Have your say – Digital Fairness Act
You can also get involved in forming EU laws. The European Commission offers a platform “Have your say” with the list of all new EU initiatives open for public consultation. You need to register to write your feedback: ec.europa.eu/info/law/better-regulation/have-your-say
Digital Fairness Act
About this initiative: This initiative aims to tackle problematic practices such as:
- unfair personalisation practices.
- unfair commercial practices related to dark patterns
- misleading marketing by influencers
- addictive design of digital products
Feedback period: for stage 2+3 it is 17 July 2025 – 24 October 2025
Feedback from Europeans for Safe Connections
We Europeans for Safe Connections welcome the intention to curb unethical digital practices and protect vulnerable consumers.
At the same time, we stress the importance of ensuring that such measures do not undermine fundamental rights, particularly the right to privacy and the freedom to use end-to-end encrypted communications. The regulation must not lead to disproportionate surveillance or mandatory data accessibility for authorities.
A revision bill is being prepared by Denmark at the moment for the long awaited CSA Regulation, which may circumvent this legislation by allowing scanning of end-to-end encrypted messages, not only of pictures but in the long run also of text. The intention is to protect children but the measures are not in alignment with the objectives. We can in no way endorse this part of the proposal and we urge the EC to uphold basic human privacy rights.
We also call for increased transparency from digital service providers and device manufacturers regarding default settings, data collection practices and the ability of users to retain real control over their digital environment — including the right to opt out of manipulative interfaces and data tracking.
Only by respecting these boundaries can digital fairness truly be achieved.
We have these suggestions:
1) Online platforms shall not be accessible for children via free internet, e.g. Wifi4EU. Children using internet platforms must always be supervised to some degree. At home parents are responsible, at school teachers are responsible, parents are responsible for (not) buying mobile data. The specification of Wifi4EU is: no-password, charge-free, unlimited and children know that and take the opportunity to use it.
2) Online platforms should contain warnings using similar systems to the ones on cigarettes. E.g. “You should prefer real people over our platform” or “You should use our platform via cable rather than wirelessly“. Moreover the platform should provide a counter on a visible place informing about the time already spent on that platform and a CO2 footprint.
3) Platforms should minimise data collection.
Children must not be monetised by data collectors without the informed consent of parents or legal guardians. All informed consents must be facilitated. The child and guardian must be able to easily understand the data collection and be able to very easily set up an opt-out.
4) Platforms should not be allowed to process automatically the data of children below 18 years old. An artificial intelligence shall not process the data of children below 18 years, and people above 18 should give an explicit agreement (opt-in) to process their data automatically or by AI.
The functionality of the system must not be conditional on consent.
5) Platforms aimed at children should be transformed into ethical platforms that do not display unhealthy attitudes, unhealthy behaviour, violent or otherwise inappropriate content and should not manipulate the identity of the child.
6) Regarding educational platforms, the rules must be even more strict. We welcome very much the 2023 Global Education Monitoring Report of UNESCO (https://gem-report-2023) and we would like to refer to PDF page 183:
- In Denmark, a data protection impact assessment conducted by the Elsinore municipality in relation to Google Workspace for Education and Chromebooks led to banning their use in schools.
- France’s Ministry of Education and Youth has banned free versions of Microsoft Office 365 and Google Workspace in schools.
- In Germany, Microsoft products have been banned in the states of Baden-Württemberg and Hessen because they do not comply with the GDPR.
- The Dutch Data Protection Authority proposed to ban Chromebooks and Google Workspace for Education from schools until August 2023 because of non-compliance with children’s data protection and privacy regulations.
Best regards
Europeans for Safe Connections
This feedback was sent from a wired internet connection
– No use of harmful radiation
– Less electricity consumption
– Increased data security
The link to our feedback: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14622-Digital-Fairness-Act/F32845037_en