Linking Transparency and Accountability: Analysing The Connection Between TikTok’s Terms of Service and Moderation Decisions

Leonard Eßer, Gerasimos Spanakis


Abstract
The European Commission’s Digital Services Act (DSA) mandates that Very Large Online Platforms (VLOPs), like TikTok, provide Statements of Reason (SoRs) to justify their content moderation decisions in an attempt to enhance transparency and accountability for these platforms. However, we can often notice a gap between these automated decisions and the platform’s written policies. This leaves users unable to understand the specific rule they have violated. This paper addresses this gap by developing and evaluating a pipeline to link TikTok’s SoRs from the DSA transparency database to the most relevant clause from TikTok’s policy documents. We test multiple methods to perform the linking task and evaluate performance using a wide range of retrieval methods and metrics.We develop and deliver a gold-standard dataset where a team of legal research assistants annotated 100 SoRs based on four criteria: clarity, understanding, presence of unclear terms and level of detail, each rated on a 1–4 scale. In addition, a binary rating is assigned for redress clarity. Moreover, annotators determined the best link to the relevant TikTok policy clauses. Results show that both TikTok’s SoRs and policy clauses are often extremely broad, granting TikTok more freedom to decide how to apply the clauses, making it even less transparent for users. We also provide a demo that, for each SoR, provides a ranking of the most relevant clauses from TikTok’s written policies, a tool that can be useful for users, regulators and researchers to better understand content moderation decisions, assess compliance with transparency requirements, and support further analysis of platform accountability.
Anthology ID:
2025.nllp-1.28
Volume:
Proceedings of the Natural Legal Language Processing Workshop 2025
Month:
November
Year:
2025
Address:
Suzhou, China
Editors:
Nikolaos Aletras, Ilias Chalkidis, Leslie Barrett, Cătălina Goanță, Daniel Preoțiuc-Pietro, Gerasimos Spanakis
Venues:
NLLP | WS
SIG:
Publisher:
Association for Computational Linguistics
Note:
Pages:
382–395
Language:
URL:
https://preview.aclanthology.org/ingest-emnlp/2025.nllp-1.28/
DOI:
Bibkey:
Cite (ACL):
Leonard Eßer and Gerasimos Spanakis. 2025. Linking Transparency and Accountability: Analysing The Connection Between TikTok’s Terms of Service and Moderation Decisions. In Proceedings of the Natural Legal Language Processing Workshop 2025, pages 382–395, Suzhou, China. Association for Computational Linguistics.
Cite (Informal):
Linking Transparency and Accountability: Analysing The Connection Between TikTok’s Terms of Service and Moderation Decisions (Eßer & Spanakis, NLLP 2025)
Copy Citation:
PDF:
https://preview.aclanthology.org/ingest-emnlp/2025.nllp-1.28.pdf