Recommender System
A recommender system is an automated system used by online platforms to suggest, rank, or prioritize specific content for users. These systems decide what information appears in your feed, search results, or recommendations based on algorithms that analyze user behavior, preferences, and other data.
Legal Basis
While Regulation 2024/900 does not define recommender systems directly, the Digital Services Act (DSA) provides the relevant framework:
"Recommender system means a fully or partially automated system used by an online platform to suggest in its online interface specific information to recipients of the service or prioritise that information, including as a result of a search initiated by the recipient of the service or otherwise determining the relative order or prominence of information displayed."
— Article 3(s), Regulation (EU) 2022/2065 (Digital Services Act)
Why It Matters
Recommender systems are critical to understanding how political advertising reaches voters online. Platforms use these systems to determine which political ads you see, how often you see them, and in what order they appear. This automated decision-making can significantly influence which political messages reach which audiences.
For political advertising transparency under Regulation 2024/900, recommender systems are particularly relevant when they use personal data for ad placement or delivery. The regulation restricts how platforms can use targeting techniques and ad-delivery techniques that rely on personal data processing. Even when a sponsor doesn't directly target specific voters, the platform's recommender system may still use personal data to optimize ad delivery, triggering the regulation's targeting restrictions.
Publishers of political advertising must understand how their recommender systems process data for political ad placement. Where these systems use personal data to determine who sees political ads or to optimize their reach, publishers must comply with the strict conditions in Chapter III of Regulation 2024/900. This includes obtaining appropriate consent and avoiding the use of certain sensitive data categories.
Key Points
- Automated content curation: Recommender systems automatically decide what content users see and in what order, using algorithms that analyze patterns in user data
- Beyond direct targeting: Even when advertisers don't explicitly target users, recommender systems may still use personal data to optimize ad delivery and reach
- Transparency obligations: Under the DSA, platforms must explain how their recommender systems work and offer users options to modify the main parameters
- Political ad restrictions: When recommender systems use personal data for political ad placement, strict rules apply under Regulation 2024/900's targeting provisions
- Multiple platform types: Recommender systems operate on social networks, search engines, video platforms, and other online services where political ads appear
- User rights: Recipients have the right to understand how recommender systems affect what political content they see and may have options to adjust settings
Recommender System vs. Targeting Technique
A recommender system is the broader automated system that a platform uses to suggest and prioritize all content for users, operating continuously across the platform. A targeting technique is a specific method used by advertisers or publishers to reach particular audiences with tailored messages, often as part of an advertising campaign.
The key difference: recommender systems are platform infrastructure that affects all content, while targeting techniques are specific strategies for audience selection. However, these overlap in political advertising when a platform's recommender system uses personal data to deliver or optimize political ads—this constitutes both the platform's recommendation function and an ad-delivery technique subject to Regulation 2024/900's restrictions.
| Aspect | Recommender System | Targeting Technique |
|---|---|---|
| Scope | Platform-wide content curation | Specific audience selection for ads |
| Primary regulation | Digital Services Act (DSA) | TTPA Regulation 2024/900 |
| Operator | Platform/publisher | Sponsor or provider acting for sponsor |
| Transparency required | Main parameters in terms & conditions | Full transparency notice for political ads |