[cooperation-wg] Wikimedia Europe and RIPE (Fwd: [WMEU updates] VLOP designation of Wikipedia under the DSA)

Dear Željko

Thanks for sharing and taking an interest in discussing a particular EU regulatory issue - the Digital Service Act and how it impacts Wikipedia Europe.

The Coop WG members usually focuses on discussion on how new regulations across the RIPE NCC service region may affect the work of network operators.
The Coop WG encourages participation outside the traditional RIPE community members including regulators, governments and other stakeholders.
 
Fyi - I am but one of 3 Coop WG Chairs, alongside Achilleas Kemos and Julf Helsingius.
You can reach us at: cooperation-wg-chairs at ripe.net as well. 

The BEUC might also be a place to check out.

Best

Desiree
—
Coop WG Co-Chair



> On 25 May 2023, at 09:41, Željko Blaće <zblace at mi2.hr> wrote:
> a 
> Dear RIPE.net Collaboration working group, after meeting some of you at RIPE#86 meeting and talking to your chair Desire Milosevic, I am making a second effort in trying to connect RIPE and Wikimedia, now with more specifically Wikimedia Europe that has been recently formally recognized as a legal entity and not just a advocacy group (as it used to be for many years in Brussels) supported by Wikimedia Germany and other affiliates.
> 
> Here is the most recent Wikimedia Europe update where I think our shared focuses overlap and could maybe benefit from inter-personal or inter-organizational coordination.
> As both organizations make strong efforts to work in maximum transparency to its communities and general public, as well as for the equality and benefit of all Internet users I am sure this will be possible to do in the near future and around shared urgencies. 
> 
> Best Z. Blace
> 
> 
> ---------- Forwarded message ---------
> From: Dimi Dimitrov <dimi at wikimedia.be <mailto:dimi at wikimedia.be>>
> Date: Fri, Apr 28, 2023 at 9:30 AM
> Subject: [WMEU updates] VLOP designation of Wikipedia under the DSA
> To: <updates at wikimedia-europe.eu <mailto:updates at wikimedia-europe.eu>>
> 
> Hi all,
> 
> The European Commission has designated Wikipedia as a Very Large Online Platform. This is no surprise and is based on the user numbers the WMF has published for the EU (https://foundation.wikimedia.org/wiki/Legal:EU_DSA_Userbase_Statistics <https://foundation.wikimedia.org/wiki/Legal:EU_DSA_Userbase_Statistics>). We estimate that we have 151 million users in the EU, 45 million would have been required. 
> 
> There are 19 platforms that fall into this category, we are the only not-for-profit. This comes with additional obligations and some bragging rights. With this status I think we can demand high level political attention in Europe. 
> 
> On the obligations, I am copying the monitoring report paragraphs below. Here is also a list of the main points:
> The DSA is targeted at the service provider (Wikimedia Foundation), not the community content moderation
> The WMF will have to appoint a legal representative in the EU for which it will  need to choose a country 
> The notice & action system means that how a user sends complaints to the WMF is now clear and the stages that follow. 
> The WMF will have to do annual risk assessments for systemic risks and mitigation reports based on them
> The WMF will need to find an auditor to control the risk assessment and mitigation measures
> The WMF will need to publish its EU user estimate every three months
> The WMF will have to pay a VLOP fee to the European Commission
> The WMF is expected to contribute to the EU's moderation decision database
> The WMF will need to demonstrate how it protects minors on Wikipedia
> I am available for additional questions, statements or interviews. Below is the monitoring report section for more detail. Phil Bradley-Scmieg, the WMF lawyer who is based in Europe and working on this can also be reached by email or on the public policy mailing list. 
> 
> === Digital Services Act ===
> WE ARE VLOP. Officially. [1] For those less acquainted with EU terminology: Wikipedia has been designated as a Very Large Online Platform by the European Commission, which means that the WMF will have to comply with the strictest obligations under the Digital Services Act, including regular risk assessments for systemic risks (including things like public health, kids’ safety and freedom of expression), publishing mitigation measures based on them, and then undergoing an external audit. Wikipedia is the only not-for-profit service that has been designated as a VLOP; the other 18 are for-profit. 
> —
> This is a chance for Wikimedia to demonstrate that compliance with such rules can be done in a manner that respects user rights and keeps communities - not the platform operator - in the driving seat. The Wikimedia Foundation (WMF) is working on compliance and dedicating significant resources to this. The challenges are serious too. If regulators cannot be convinced that Wikipedia is properly addressing “systemic risks”, like election manipulation, then WMF and the community will be challenged to find additional responses to that.  There’s also substantial “bureaucracy”: VLOP designation means that the WMF needs to appoint a legal representative in the EU. It needs to adjust internal processes so they are in line with the new “notice & action” framework, it has to set up a process on how to conduct risk assessments and mitigation reports (annually, and before making significant changes to things), and to find an appropriate auditor who will grill it on all of these things. 
> —
> VLOPs are also expected to contribute to the European Commission’s moderation decision database (though whether and how such a database can comply with EU privacy laws, remains to be seen). Plus, there remains the not inconsequential task of ensuring all of the other Wikimedia projects - such as Commons - comply with the DSA’s more general rules.  That’s a lot of work - and so is convincing the regulators to not forget our model when they’re writing the guidance and implementing rules - and it is handled by very lean teams (as openly and collaboratively as they can manage - witness the TOU update <https://meta.wikimedia.org/wiki/Wikimedia_Foundation_Legal_department/2023_ToU_updates>).
> 
> 
> Cheers,
> Dimi
> -- 
> Dimitar Dimitrov
> Policy Director
> Wikimedia Europe
> 
> mobile: +32497720374
> Rue Belliard 12 Belliardstraat
> Brussels
> Imagine a world in which every single human being can freely share in the sum of all knowledge. That's our commitment.
> www.wikimedia.org <http://www.wikimedia.org/>
> 
> Wikimedia Europe ivzw
> 
> -- 
> 
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