出了一种基于决策树的工具包，以系统化的方式识别、评估并记录相关风险。
📝 Abstract
The EU Digital Services Act (DSA) requires Very Large Online Platforms and Search Engines (VLOPs/VLOSEs) to assess and mitigate systemic risks, including actual or foreseeable negative effects on fundamental rights, and subjects these assessments to independent audit. Yet how such rights-relevant risks should be identified, assessed, evidenced, and documented remains methodologically under-specified. We address this gap by introducing a decision-tree-based toolkit that operationalizes Article 34(1)(b) DSA and related audit requirements into a structured assessment process. The toolkit decomposes platforms as systems-of-systems and guides assessors through DSA applicability, context definition, subsystem and stakeholder identification, risk identification, risk assessment, reporting, and visualization. A central design contribution is its treatment of vulnerability as situational and relational: rather than assigning vulnerability to fixed groups, the toolkit asks how particular platform subsystems and dependencies may place stakeholders in vulnerable positions. It further makes fundamental rights-relevant judgments traceable by recording the affected right, interference and justification analysis within the structure of a proportionality test, while also covering a perception and impact dimension including severity, scope, duration, reversibility, as well as practical consequences. We developed the toolkit iteratively through a design-science process combining literature-derived design requirements, three interdisciplinary expert workshops (N=4; N=11; N=20) testing the framework design with two DSA user persona scenarios. We contribute an extensible methodological foundation for making fundamental-rights risk assessments under the DSA more streamlined, systematic, transparent, and auditable.
Innovation
Methods, ideas, or system contributions that make the work stand out.
Decision-Tree Toolkit
Vulnerability as Situational and Relational
Proportionality Test
Fundamental Rights Risk Assessment
Digital Services Act
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