Work & reports

Evidence of the work, not a list of claims.

Selected engagements and public studies show the substance, range and institutional settings of DigiData’s work. Forthcoming work is labelled clearly; private Council of Europe AI-in-education materials are not published here.

Selected engagements

Different forms of work, described accurately.

The examples distinguish commissioned studies, ongoing advisory work, public submissions, personal-capacity contributions and research partnerships. The wording avoids implying that every organisation shown is a conventional fee-paying client or endorses DigiData.

Public library

Reports, submissions and long-form analysis.

Download the public files directly or follow the official publication record where one exists.

Cover for Report for the European Commission on Article 5(1)(a) and (b) of the AI ActPublished
2026European Commission final study report

Report for the European Commission on Article 5(1)(a) and (b) of the AI Act

A comprehensive analysis of subliminal, purposefully manipulative, deceptive and vulnerability-exploitative AI practices, including constitutive elements, enforcement challenges, use cases and interaction with the wider EU digital acquis.

Cover for Analysis of Deceptive Design Techniques in Online Services Popular Among ChildrenPublished
2025Commissioned report for the Dutch Government

Analysis of Deceptive Design Techniques in Online Services Popular Among Children

A 155-page analysis of manipulative interfaces and system architecture, personalised influence, gamification, children’s vulnerabilities and the adequacy of the GDPR, DSA, UCPD and AI Act.

Cover for Making Access to Google Search Data Work Without Inventing a Privacy FictionPublished
2026European Commission consultation submission

Making Access to Google Search Data Work Without Inventing a Privacy Fiction

A submission on Article 6(11) DMA that preserves anonymisation as the legal condition for sharing personal search data, proposes tiered access modalities and introduces the AUIA.

Cover for The Innovation MandatePublished
2026Policy paper

The Innovation Mandate

A proposal for a binding duty of evidence and public reason-giving when digital regulators choose among materially different lawful routes affecting rights, legal certainty, investment and scale.

Cover for From Individual Rights to Industrial LitigationPublished
2026CIPL Digital Thought Lab report

From Individual Rights to Industrial Litigation

An analysis of collective redress, Article 82 GDPR, procedural fragmentation, forum selection, automation and the need to keep harm, procedure and remedy tightly coupled.

Cover for Consumer Interest and AI: Tools, Frameworks, Accountability and Tolerable RiskPublished
2026DRCF Phase 2 submission · Personal capacity

Consumer Interest and AI: Tools, Frameworks, Accountability and Tolerable Risk

A functional risk ladder and Consumer AI Accountability Framework covering purpose, control, evidence, outcomes, redress, agentic permissions, action receipts and cross-sector cooperation.

Cover for Non-Personal Data Is Not One ThingPublished
2026Research essay and taxonomy

Non-Personal Data Is Not One Thing

A cross-acquis taxonomy that separates legal status from route, scope, artefact form, circulation and assurance instead of treating non-personal data as one coherent object.

Cover for From Sticker to Passport: TRACE and the AUIAPublished
2026Research essay and product concept

From Sticker to Passport: TRACE and the AUIA

A documentation stack in which the legal baseline, complete assessment dossier and portable data-status claim remain separate, reviewable and time-bounded.

Cover for Recalibrating the EDPB and the EDPS Under a Duty to CooperatePublished
2026Institutional reform policy paper

Recalibrating the EDPB and the EDPS Under a Duty to Cooperate

An institutional case for cooperative digital administration, clearer responsibility, procedural discipline, auditable separation and an enforceable duty of inter-regulatory cooperation.

Cover for ProportionalityPublished
2026Legal research paper

Proportionality

A reconstruction of proportionality as a discipline of justified interference and rights-sensitive technological architecture across EU law, the GDPR and the AI Act.

Cover for The Addiction Panic Is a Poor Basis for Children’s RightsPublished
2026Long-form policy essay

The Addiction Panic Is a Poor Basis for Children’s Rights

A rights-based critique of addiction-centred policy narratives and a case for evidence-led, function-specific regulation of manipulation, exploitation and genuine harm.

Cover for Outcome Report on the EU Proposal to Prevent and Combat Child Sexual AbusePublished
2023Interdisciplinary expert workshop report

Outcome Report on the EU Proposal to Prevent and Combat Child Sexual Abuse

An expert-workshop report on proportionality, detection orders, private communications, children’s participation and fundamental rights, presented to the Council of Europe’s Lanzarote Committee.

Cover for Virtual Currencies, Real HarmsPublished
2021Policy report

Virtual Currencies, Real Harms

An earlier policy report on consumer and regulatory harms associated with virtual currencies and the need for legal certainty in technically complex markets.

Cover for The Digital Omnibus and Legal CertaintyForthcoming
2026Forthcoming flagship report

The Digital Omnibus and Legal Certainty

A forthcoming report on contextual identifiability, anonymisation, scientific research, supervisory interpretation and the political economy of Europe’s digital simplification programme.

“The strongest argument is rarely the loudest position. It is the one that makes its assumptions visible, survives the hard objection and still leaves a workable route forward.”DigiData working principle
Publication status

Public where possible. Controlled where necessary.

DigiData publishes work when commissioning terms, timing and subject matter permit it. Some work remains confidential, and some institutional materials cannot be released before the relevant process concludes.

Start a conversation

A difficult digital-regulation question deserves more than a generic compliance answer.

Tell DigiData what decision, dispute or policy problem you need to resolve. The initial enquiry form is designed to establish scope, urgency and the expertise the work may require.