December 14, 2018

Civil Society Stakeholder Analysis

We have mapped relevant stakeholders within civil society in Europe who are active within the digital policy arena. Our aim was to get a better understanding of which digital issues are important to civil society organisations and how they frame these issues. This will help us find a new overlapping framework that would replace the imposed Digital Single Market narrative within which civil societies are now forced to fit their agenda. Our assumption is that an alternative frame would allow civil society to discuss digital issue in a way that aligns with their (public) mission and goals.

In order to understand the current issues that are put forward by civil society organisations, we have mapped the key digital policy issues, the key policy positions and the key policy documents on these issues. In this piece we share our methodology, the results and our reflection on the outcomes.


We used the following methodology to map organisations, issues and key policy documents. We limited our mapping exercise to civil society organisations that work on the European level such as European organisations, think tanks and corporations. By an organisation working at EU level we mean organisations that have actively participated in any form in EU policy making related to the Digital Single Market strategy, for example: published a policy paper, took part in consultation or took part in an event related to the DSM. Due to practical limitations, we have only considered organisations that communicate in english. We have selected all entities that fulfilled these criteria from the participants list of RightsCon 2017 which was the largest conference on digital issues held in Brussels.

Our objective was not to have a full analysis of all relevant policy positions on every digital issue - this should be a next step in a follow-up research. Here, we aimed to map key organisations, issues and identify key documents so that we would be able to categorize the needs and perspective of these organisations.


After analyzing and filtering 152 organisations, we were left with 85 organizations that fulfilled above mentioned criteria. You can find the results of our mapping exercise in this document. Within column A you find the list of the key organizations. In column B we have indicated whether an entity is an european ngo, an international ngo, a corporation that falls within the business sector, a representatives of sectors or a university. Column C includes - when available - their policy goal. Column D describes the policy areas where they are active. Lastly, Columns E and F list the most relevant documents in relation to digital policy.

This data shows a wide range of issues organisations are working on, such as digital security, open source, copyright, machine learning, women’s empowerment and (digital) human rights.


After looking at the results of our mapping excercise, we were able to split the organisations into six new categories. These categories will help us understand the main approaches that exist within the area of digital policy. Per category, we will briefly describe what issues organisations are working on, what influences their strategy and the motivations behind working on digital policy.

The six categories are:

  1. organisations representing public entities;
  2. organisations that are part of the open movement;
  3. technology companies;
  4. organisations representing industry interest;
  5. organisations that work on (the impact of technology on individual to) human rights;
  6. universities.

1 organisations representing public entities

Firstly, you have organisations representing public entities, mostly sectors relating to culture, cultural heritage, museums, libraries, music or science. Examples are organisations such as EBLIDA (European Bureau of Library Information and Documentation Associations) and NEMO (Network of European Museum Organisations). The organisations are usually representatives of members and have a mandate to present policy positions on behalf of them.

These organisations’ strategy and vision are tied to the interests of their organizations. They take any measure that comes from the EU into account, including the Digital Agenda for Europe and the Digital Single Market Sector and often have made the Digital Single Market a specific part of their work plan. For instance, EBLIDA, like others, explicitly names the DSM in their strategy document for 2016-2019.

Cultural organisations that fall within this category reflect on the impact of digitalisation and technology on their sector. NEMO states in their policy statement that ‘NEMO believes that the digital shift has had a significant impact on society, and museums have a role to play in this process.’’

Cultural organisation also emphasize the non-commercial aspect of their sector and the value of their sector to the society, in particular in contributing to agendas on health, social justice, poverty, education, tolerance and understanding.[1] Underlying principles of the cultural organisations are promoting creativity and enabling access to information and culture. Most of their policy positions related to digital issues ask to rethink current local, national and regional (digital) policies to facilitate access to information. It is important for cultural organisations to be recognized as ‘Europe’s knowledge, culture and learning institutions’.[2] Therefore, they are not economically motivated in digital policy, but consider working on digital policy as a means to reach a greater public objective.

2 organisations that are part of the open movement

Secondly, you have organisations that are part of the open movement such as Creative Commons and the Wikimedia Foundation. Common themes within this group are access, reuse, Open Education, Open Access, Open Science, Copyright reform and the Commons. These organisations promote sharing of creativity and knowledge and a healthy internet.

While some of these organisations clearly focus on opening up data, information online or the internet in general, such as Open Knowledge International and Open Media, others also apply the principles of collaboration and sharing to wider issues. For instance Open Forum Europe seeks to open culture, not only online, but by building collaborative communities and measures.[3] The Commons Network takes it a step further and advocates for a ‘ “commons” approach that holds the potential for a unified vision towards an alternative economy, a Europe from the bottom-up, and an ecological economy and way of life’.[4] By organisations like the latter, digital issues are made an integral part of a larger ideology and policy position.

3 technology companies

Thirdly, there are technology companies such as Google and Mozilla. While these organisations are clearly not part of civil society which is the focus of our stakeholder analysis, they do interact with civil society, have participated in RightsCon17 and therefore we have included them in this exercise.

Organisations within this category usually focus on competition, innovation and (de)regulation of technologies. Unfortunately, the big technology companies are not very open about their vision and strategy when it come to digital policy within Europe. We could only find some information about Microsoft’s policy. Microsoft published a report on the future of Artificial Intelligence. In it they argue that it is important that governments update and enhance privacy law, competition law and liability schemes to make sure to ‘balance support for innovation with the need to ensure consumer safety’.[5] Further research would need to be done to get a better understanding of their interests, positions and strategy.

4 organisations representing industry interest

Fourthly, we have organisations representing the tech industry. Generally, they focus on issues that are very close to the framing of the Digital Single Market. They focus on supporting competition and enabling a climate for innovation,[6] especially for startups. Their policy positions are intended to improve the economic situation of the organisations they represent. They believe that ‘vigorous competition, freedom of expression, and openness is a natural product of the understanding of what has helped our industry thrive, and what it needs to continue to do so.[7]

5 organisations that work on (the impact of technology on individual) human rights

There are organisations that work on the impact of technology on individual human rights such as Amnesty International, UNICEF and Article 19. Most human rights organisation focus on fundamental individual rights. Digital issues can be part of these focusses. Regarding digital rights, they mostly focus on freedom of expression, privacy and security,[8] because the implications of not having these rights is the most severe for individuals. They mainly focus on civil and political rights, and less on cultural rights or third-generation human rights such as group and collective rights in relation to digital issues. While they focus on individual rights, they connect these rights to principles such as democracy, freedom, transparency and the rule of law. The narrative human rights organisation put forward is strongly tied to formal structures such as international law treaties and the Sustainable Development Goals.[9]

6 universities

While universities generally do not have policy goals that they want to achieve with their research, academics and their institutions do participate in public debate around digital issues. They sign and send Open Letters to policy makers in which they give advice based on their expertise. Academics generally do not want their work to be seen as being politically motivated, but merely objectively constructed.

The influence of universities is an interesting development. Especially since, for instance in the debate around the DSM Directive, the criticism from academia was generally ignored by policymakers.

A common framework

For our purpose we chose a sample that would included a wide variety of civil society organizations. With our analysis we have received a better understanding of how organisations put themselves forward and for what aim. Civil society organisations in generally react on policy making and do not seem to elicit policy proposals.

As technology organisations and organisations representing industry interests interact with civil society, we have included them in this analysis. Further research would need to be done about them in which they are the main focus to get a better understanding of their interests, positions and strategy.

The organisations from all categories work on related issues, their perspective, background and approach differs significantly. Open movement organisations and public sector organisations are connected in the sense that most of them try to encompass digital policy issues in a narrative that explains how they fit in a larger narrative on in what society we (should) want to live in. They look at the interaction of online and offline spheres and sometimes don’t even make the distinction between online and offline at all.

Human rights organisations understandingly look at digital issues as an integral part of human rights framework. However, they differ strongly from public sector and open movement organisations in which they look at it from an individual rights perspective, when the other organisations try to find communal solutions for society instead of focussing on the individual. It is not surprising that human rights organisations use formal structures such as international treaties to forward their argument, as these structures are familiar to policy makers in Europe. Public sector entities and open movement organisations lack such an all encompassing frame in which they can place themselves in.

While organisations of the first, second and fifth groups often work together on overlapping issues, a common framework or perspective on digital issues seems to be lacking across the categories we have distinguished. At the same time we believe that when looking at the interests of these organisations an alternative frame that emphasise the importance of non-commercial societal values can benefit all organisations mentioned except for the industry focussed organisations and technology companies. While it remains unclear what the most important issues and strategy are of the latter, on the surface the current market framework already seems to be aligned with their general interests such as competition and innovation (albeit that the issues discussed within the market frame have not always benefited the industry looking at, for instance the outcomes of the Directive on copyright in the Digital Single Market).

Civil society organisation would benefit from a wider narrative on digital policy in which they can all position themselves. It is in the interest of these organisations to be able to talk about digital issues without being confined to a market or economic narrative. Public values, individual rights and the integration of digital policy into wider policy are important objective to them, that could be more easily fulfilled with an framework that would connect digital policy with society and not just the market.

  1. See Nemo, Policy Statement ↩︎

  2. For instance see ‘Take down the digital barriers!’ by Eblida and IFLA’s Strategic Direction 2 ↩︎

  3. See ‘Towards an Open Digital Single Market, an OFE vision Paper (2015), p. 3 ↩︎

  4. See Commons as a Unifying Political Vision, Sophie Bloemen ↩︎

  5. See 'The Future Computed - Artifical Intelligence and its role in society', Microsoft, 2018, p. 84 ↩︎

  6. See CCIA’s Mission and EUROispa’s mission statement ↩︎

  7. See CCIA’s Mission Strategy ↩︎

  8. For instance EDRi focusses on privacy, surveillance, net neutrality and copyright reform. ↩︎

  9. See Sustainable Development Goals ↩︎