Digital Services Act

The DSA applies to LinkedIn in the EU through LinkedIn Ireland Unlimited Company, which LinkedIn Help names as the provider of LinkedIn's services there2. LinkedIn describes the law as one of the most comprehensive pieces of online safety legislation ever drafted, and says it calls for heightened transparency, greater controls for users and additional accountability from online platforms14. Patrick Corrigan, VP of Legal - Digital Safety, wrote in August 2023 that LinkedIn had been working for over a year to get ready14. He also wrote that LinkedIn welcomes laws like the DSA because they codify online safety practices it says it has always supported4.

LinkedIn's DSA materials include a systemic risk assessment, an independent audit and an internal compliance function35. DSA Article 34 requires the assessment, and each LinkedIn report sets out its results, the mitigation measures put in place under Article 35(1) and the consultations held to support it36. The reports describe risk for the LinkedIn platform and services as a whole and also address risks or mitigations that apply to specific products36. The independent auditor's report checks whether the risk assessment process was properly reported and whether mitigation measures are tailored to the severity and likelihood of the risks identified5. It also describes a DSA Compliance Function whose responsibilities include cooperating with Coimisiún na Meán and the European Commission and helping ensure that Article 34 risks are identified and that reasonable, proportionate mitigation measures are taken5.

LinkedIn makes DSA information public through reports it posts and through research access described on LinkedIn Help27. LinkedIn Help lists its transparency reports as published under Articles 15(1), 24(1)-(2) and 42(1)-(3), as zip or csv files2. Under Article 42(4), LinkedIn also publishes its systemic risk assessment reports with mitigation measures, the external audit report and the audit implementation report2. LinkedIn Help also says Article 40 of the DSA includes a requirement to enable research on public data and content, and in some cases on private data and content once the appropriate EU regulator has authorized it7. LinkedIn says it may limit the personal data it provides, gives researchers only what a project reasonably needs, and does not allow outside researchers to run tests on members7.