Auditing African Content Moderators' Working Conditions by Using the European General Data Protection Regulation (GDPR)
Abstract
In this article, we audit the working conditions of content moderators in Kenya and Nigeria employed by business process outsourcing (BPO) companies by using the European General Data Protection Regulation (GDPR). We demonstrate its extraterritorial scope for gaining access to elements such as employment contracts and NDAs that have never been provided to the workers concerned. The results of this approach provide legally grounded evidence of the structural disadvantages faced by content moderators in the Global South, whose exploitative working conditions violate workers' rights. Our work also highlights the benefits of legislation aimed at protecting individuals' data rights as a counterweight to the tech industry's discourse of exceptionalism, which obscures its dependence on BPOs to externalise labour costs and accountability, whilst claiming that its products, business models, and methods of resource extraction are unprecedented and fall outside any existing legal framework.
Fields of Study & Subjects
Global trade
sustainability
and social impact
Cybersecurity and Cyber Warfare Studies
Copyright and Intellectual Property
Publication details
- Journal / source
- Proceedings of the 2026 ACM Conference on Fairness, Accountability, and Transparency
- Publisher
- ACM
- Pages
- 8009–8028
- Publication date
- 23 June 2026