our recommendations to the European Data Protection Board – World Wide Web Foundation

This post was written by Kaushalya Gupta, Political Program Manager and leading the Tech Policy Design Lab project on deceptive design.


Misleading designs, also known as “dark patterns”, pose a serious threat to the protection of fundamental rights, as they can cause considerable harm to people, especially vulnerable people. As part of our ongoing commitment to this issue, we have joined Access Now and Simply Secure to make recommendations to the European Data Protection Board (EDPB) on Social Media Interface “Dark Patterns” Guidelines.

These guidelines offer practical recommendations for designers and users of social media platforms to recognize and avoid misleading design, with great potential to serve not only as an essential resource, but also to shape industry practices at the coming.

Since the adoption of the guidelines in March, the political institutions of the European Union have reached agreement on many central issues of the Digital Services Act, including measures prohibiting certain types of misleading design. We believe that the Commission’s guidelines should now be used as a tool to implement and enforce this legislation.

Our joint recommendations focus on how to ensure the Guidelines have the most impact for a wide audience and how to leverage the Guidelines among civil society organizations to help change the status quo.

In particular, we hope the EDPB will consider our recommendation to limit the use of the term “dark patterns” and instead move to “misleading design”, a more culturally appropriate, user-centric and inclusive term. . We welcome the decision of Harry Brignull, who coined the original term “dark patterns” for adopt the phrase “misleading conception.

We are confident that these guidelines will go a long way in informing users about misleading design practices and their rights regarding their personal data.

What is the next step in our work to combat misleading design

It is imperative that we continue our work towards a future of reliable design. That’s why we’ll be hosting our first Tech Policy Design Lab workshop on May 26, 2022. This workshop will focus on designing patterns to embrace “trustworthy design” to combat misleading design on the web at scale.

Often described as “click to subscribe, call to unsubscribe”, misleading designs are more than a nuisance – they’re too often a default practice that platforms may have unwittingly adopted and are wreaking havoc on consumer choice, autonomy and financial stability. This workshop is the first in a series that aims to create viable models for design practices that enhance consumer autonomy and choice, and provide a path forward for trusted design practices.

Our policy design workshop will include civil society and government representatives, industry advocates and other subject matter experts. At the end of the workshop, we hope to craft a vision of a Web based on trusted design that governments, technology companies, industry partners and designers can take forward – a vision that is grounded in global perspectives. and the lived experience of those most affected by motive deception.

Watch this space for more information on our sessions at RightsCon 2022, taking place June 6-10, 2022.

To learn more about the lab, please visit techlab.webfoundation.org.


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