Report March 2025

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Empowering Users

Commitment 17

In light of the European Commission's initiatives in the area of media literacy, including the new Digital Education Action Plan, Relevant Signatories commit to continue and strengthen their efforts in the area of media literacy and critical thinking, also with the aim to include vulnerable groups.

We signed up to the following measures of this commitment

Measure 17.2 Measure 17.3

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 17.2

Relevant Signatories will develop, promote and/or support or continue to run activities to improve media literacy and critical thinking such as campaigns to raise awareness about Disinformation, as well as the TTPs that are being used by malicious actors, among the general public across the European Union, also considering the involvement of vulnerable communities.

QRE 17.2.1

Relevant Signatories will describe the activities they launch or support and the Member States they target and reach. Relevant signatories will further report on actions taken to promote the campaigns to their user base per Member States targeted.

Les Surligneurs organises and participates in awareness-raising events on disinformation issues and fact-checking. In 2024, it notably organized the first two editions of a new series of debates:

- « La régulation d’internet peut-elle apporter la paix ? », 12/11/24;

- « La désinformation est-elle en train de tuer la démocratie ? », 10/12/24.

Measure 17.3

For both of the above Measures, and in order to build on the expertise of media literacy experts in the design, implementation, and impact measurement of tools, relevant Signatories will partner or consult with media literacy experts in the EU, including for instance the Commission's Media Literacy Expert Group, ERGA's Media Literacy Action Group, EDMO, its country-specific branches, or relevant Member State universities or organisations that have relevant expertise.

QRE 17.3.1

Relevant Signatories will describe how they involved and partnered with media literacy experts for the purposes of all Measures in this Commitment.

Les Surligneurs occasionally works with EDMO. It notably contributed to a report published in August 2024 on the implementation of the Code of practice by signatories.

Empowering Researchers

Commitment 26

Relevant Signatories commit to provide access, wherever safe and practicable, to continuous, real-time or near real-time, searchable stable access to non-personal data and anonymised, aggregated, or manifestly-made public data for research purposes on Disinformation through automated means such as APIs or other open and accessible technical solutions allowing the analysis of said data.

We signed up to the following measures of this commitment

Measure 26.1 Measure 26.2

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 26.1

Relevant Signatories will provide public access to non-personal data and anonymised, aggregated or manifestly-made public data pertinent to undertaking research on Disinformation on their services, such as engagement and impressions (views) of content hosted by their services, with reasonable safeguards to address risks of abuse (e.g. API policies prohibiting malicious or commercial uses).

QRE 26.1.1

Relevant Signatories will describe the tools and processes in place to provide public access to non-personal data and anonymised, aggregated and manifestly-made public data pertinent to undertaking research on Disinformation, as well as the safeguards in place to address risks of abuse.

Les Surligneurs’ articles are freely accessible, and anyone can scrap and analyse them. Les Surligneurs remains open to sharing its relevant data for research purposes. The group itself is strongly connected to the academic sector as it is driven by law professors and doctoral students. Anyone can contact [email protected] for such a request. None has been received yet.

Commitment 27

Relevant Signatories commit to provide vetted researchers with access to data necessary to undertake research on Disinformation by developing, funding, and cooperating with an independent, third-party body that can vet researchers and research proposals.

We signed up to the following measures of this commitment

Measure 27.3

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 27.3

Relevant Signatories commit to cooperate with the independent third-party body referred to in Commitment 27 once it is set up, in accordance with applicable laws, to enable sharing of personal data necessary to undertake research on Disinformation with vetted researchers in accordance with protocols to be defined by the independent third-party body.

QRE 27.3.1

Relevant Signatories will describe how they cooperate with the independent third-party body to enable the sharing of data for purposes of research as outlined in Measure 27.3, once the independent third-party body is set up.

Les Surligneurs is a member of the EFCSN and works on the establishment of the repository and other initiatives at the EU scale. It remains open to work with the third-party body referred to in Commitment 27.

Commitment 28

COOPERATION WITH RESEARCHERS Relevant Signatories commit to support good faith research into Disinformation that involves their services.

We signed up to the following measures of this commitment

Measure 28.1 Measure 28.2 Measure 28.3

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 28.1

Relevant Signatories will ensure they have the appropriate human resources in place in order to facilitate research, and should set-up and maintain an open dialogue with researchers to keep track of the types of data that are likely to be in demand for research and to help researchers find relevant contact points in their organisations.

QRE 28.1.1

Relevant Signatories will describe the resources and processes they deploy to facilitate research and engage with the research community, including e.g. dedicated teams, tools, help centres, programs, or events.

Anyone can contact [email protected] or fill a form to make requests. Appropriate human resources are dedicated to this, considering that the volume of demands is low.

Measure 28.2

Relevant Signatories will be transparent on the data types they currently make available to researchers across Europe.

QRE 28.2.1

Relevant Signatories will describe what data types European researchers can currently access via their APIs or via dedicated teams, tools, help centres, programs, or events.

Les Surligneurs’ fact-checking articles are completely and freely accessible. Anyone can scrap and analyse them.

Measure 28.3

Relevant Signatories will not prohibit or discourage genuinely and demonstratively public interest good faith research into Disinformation on their platforms, and will not take adversarial action against researcher users or accounts that undertake or participate in good-faith research into Disinformation.

QRE 28.3.1

Relevant Signatories will collaborate with EDMO to run an annual consultation of European researchers to assess whether they have experienced adversarial actions or are otherwise prohibited or discouraged to run such research.

Les Surligneurs is open to work with EDMO on the annual consultation of European researchers. It did not prohibit or discourage public interest good faith research into Disinformation.

Permanent Task-Force

Commitment 37

Signatories commit to participate in the permanent Task-force. The Task-force includes the Signatories of the Code and representatives from EDMO and ERGA. It is chaired by the European Commission, and includes representatives of the European External Action Service (EEAS). The Task-force can also invite relevant experts as observers to support its work. Decisions of the Task-force are made by consensus.

We signed up to the following measures of this commitment

Measure 37.1 Measure 37.3 Measure 37.4 Measure 37.5

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

Yes

If yes, list these implementation measures here

Les Surligneurs is working with the task-force and is, more specifically, engaged in the sub-groups on Empowering fact-checkers and on Generative AI. It participates to the meetings and work of the said sub-groups, and to the plenary meetings of the Code (notably, in 2024, regarding its conversion to a Code of Conduct under the DSA).

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?