James Shires is an Assistant Professor in Cybersecurity Governance at the Institute of Security and Global Affairs, University of Leiden. He is a Fellow with The Hague Program for Cyber Norms and the Cyber Statecraft Initiative at the Atlantic Council. He has written widely on issues of cybersecurity and international politics, including on cybersecurity expertise, digital authoritarianism, spyware regulation, and hack-and-leak operations. He is the author of The Politics of Cybersecurity in the Middle East (Hurst/Oxford University Press 2021).

Twitter: @jamessshires

Website: www.jamesshires.com

Dr. Judith Möller. As a social scientist trained in a wide range of methods, Möller compliments the consortium both on a theoretical and methodological level. Through her expertise the consortium can ensure valid testing of the impact of the phenomena observed using computational methods. On a theoretical level, the dialogue between CS, law, and social sciences ensures that the analysis of features of the landscape and consequences of disinformation is inclusive and valid. In 2019 she was awarded a VENI talent track grant by the Dutch Science Foundation (NWO) and is the recipient of the Baschwitz Article of the Year Award in 2018. She has co-written reports for the Dutch media regulator (CvdM), the Council of Europe, and is currently writing a report on types of disinformation for a German media regulator.

Dr. Ronan Ó Fathaigh is a Senior Researcher at the Institute for Information Law (IViR), University of Amsterdam, specialising in online platforms, disinformation and fundamental rights (freedom of expression and privacy). Ronan published widely on these topics in international academic journals, and has co-written reports for the Dutch Ministry of the Interior and Kingdom Relations (BZK) on the legal framework applicable to online disinformation, and for the Dutch Ministry of Economic Affairs (EZ) on the regulation of online platforms.  He is also an Expert member of the Columbia Global Freedom of Expression collaboration at Columbia University.

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Prof. Dr. Frederik Zuiderveen Borgesius is Professor ICT and Law at Radboud University Nijmegen, where he is affiliated with the interdisciplinary research hub on Security, Privacy, and Data Governance: the iHub. His research interests include privacy, data protection, and discrimination, especially in the context of new technologies. He has published widely on privacy, behavioural advertising, online political microtargeting, and more generally on protecting fundamental rights in the context of new technologies. He is a recognized expert on such topics, and has written reports for e.g. the Dutch Ministry of Justice, the European Parliament, and the Council of Europe.

This paper concerns the problem of political disinformation, defined as deliberately circulating verifiably false information for political goals. Political disinformation can erode confidence in experts, manipulate democratic procedures, degrade the public sphere, and advance adversarial goals of foreign states. This paper focuses on one particular set of actors: commercial companies in the public relations, strategic communications, and lobbying sectors. Although these organizations are a well-recognized part of specific instances of disinformation, most analyses treat such actors as relatively simple conduits between the interests of the original disinformation actor and the social media networks where disinformation is distributed and consumed.

This paper suggests a new approach to such actors as what we call “creative commercial intermediaries” for disinformation. The paper is exploratory in nature, with two related research questions that together set out the research agenda for future work. First, the paper asks: how can we define creative commercial intermediaries for political disinformation, and how can we differentiate them from other actors in this space? The second research question regards appropriate responses. What are the current regulatory and policy instruments applicable to disinformation activities conducted by creative commercial intermediaries, and how do they relate to the wider industry, including social media platforms?

The paper provides illustrative examples of creative commercial intermediaries in open sources, drawing on news media and technical reports to identify common elements such as sector, size, ownership, geographical location, legal jurisdiction, and branding. We then briefly survey the current regulation and policy applicable to disinformation, creative commercial intermediaries, and social media platforms, discussing their strengths and weaknesses in a provisional manner only – further in-depth research is required for detailed application. Disinformation-as-a-service, we argue, not only presents a difficult regulatory problem in itself, but is at the centre of broader crises in democratic accountability and governance in digital media.

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