NGOs

The Norwegian Consumer Council is an organisation which oversees consumer issues across various markets in Norway. It is very active against dark patterns and publishes its findings and resources on deceptive and cunning design in a segment of their website which may be found here. In their ‘Deceived by Design’ report, they chronicle how tech companies utilise dark patterns to prevent users from exercising their rights to privacy. Their work includes: Enough deception! Norwegian consumers’ experiences with deceptive design (2022) Insert coin: How the gaming industry exploits consumers using loot boxes (2022) You can log out, but you can never leave: How Amazon manipulates consumers to keep them subscribed to Amazon Prime (2021) Deceived by design: How tech companies use dark patterns to discourage us from exercising our rights to privacy (2018) Complaints are accepted in English and Norwegian

The BEUC has played a part in the fight against dark patterns by giving feedback on the ‘Guidelines 3/2022 on Dark Patterns in Social Media Platform interfaces: How to Recognise and Avoid Them’, where they push for privacy-by-default principles to be upheld, reiterating that refusing consent should be as easy as giving consent, and also offering practicable recommendations on how these laws can be better enforced and reformed. Some of their work includes: ‘Dark Patterns and the EU Consumer Law Acquis’ (2022) Presentation on the negative effects of dark patterns on the consumer and the digital single market at large (2022)

None of your business’ is an EU- focused nonprofit whose activity against dark patterns includes not only research endeavours and raising awareness, but also filing complaints against erring organisations and companies. They have in the past instituted 422 formal GDPR complaints against websites featuring cookie banners which employed dark patterns to gain user consent. Noyb also responded to the EDPB’s call for feedback on the Guidelines 3/2022 on Dark Patterns in Social Media Platform interfaces: How to Recognise and Avoid Them. Its project on dark patterns which raises awareness, takes legal steps, and reaches out to erring organisations about their shortcomings have led to an increase in compliant cookie banners. noyb’s comments on the Draft Guidelines 3/2022 on Dark Patterns In Social Media Platform Interfaces: How To Recognize And Avoid Them (2022) Cookie Banners Project (2021-) noyb files 422 formal GDPR complaints on nerve-wrecking “Cookie Banners” (2021) noyb has an ‘Exercise Your Rights’ series which informs users about their rights and ways to enforce them.

Founded on the ideals of open, safe, and empowering access to the web, the Web foundation has actively worked against dark patterns through raising awareness and other activities including hosting a hackathon focused on solutions to dark patterns in fields such as e-commerce, e-transactions, and flight aggregation platforms. These Initiatives provide an environment for experts, regulators, and other stakeholders to participate in building a suitable legal framework for dark patterns. In collaboration with stakeholders across Africa, they developed a policy brief which can be adopted by regulators the world over in tackling dark patterns. Its Tech Policy Design Lab also aims to conduct a range of workshops to design policies and prototypes to tackle deceptive designs and publishes takeaways of its workshops on the Design Lab’s website. World Wide Web Foundation Tech Policy Design Lab on Dark Patterns