Auditing African Content Moderators' Working Conditions by Using the European General Data Protection Regulation (GDPR)

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Authors: Mariame Tighanimine, Jessica Pidoux, Sonia Kgomo, Kauna Ibrahim Malgwi, Richard Mwaura Mathenge, Mophat Okinyi, James Oyange
Cited by: 1
References: 125

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