SNIP – Self-assessment Network Impact Program


Considering the characteristics and goals of the currently in-development European Digital Strategy, the SNIP Project aims to develop a self-assessment programme for stakeholders to assess users’ vulnerabilities by design and by default in compliance with the newly enacted Regulations approved as part of the EU Digital strategy, with a particular focus on obligations arising from the recently approved Digital Services Act and the Digital Markets Act.


Data-driven technologies undoubtedly help to improve users’ experience in the digital environment. Nonetheless, they also bring new risks and challenges. Risks related to unregulated abuse of these techniques are significant and can lead, e.g., to violations of users’ data protection and privacy, unjust discrimination based on protected grounds, manipulation of users’ decision-making, and exploitation of vulnerabilities.

In order to tackle these risks, the EU Digital Strategy aims at striking a balance between profitability from a genuinely competitive data economy and individuals’ protection. In this scenario, the European Union has adopted a set of regulations to harmonize digital intermediary services framework and to ground a safe, predictable, and trustworthy online environment. Accordingly, the recently approved Digital Services Act (DSA) establishes risk-mitigating obligations for providers of intermediary services and online platforms, such as social media and marketplaces, with a major focus on Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs).

The obligations set in the DSA are heterogeneous and involve liability rules, transparency and reporting requirements, rules on due diligence for intermediaries and online platforms for third-party contents (including a notice and take-down system), redress and audit procedures.

Whereas legislators expect that the DSA will provide a level playing field by fostering competition in online markets and, at the same time, advancing user protection in the digital environment, the current state of the art unveils significant uncertainties: the absence of effective tools for conducting the monitoring and supervision of companies’ compliance with the DSA and to assess its rules’ effectiveness in preventing the exploitation of users’ vulnerabilities create major regulatory uncertainties that can frustrate the goals of the overall digital strategy. The current lack of standardised procedures to evaluate the respect of the DSA, as well as the absence of tools to identify and extirpate the vulnerability drivers that platforms might create, is therefore a substantive obstacle in the attempt to establish an ethical, transparent, fair, explainable, and overall accountable operativity of digital platforms.

The project, participated by legal scholars aims at developing a self-assessment tool that will foster DSA compliance and the establishment of best practices within the platform market and empower users in the digital environment by increasing their awareness on risks and their protection by design and by default.


SNIP is conducted by a two-university team including the University of Bari “Aldo Moro” and the Sant’Anna School of Advanced Studies (Pisa). The Project is coordinated by two under 40 internationally recognised researchers whose expertise and interests are perfectly matching SNIP goals. The research team are carefully identified in order to be able to handle the different activities that the project entails and demonstrate a high-level international expertise in the various investigated fields.

Antonio Davola serves as PI and head of the UniBa Unit, and Caterina Sganga – Associate Professor of Private Comparative Law at Sant’Anna – acts as head of the SSSA Research Unit and associated PI.