ADM+S researchers contribute evidence to Digital Duty of Care inquiry
Author ADM+S Centre
Date 11 November 2026
Researchers from the ARC Centre of Excellence for Automated Decision-Making and Society (ADM+S) appeared before a Senate committee hearing examining Australia's proposed Online Safety Amendment (Digital Duty of Care) Bill 2026 on 10 November.
Professors Daniel Angus (QUT), Christine Parker (University of Melbourne), Nicholas Carah (The University of Queensland), and Kimberlee Weatherall (The University of Sydney), were invited to provide expert evidence to the inquiry, drawing on their extensive research into digital platforms, online governance, regulation and the societal impacts of automated systems.
Current Australian online safety laws largely rely on a reactive complaints and content-removal model, placing responsibility on users to report harms after they occur.
The proposed Digital Duty of Care would instead require online service providers to take proactive steps to identify, prevent, and mitigate harms arising through their services.
In their written submission to the inquiry, ADM+S researchers argued that the Digital Duty of Care presents an important opportunity to address the changing nature of online harms, require safety-by-design in online services, and ensure that online services and their impacts can be independently observed, evaluated, and held to account.
During the hearing, researchers highlighted three important elements of effective digital regulation: independent scrutiny of platforms, meaningful access to data for research, and stronger accountability mechanisms for people and businesses experiencing harm.
Building an ecosystem of transparency and observability
Professor Daniel Angus highlighted the need for practical, independent, and sustained research access, explaining that existing transparency reports and platform research tools provide only a partial picture of how digital platforms operate.
Using online advertising research as an example, he described how the Australian Ad Observatory enables researchers to examine not only individual advertisements but also the sequence of advertising people encounter across platforms including Facebook, Instagram, TikTok, and YouTube.
Professor Angus recommended that platforms make all advertisements available for independent scrutiny and retain them for at least three years. He also highlighted the importance of data donation methods, allowing people to share their personal information for research purposes, and pointed to the Australian Internet Observatory as crucial research infrastructure supporting independent platform observability.
“What we really need is an ecosystem here to ensure that the regulation works as intended – it can’t be left just to the regulator themselves,” Professor Angus told the committee.
He advocated for a graduated approach to research access, combining public transparency, user-controlled data donation and more extensive data access arrangements to help researchers understand platform activity and evaluate regulatory effectiveness.
Enabling independent research into online advertising
Professor Nicholas Carah emphasised the importance of enabling researchers to investigate how people are targeted by online advertising, including examining content and practices that are not publicly visible.
He described the Bill’s data access provisions as an important development. The bill could open the way for researchers to have protections and access to enduring content libraries, donation of personal data and simulated testing of platform algorithms using researcher-controlled accounts (sometimes known as sock puppets). Together with provisions to request data from platforms, these measures would enable researchers to independently and rigorously study online safety and risk.
Professor Carah recommended clarifying these provisions to ensure they provide researchers with effective access to the information needed for independent investigation.
Strengthening accountability and access to remedies
In their joint opening statement, Professors Christine Parker and Kimberlee Weatherall supported the proposed Digital Duty of Care’s shift towards an outcomes-based approach, arguing it is better equipped to address broader, systemic and emerging online harms than approaches focused on individual pieces of harmful content.
However, they recommended strengthening protections for adults by explicitly addressing harmful design features and cumulative harms, which can arise through the interaction of content, recommendation systems, and commercial incentives.
They also emphasised the importance of ensuring risk assessments go beyond procedural or box-ticking exercises, and of support for independent research to evaluate whether platforms are effectively identifying and mitigating risks.
Professor Christine Parker highlighted the need for individuals and businesses harmed by digital platforms to have avenues for seeking remedies, rather than relying solely on the eSafety Commissioner to enforce the proposed duty.
She supported including a private right of action to allow those experiencing loss or damage to seek remedies, alongside an ombudsman or external dispute resolution scheme to provide additional avenues for resolving complaints.
The researchers’ evidence highlights the importance of independent research, meaningful access to platform data, and effective accountability mechanisms in ensuring the proposed Digital Duty of Care delivers meaningful protections for Australians.
Read the ADM+S submission to the inquiry.
Watch the Senate Environment and Communications Legislation Committee hearing (10 November 2026).
