Dark by design: regulating manipulation in online environments


  • Arianna Rossi


  • Frederik Zuiderveen Borgesius
  • Estelle Hary
  • Anne-Jel Hoelen
  • Ailo Ravna
  • Geoffrey Delcroix

Organisation: SnT, University of Luxembourg

Room: Online 4

Timing: 14:15 - 15:30 on 28 January 2021

Online services are scrupulously designed to offer the best experience to their users, accommodate their needs and direct their actions towards desirable outcomes. Yet, online services can also use manipulative design strategies to circumvent the tenets of transparency, fairness, and data protection by design. Such strategies are known as “dark patterns”. They can restrict the number of available choices to trick users into accepting privacy-invasive features or make it overly difficult to access, transfer or erase personal data, thus hindering data subjects from exercising their rights. Dark patterns create an unequal playing field, where some companies illegitimately gather massive amounts of personal data. This panel will discuss possible interventions, including regulatory decisions interpreting data protection principles, guidelines on best design practices, awareness-raising initiatives, and empirical studies demonstrating the influence of manipulative designs.

• How pervasive are manipulative designs in online services and what is their impact on users?
• Which tools, skills, and resources are needed to support the enforcement of rules that regulate manipulative designs ?
• Which incentives might encourage businesses to prefer fair designs over dark patterns?
• How might we design interventions that enhance people's ability to protect themselves from online manipulation?


Arianna Rossi

SnT, University of Luxembourg (LU)

Arianna Rossi is a research associate at the Interdisciplinary Center for Security, Reliability and Trust (SnT) of the University of Luxembourg. Her main expertise is in human aspects of privacy, transparency, choice architecture, legal design, and online trust. Arianna has a mixed background, with a joint international Doctoral Degree in Law, Science and Technology (University of Bologna) and a Ph.D. degree in Computer Science (University of Luxembourg). She has been an invited speaker at international conferences and routinely gives seminars at European universities, while she also organizes events on legal innovation.


Frederik Zuiderveen Borgesius

iHub & iCIS Institute for Computing and Information Sciences, Radboud University Nijmegen (NL)

Prof Frederik Zuiderveen Borgesius is Professor ICT and Law at Radboud University Nijmegen, where he is affiliated with the Institute for Computing and Information Sciences, and with new interdisciplinary research hub on Security, Privacy, and Data Governance: the iHub.

Estelle Hary


Anne-Jel Hoelen

Authority for Consumers and Markets (ACM) (NL)

Anne-Jel Hoelen is a Laywer / Senior Enforcement Official at the Netherlands Authority for Consumers and Markets (ACM). She focuses on the protection of consumer rights in the digital economy end participates in several European e-enforcement projects. The interplay of consumer protection, data protection and competition law has her special attention as well as online unfair commercial practices and media an commercial communication related issues. Before ACM she works at SRC (self-regulation of advertising) and at SOLV, a law firm specialized in technology, media and communications law) and had a career in the media and entertainment industry.

Ailo Ravna

Norwegian Consumer Council (NO)

As a researcher and senior policy advisor at the Norwegian Consumer Council, Ailo has been a central part of the organization's work on data protection, privacy, cybersecurity, and consumer rights. This work has included comprehensive reports on dark patterns, the adtech industry, and the internet of things, and has led to legal complaint against Google for applying dark patterns, and complaints against Grindr and five adtech companies. These projects have also involved the European Consumer Organization (BEUC) and the Trans Atlantic Consumer Dialogue (TACD).

Geoffrey Delcroix

Ubisoft (FR)

Geoffrey is Head of legal innovation at Ubisoft, a leading creator, publisher and distributor of interactive entertainment and services, with famous video games like Assassin's Creed, Far Cry, Rabbids, Just dance, ... Before joining Ubisoft in 2019, Geoffrey co-founded LINC, the innovation and foresight laboratory of the french Data protection Authority (CNIL). He is a professional futurist and innovation manager.