Recognising and Enabling the Collective Dimension of the GDPR and the Right of Access A call to support the governance structure of checks and balances for informational power asymmetries

The digitisation and datafication of European society necessitate a robust ecology of transparency to enable scrutinising and challenging digital infrastructures that govern our lives. The GDPR – and its transparency provisions in particular – play a vital role in this pursuit. Crucially, in light of the strong informational power asymmetries in the digital society, the effectiveness of GDPR transparency measures will depend on their collective use. This contribution -- submitted as feedback to the European Commission’s two-year evaluation of the implementation of the GDPR -- aims to highlight this collective dimension of GDPR access rights, emphasising their potential for social justice (with a rich list of real-life examples in the Annex) and the requirements for rendering them effective. We hope the European Commission takes this contribution as a call to action for creating an enabling environment for collective access rights: empowering all actors in the GDPR’s ecology of transparency, and unlocking the full potential of the GDPR in safeguarding a fair digital society.