Base normativa
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DSA Art. 14 - Terms and conditions
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DSA Art. 15 - Transparency on content restrictions
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DSA Art. 17 - Statement of reasons
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DSA Art. 24 - Transparency obligations for VLOPs
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DSA Art. 42 - Additional transparency for very large platforms AGCOM - Communications Guarantee Authority (competent Italian authority)
What it is
The right to transparency on moderation is the right to know how and why digital platforms (social networks, marketplaces, app stores, etc.) decide to:
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Remove or limit your content
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Suspend or close your account
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Reduce the visibility of your posts (shadow ban)
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Reject your products from a marketplace
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Remove your app from a store
In practice, it means platforms MUST:
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Explain decisions clearly: tell you which specific rule was violated
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Indicate consequences: temporary or permanent ban, content removal, etc.
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Provide redress options: how you can appeal the decision
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Publish transparency reports: how many contents removed, for what reasons, etc.
When
The right applies with increasing intensity depending on the size of the platform:
For ALL Platforms
1. Clear Terms and Conditions (DSA Art. 14)
Mandatory: Post T&Cs that explain:
Content Restrictions:
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What is prohibited (hate speech, nudity, violence, spam, fake news)
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Precise definitions (it's not enough to say "hate speech is prohibited", they must explain what they mean)
Consequences of violations:
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Warning
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Removing content
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Temporary suspension
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Permanent ban
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Gradual enforcement
Enforcement policies:
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Preventive/reactive moderation
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Algorithmic/human/mix
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Exceptions (violent content OK if educational context)
Complaints system:
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How to contest
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Complaint form link
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Response times
Dispute Resolution:
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Certified ADR bodies available
T&C Requirements:
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Easily accessible (link visible on homepage)
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Clear language (no obscure legalese)
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Updated regularly (changelog changes)
Compliant example: Facebook Community Standards (transparency.fb.com/policies)
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"Violence and Incitement" section: definitions, examples, prohibited content, exceptions, and sanctions
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"Adult Nudity" Section: Rules, Exceptions (Breastfeeding, Protest, Art), and Consequences
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Each category: what violates, what does not, graduality of sanctions
2. Reasoned Notification (DSA Art. 17)
When they remove YOUR content, they MUST notify you with:
A) Specific reason
B) Contested fact
C) Whether automated or human decision
D) Consequences
E) Available rights
For VLOP - Very Large Platforms (>45M EU users)
Additional Obligations:
1. Half-Yearly Transparency Reports (DSA Art. 24)
2. Transparency Algorithms Recommendation (DSA Art. 27)
I must explain how the algorithms that decide what you see work:
A) Main ranking parameters
B) User Edit Options
C) NON-algorithmic feed option
D) Transparency for individual content:
Each suggested post must have a "Why am I seeing this?" link:
DIRITTI DIGITALI UTENTI ONLINE