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: [email protected] 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 <[email protected]> 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 <[email protected] <mailto:[email protected]>> > Date: Fri, Apr 28, 2023 at 9:30 AM > Subject: [WMEU updates] VLOP designation of Wikipedia under the DSA > To: <[email protected] <mailto:[email protected]>> > > 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 > > -- > > To unsubscribe from this mailing list, get a password reminder, or change > your subscription options, please visit: > https://lists.ripe.net/mailman/listinfo/cooperation-wg
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