Cambridge Research Proposal Example: Journalist to digital platform policy (Score 93)

When the UK Online Safety Act 2023 came into force, it imposed a duty of care on Category 1 platforms to protect recognised news publishers and, by extension, the journalists whose work those publishers carry. The Act requires platforms to publish transparency reports and maintain appeals mechanisms, but it leaves the substantive standard for enforcement largely to platform discretion. This creates a regulatory design problem: the statute sets a procedural frame while the operative norms—what counts as harassment of a journalist, what triggers content removal, what constitutes a meaningful remedy—are defined in platform community standards that Ofcom cannot directly rewrite. This proposal asks: to what extent do the self-regulatory commitments that major social media platforms make in their transparency reports and community standards align with the journalist-protection obligations imposed by the Online Safety Act 2023, and where misalignment exists, what regulatory mechanisms could close it? Two subsidiary questions sharpen the inquiry. First, are platform-stated commitments on journalist safety operationally consistent across enforcement decisions documented in transparency data? Second, do the Act's current accountability instruments—transparency reporting requirements and the super-complaints mechanism—give Ofcom sufficient purchase to detect and correct systematic under-enforcement? The question is tractable within an MPhil timeframe because it is bounded to a defined statutory instrument, a defined set of platforms subject to Category 1 designation, and a defined class of protected persons. It does not require primary fieldwork with at-risk journalists, which would raise access and ethics complications beyond the scope of a one-year programme. Two bodies of scholarship bear on this question but have not been brought into productive dialogue. The first is the platform governance literature. Tarleton Gillespie's work on content moderation as a constitutive rather than merely reactive practice established that community standards are policy instruments, not neutral rules. Kate Klonick's empirical account of how platforms developed internal quasi-judicial processes showed that these processes were designed to manage advertiser and user relations as much as to vindicate expressive rights. More recent scholarship—including work associated with the Oxford Internet Institute on algorithmic amplification and the Reuters Institute's annual digital news reports—has documented the structural asymmetry between platforms and news organisations: platforms set the terms on which journalism circulates, yet journalists bear the reputational and physical risks when content about them goes viral. This literature is strong on diagnosis but has not yet engaged systematically with the compliance architecture introduced by the Online Safety Act. The second body of work is the regulatory design literature on co-regulation and meta-regulation. Julia Black's framework for decentred regulation and Colin Scott's work on accountability in regulatory networks provide conceptual tools for analysing whether a statutory duty of care, enforced through transparency obligations rather than direct content mandates, can produce consistent outcomes. The emerging literature on the Digital Services Act in the EU—particularly work examining whether Article 40 vetted researcher access has produced actionable accountability findings—offers a comparative reference point. What is missing is an applied analysis that maps these regulatory design concepts onto the specific journalist-protection provisions of the Online Safety Act and tests them against available platform transparency data. The gap, stated precisely, is this: there is no systematic analysis of whether the Online Safety Act's accountability instruments are calibrated to detect the specific failure mode of platform under-enforcement against journalist-targeted harassment, as opposed to the broader harms the Act was primarily designed to address. The study uses a two-phase design. Phase one is a regulatory text analysis. I will code the journalist-protection provisions of the Online Safety Act 2023, the relevant Ofcom draft codes of practice, and the community standards and transparency reports of the four platforms most likely to receive Category 1 designation—provisionally Meta (Facebook and Instagram), X (formerly Twitter), YouTube, and TikTok. Coding will follow a framework derived from Black's accountability dimensions: standard-setting, information-gathering, behaviour-modification, and enforcement. The unit of analysis is the commitment or obligation statement; the outcome variable is whether each statement is accompanied by a verifiable metric, an appeals pathway, or a third-party audit requirement. This phase produces a structured gap inventory. Phase two is a comparative case analysis of three documented enforcement episodes involving journalists on UK-facing platforms between 2020 and 2024. Cases will be selected to vary platform type and harm category (coordinated harassment, account impersonation, and doxxing) while remaining within publicly documented records—parliamentary evidence submissions, Ofcom consultations, and press freedom organisation reports from bodies such as the Committee to Protect Journalists and Reporters Without Borders. The case analysis will test whether the gap inventory from phase one predicts the enforcement failures observed in phase two, and will identify which regulatory instruments, if any, were invoked and with what effect. The method is qualitative-interpretive with structured coding rather than statistical inference. This is appropriate because the research question is about regulatory design adequacy, not causal effect size. The analysis does not require access to non-public platform data; it works within the documentary record that the Act's transparency obligations are themselves intended to produce. All primary materials are publicly available or will become so under the Act's transparency reporting schedule. No human subjects research is involved in the core design; the case analysis draws on published records, not interviews with journalists who may be at risk. If I determine during phase two that expert interviews with regulatory practitioners would sharpen the analysis, I will seek ethical approval through the standard Faculty process, but the proposal is not contingent on that access. The principal feasibility risk is that Ofcom's Category 1 designation decisions and the first round of transparency reports may not be published on the schedule I am assuming. I have built a contingency into the timeline: if UK transparency data is delayed, the comparative case analysis can draw on equivalent DSA transparency reports from the EU, which are already subject to enforceable publication timelines under Article 15. Provisional timeline: Michaelmas term—regulatory text coding and gap inventory; Lent term—case selection, case analysis, and draft chapters one and two; Easter term and summer—synthesis, final chapter, and submission. This is consistent with a September submission deadline for a one-year MPhil. The scope is deliberately narrow. I am not attempting to evaluate the Online Safety Act as a whole, nor to produce a comparative study of journalist protection regimes across multiple jurisdictions. Both would exceed the feasible scope of a one-year research degree. The Centre for Science and Policy and the research clusters associated with the Faculty of Law and the Department of Politics and International Studies at Cambridge have active programmes on platform regulation, digital governance, and the intersection of media freedom with technology law. The Minderoo Centre for Technology and Democracy, which is affiliated with Cambridge, has published directly relevant work on platform accountability and the Online Safety Act's design choices. This proposal sits within that intellectual environment without requiring access to restricted datasets or laboratory resources. The documentary materials I need—statutory instruments, Ofcom consultations, platform transparency reports, and press freedom organisation records—are all open-access. The Cambridge library's electronic resources provide access to the regulatory governance and platform studies journals in which the relevant secondary literature is published. My background in journalism and platform analysis, including independent research producing a policy memo on journalist-to-platform regulatory dynamics, has given me working familiarity with how platform policy documents are constructed and where the gap between stated commitment and operational practice tends to appear. The MPhil in Technology Governance would provide the regulatory theory and research methods training to convert that practitioner familiarity into a rigorous, publishable analysis. I am seeking a supervisor whose work engages with co-regulatory design or platform accountability; I have identified research-group outputs in this area and am prepared to discuss specific supervisory fit at interview.