1. What does the Act provide for illegal content?

The Act establishes a set of uniform measures across the EU to ensure the detection, and removal of illegal content, for example, child sexual abuse material, hate speech, unsafe or counterfeit products, non-consensual sharing of private images (photos, videos), and non-authorised use of copyright protected material.

According to the Act, providers of intermediary digital services are obliged to:

• Provide the ability to users to report illegal content through user-friendly tools/mechanisms,
• examine the above-mentioned reports and inform users of their decisions, as well as of the possibility to challenge them,
• publish annual reports on the content moderation in which they engage,
• include clear information in their terms and conditions about any restrictions they impose (e.g., policies, procedures, and measures/tools used for content moderation).

What constitutes illegal content is defined by EU and national legislation. If content is considered illegal in only one Member State, it is generally removed only within that specific territory.

2. Whom should I contact to report illegal content? What is the “notice and action mechanism”?

It is recommended that you immediately report any illegal content you have identified to the intermediary service provider.

The provider must provide you  a way to report illegal content through a user-friendly “notice and action mechanism,” in accordance with Article 16 of the Act.

The mechanism must facilitate the collection of the following information, based on which the provider will decide whether to remove the content or disable access to it:

• The reasons why you consider the content to be illegal.
• The location (e.g., URL) where you identified the specific content.
• Your name and email address. This information is not required when the content includes Child Sexual Abuse Material (CSAM).
• A statement that the information in your notice is accurate and complete.

After reporting illegal content, the provider is obligated to send you confirmation of receipt of the notice without undue delay. Based on the information provided, the provider shall take  a decision about the allegedly illegal content in a timely, diligent, and objective manner. Providers shall inform you without undue delay about:

• the decision taken regarding yournotice,
• the possibilities for appealing against the decision

3. I disagree with a provider’s decision regarding illegal content I reported.  To whom can I address my concern? What is the “complaint handling system”?

If you reported illegal content to a digital service provider and you disagree with the decision, it is recommended that you lodge a complaint against the decision taken by the provider.

The provider must have a user-friendly “complaint handling system” that allows you to lodge a complaint, electronically and free of charge against the decision taken by the provider

You have the right to lodge a complaint against the decision taken by the provider within 6 months from the date of the decision. The provider is obligated to inform you without undue delay about:

• the decision taken regarding your complaint, along with the relevant reasoning,
• the possibility of out-of-court dispute settlement and other available appeal options.

4. I disagree with restrictions imposed by a provider on content I posted or on my account. To whom can I address my concern?

You can file a complaint with the provider if any of the following restrictions were imposed on you, on the grounds that you have posted content that is illegal or incompatible with the service’s terms and conditions:

• The provider has removed/restricted the visibility of content you had posted or disabled access to it.
• The provider has partially or fully suspended or terminated the service it was providing to you.
• The provider has suspended/deleted your account.
• It has suspended/terminated/restricted your ability to receive payment for content.

The provider must have a user-friendly “complaint handling system,” in accordance with Article 20 of the Act, providing you the ability to lodge a complaint including the necessary information, electronically and free of charge.

You have the right to lodge a complaint with the provider within 6 months date of  the decision that imposed the restriction. The provider is obligated to inform you without undue delay about:

• the decision taken regarding your complaint, along with the relevant reasoning,
• the possibility of out-of-court dispute settlement and other available appeal options.

5. In which cases should I contact EETT? What actions does it take?

If the problem you are facing is related to any of the following issues, you can lodge a complaint with EETT by completing the online complaint form.

• Restrictions on communication with the provider of the intermediary digital service.
• Restrictions on the ability to report illegal content.
• Insufficient justification from the provider for blocking your account due to content you posted or for the deletion of the content itself.
• Restrictions on the ability to lodge a complaint with the provider.
• Difficulty in locating or finding the terms of use.
• Restrictions on providing information about the possibility of out-of-court dispute settlement or no cooperation during resolution process.
• Violations of obligations of intermediary digital service providers regarding the protection of minors.
• Misleading presentation of services.
• Violations of obligations regarding the way personalised recommendations for content and product purchases are configured.
• Violations of obligations regarding the way advertisements are displayed and targeted.

You are advised to consult EETT’s responsibilities (see General Information, Q. 3 and General Information, Q. 4).

The complaint shall contain all necessary information to support the alleged violation of the Digital Services Act, and include information about any prior written communication with the provider.

After submitting the form, you will receive confirmation of receipt.  EETT will then assess the complaint. If it is determined that the issue concerns a violation of the Digital Services Act, EETT will determine whether the complaint should be handled by itself or forwarded to another body, as appropriate:

• The National Council for Radio and Television (NCRTV), regarding the display of advertisements on online platforms (Article 26) and the adoption of measures for the protection of minors (Article 28).
• The Hellenic Data Protection Authority (HDPA), regarding the information provided to users on how advertisements are displayed and targeted (Article 26), as well as the protection of minors’ personal data (Article 28).
• The Digital Services Coordinator of the provider’s country of establishment, when its main establishment is not in Greece.
• The European Commission, transmitted by the Digital Services Coordinator of the provider’s  Member State of establishment, if the issue concerns  specific obligations of very large online platforms (VLOPs) / search engines (VLOSEs).

In the event that your complaint is forwarded to another body or does not concern a violation of the Digital Services Act, you will be duly informed.

Further details are available in Article 53 of the Act.