Dr. Cristiana Teixeira Santos

Assistant Professor
International and European Law
c.teixeirasantos@uu.nl

Impact

  • March 2024: I gave an interview to the NRC on the recent CJEU decision on IAB Europe TCF and its impact on adtech industry
  • March 2024: Our work on Real Time Bidding and IAB Europe TCF was cited by The Register. Link and paper
  • February 2024: Our work on the ''Pay or Okay'' was cited in an open joint letter signed by 27 civil rights organisations, urging the EDPB to oppose to the 'pay or okay' model. 
  • December 2023: Our work on the pay-or-ok model was cited in a ''Pay or Okay'' complaint against META to the Spanish Data Protection Authority! 
  • November 2023: Our work on dark patterns was cited in the study report of the US California Consumer Privacy Act. 
  • November 2023: Our work on the pay-or-ok model was cited in the Noyb's ''Pay or Okay'' complaint against META to the Austrian Data Protection Authority! 
  • May 2023 - We launched a database of case law on deceptive design: deceptive.design/cases 
  • April 2023 - Our work on Dark Patterns and Legitimate interest legal basis was presented at the regulator CNIL (French Data Protection Authority) at the event Privacy Research Day 2023. Link and paper 
  • March 2023 - Our paper "Two Worlds Apart: Closing the Gap Between Regulating EU Consent and User Studies" was presented at the Harvard Law School conferece "Beyond the FTC: The Future of Privacy Enforcement". Link 
  • January 2023 - Our work on Dark Patterns and tracking was cited in the EU Commission report "Study on the impact of recent developments in digital advertising on privacy, publishers and advertisers",  Link and paper 
  • January 2023 - Our work on IAB TCF “Impossible asks: Can the TCF Ever Authorize Real-Time Bidding After the Belgian DPA Decision ” was also cited by the EU Commission report "Study on the impact of recent developments in digital advertising on privacy, publishers and advertisers", Link and paper 
  • October 2022 - Our work on Paywalls entitled " Your Consent Is Worth 75 Euros A Year – Measurement and Lawfulness of Cookie Paywalls " was covered by the Gizmodo (Link) and was in a podcast by Dataskeptic.  This paper was presented at the 2022 Workshop on Privacy in the Electronic Society (WPES) in November. Link and paper.
  • August 2022 - Our work on the legal and empirical analysis of the IAB Europe TCF was covered by the Decareto company in their report on the lawfulness of this standard. Link and Paper.
  • June 2022 - Our work on Dark patterns and legal compliance of consent requests was covered by the EU Commission study  "Behavioural study on unfair commercial practices in the digital environment-Dark patterns and manipulative personalisation" Link
  • April 2022 - Our work on Dark Patterns and the Legal Requirements of Consent Banners: An Interaction Criticism Perspective was covered by the UK Competition & Markets Authorithy (CMA). Link and paper
  • April 2022 - Our paper "My Cookie is a phoenix: detection, measurement, and lawfulness of cookie respawning with browser fingerprinting" was covered by LeMonde.fr, La-rem.eu. Paper
  • April 2022 - Our work on In-Depth Technical and Legal Analysis of Tracking on Health Related Websites with ERNIE Extension   was covered by Le Monde. Link and paper
  • April 2022- Our work on “ Impossible asks: Can the TCF Ever Authorize Real-Time Bidding After the Belgian DPA Decision ” was covered by EDRI regarding the IAB TCF decision. Link
  • February 2022 - The Belgian Data Protection Authority ruled a decision that IAB Europe's TCF is non-compliant with the GDPR and imposed a fine of 250K euro. Our research on Consent Management Platforms (CMPs), Cookie Banners   and Dark Patterns was used in the investigation and cited multiple times in the final decision of the Belgian DPA. Link 
  • January 2022 - Our paper on Consent Management Platforms (CMPs) was cited by ENISA. Link 
  • Our paper on privacy and smart tourism destinations was cited by the EU Commission study "Study on
    Mastering data for tourism by EU destinations" Link and paper 
  • July 2021 - We were interviewed by the Vice on Dark Patterns , named ' It's Bad Design On Purpose' – Why Website Cookie Banners Look Like That? Link
  • June 2021- I spoke at the conference “ What can the ePrivacy Regulation do against Dark Patterns ” together with Maryant Fernandez (BEUC), Peter Eberl (European Commission), and Christian Drews (Dapde project). Link
  • July 2020 - We were interviewed by the French Data Protection Authority (CNIL) about our work on user's consent by the IAB Europe's Transparency and Consent Framework (TCF) Link

Contributions to stakeholder public consultations

I have provided feedback to:

  • French Data Protection Authority draft recommendation on “cookies and other trackers”  in 2020 (link)
  • Italian Data Protection Authority  on guidelines on the use of cookies and other tracking tools in 2020 (link)
  • European Data Protection Board (EDPB) guidelines on the concepts of controller and processor in
    the GDPR in 2020 (link)
  • European Data Protection Board (EDPB) guidelines on “Dark patterns in social media platform interfaces: How to recognise and avoid them” in 2022 (link
  • European Data Protection Board (EDPB) guidelines on the Right of Access in 2022 (link
  • European Data Protection Board (EDPB) guidelines on technical scope of Art. 5(3) of ePrivacy Directive in 2024 (link)
  • European Commission Report on the General Data Protection Regulation on the use of paywalls in 2024 (link)