Glen Joris

Camiel Colruyt

Judith Vermeulen

Stefaan Vercoutere

Frederik De Grove

Kristin Van Damme

Orphée De Clercq

Cynthia Van Hee

Lieven De Marez

Veronique Hoste

Cyn- Thia Van Hee

Eva Lievens

Toon De Pessemier

Luc Martens

News Diversity and Recommendation Systems: Setting the Interdisciplinary Scene

Keywords: News personalisation, Algorithms, News recommender systems, Right to receive diverse information, News diversity, News content extraction, #NewsDNA

des établissements d'enseignement et de recherche français ou étrangers, des laboratoires publics ou privés.

Introduction

In recent years, online news organisationsboth web-editions of traditional news outlets and digital-only news sitesincreasingly explore how recommender systems can be used to provide consumers with a tailor-made news offer. The New York Times, for example, uses a mix of editorial curation and algorithms to compose a newsletter tailored to each recipient [START_REF]for you: The New York Times[END_REF]. In Belgium too, De Standaard and Het Nieuwsblad recently introduced a personal page that collects articles based on the reader's selected topics [START_REF]Mis niets over uw favoriete thema's via "Mijn dS[END_REF]. In The Netherlands, online newspapers nu.nl and Algemeen Dagblad both invested heavily in personalised news notifications [START_REF]Gepersonaliseerd nieuws: matchmaker voor online media of journalistiek-ethisch mijnenveld?[END_REF]. Hence, news organisations are increasingly exploring implicit and explicit algorithmic news personalisation [START_REF] Thurman | My Friends, Editors, Algorithms, and I[END_REF][START_REF] Thurman | The Future of Personalization at News Websites[END_REF], similarly to how companies such as Netflix and Amazon individualise content.

Personalisation typically relies on automated decision-making and recommender systems. However, in contrast to what people might think [START_REF] Araujo | Automated Decision-Making Fairness in an AI-driven World: Public Perceptions, Hopes and Concerns[END_REF], these systems are not neutral as they primarily apply a commercial logic. More specifically, they produce recommendations based on the calculated relevance of news items vis-à-vis individual news consumers (for example taking into account selected fields of interests or past consumption patterns). Such practices contrast with the role of the media as 'a marketplace of ideas' in which citizens are confronted with a diverse array of ideas [START_REF] Mcquail | McQuail's Mass Communication Theory[END_REF]. Although empirical research currently supports a more nuanced view [START_REF] Möller | Filterbubbels in Nederland[END_REF], news recommender systems are argued to be a potential threat to an informed citizenry and the democratic processes between media, politics and audiences [START_REF] Borgesius | Should we worry about filter bubbles?[END_REF]. With these concerns in mind, several scholars have raised questions regarding how news recommender systems can be built in a more citizen-oriented way by maintaining the normative aims of journalism [START_REF] Helberger | On the Democratic Role of News Recommenders[END_REF].

The current chapter presents research conducted by the interdisciplinary research project #NewsDNA at Ghent University (Belgium), which seeks to provide a possible answer in that regard. More specifically, it outlines building blocks for the construction of a recommender system that uses news diversity as a key driver for personalised news recommendations. As such, the deployment of artificial intelligence could support the media in providing people with information and stimulating public debate, rather than undermine their role in that respect. To gather feedback concerning this framework from scholars of different backgrounds, this research has been presented during the 2019 IFIP summer school workshop on 'co-designing a personalised news diversity algorithmic model based on news consumers' agency and fine-grained content modelling'. The results of this exercise are also included in this contribution.

As the current research builds on insights from multiple disciplines, the remainder of this paper isas was the workshoporganised per discipline. First, we present a state-of-the-art overview of the most commonly used methods to design news recommender systems within computer sciences. Second, we explore the existence of a legal ground for receiving diverse news. Third, we expound on the conceptual meaning of news diversity by building on literature in communication sciences. Finally, we discuss the computational feasibility of news content extraction, provided by computational linguistics, to provide data to the aspired diversity-promoting news recommender system. Each part is followed by related questions we presented the workshop participants with as well as their answers in that regard.

News recommendations systems today

In this section, we provide an overview of current news recommendation systems, from a computer science perspective. We present the two dominant approaches, being collaborative and content-based filtering, and outline the obstacles related to the development of a diversity-enhancing news recommender.

One of the most commonly used methods in the field of recommendation systems is collaborative filtering. Collaborative filtering assumes that people who had similar interests in the past are likely to have similar interests in the future [START_REF]Recommendation Systems: General Collaborative Filtering Algorithm Ideas[END_REF]. As such, relevant news articles are predicted based on news articles read by so-called 'neighbours', other users who have historically had similar taste in news [START_REF] Sarwar | Item-based Collaborative Filtering Recommendation Algorithms[END_REF]. In essence, it is very similar to the concept of 'word of mouth': we often consult with our peers when gathering opinions about certain activities or decisions (e.g. interesting movies, tasty drinks). Especially for news, peer recommendations are still perceived as valuable [START_REF] Damme | Mapping the Mobile DNA of News. Understanding Incidental and Serendipitous Mobile News Consumption[END_REF].

Collaborative filtering methods have two major drawbacks when recommending news stories. First, news is quick and volatile, which exacerbates the first-rater problem [START_REF] Good | Combining Collaborative Filtering with Personal Agents for Better Recommendations[END_REF][START_REF] Liu | Personalized News Recommendation Based on Click Behavior[END_REF]: a new story cannot be recommended to users unless other users have read it before. This becomes problematic when trying to present the latest information in a timely manner, as it is not uncommon for collaborative filtering based methods to take several hours before sufficient clicks have been collected and a new item can be recommended. Generally, as an item gains more clicks, the system becomes more confident in its ability to recommend it. Hence, older and popular items dominate the recommendation process, which is not desirable for news recommendations. Second, there is the sparsity problem [START_REF] Chen | Solving the Sparsity Problem in Recommender Systems Using Association Retrieval[END_REF], which occurs when there is insufficient overlap between the consumption patterns of users. As the relevance of news stories sharply decreases over time, it is not unreasonable to assume little overlap between new and old users.

A second approach is content-based filtering, which does not have these shortcomings, and consequently is often used for news recommendations [START_REF] Liu | Personalized News Recommendation Based on Click Behavior[END_REF][START_REF] Adnan | Content based news recommendation system based on fuzzy logic[END_REF]. Content-based systems use the news articles themselves to recommend similar news, both the content and its metadata. For example, the system looks at the topic of the news, the keywords or the broader classification (e.g. sports or domestic affairs), the author, word count, etc. This means that in contrast to collaborative filters, content-based systems treat recommendation as a single user classification problem.

However, this method also suffers from certain drawbacks. First, over-specialisation: content-based systems cannot provide recommendations outside the scope of what the user has already shown interest in. Within journalism, this is the trigger for concerns of filter bubbles and news personalisation [START_REF] Borgesius | Should we worry about filter bubbles?[END_REF]. Second, the performance of the system heavily depends on the quality of the content descriptions. In domains where the items consist of music or video, the extraction of a useful representation of the content can be very challenging. In journalism as well, news articles often do not have sufficient metadata, nor are metadata compatible across different news companies. Section 5 illustrates a few content dimensions that can be used in recommendation.

What both these techniques have in common is that they are based on similarity, either between users or items. The risk of such a recommendation strategy is that users are more likely to be exposed to a narrowing segment of popular items, as the focus lies on maximising the overlap between users' behaviour. As such, recommender systems today strive for news personalisation, which in fact contrasts with the aspired goal of a citizen-aware recommender system. This risk is compounded by the focus on metrics such as accuracy. Often, the performance of a recommender is solely measured in terms of its re-constructional capabilities (i.e. how precise the system is in predicting already consumed articles). All differences between the original and predicted user history are seen as losses in performance. When the lack of diversity is addressed, it is typically done as an adjunct to the standard procedures and through rudimentary means [START_REF] Smyth | Similarity vs. Diversity[END_REF][START_REF] Lathia | Temporal Diversity in Recommender Systems[END_REF].

Increasing diversity and novelty is only considered if it can be done without significantly compromising query similarity, and this application remains limited to aimlessly broadening of the coverage.

Having set the scene, the participants were asked whether they had ever encountered news personalisation in their daily lives and to share their perception of such practices in general. As regards the first question, one attendee indicated to have experienced personalisation at a news site whereby items presumed relevant to a particular consumer were highlighted. However, all news available remained accessible for all users in the same order. Another noted that as social media feeds are being personalised, the news you view on these platforms is so too. In response to the second question, concerns were raised as regards a presumed lack of awareness and transparency in relation to the existence of algorithmic selection processes as well as concerning the logic behind them. It was added that news consumers should be properly informed. One participant furthermore indicated to "dislike the feeling of being steered".

A fundamental right to diverse information

The importance of an easily available diverse news offer has been recognised in several recent policy documents. More specifically, it was argued that it has "the potential to make democratic processes more participatory and inclusive" and to foster public debatewhich may ultimately secure democracy -, and could even "uncover, counterbalance, and dilute disinformation" [START_REF]) Special Rapporteur on Freedom of Opinion and Expression, Organization for Security and Co-operation in Europe (OSCE) Representative on Freedom of the Media, Organization of American States (OAS) Special Rapporteur on Freedom of Expression, African Commission on Human and Peoples' Rights (ACHPR) Special Rapporteur on Freedom of Expression and Access to Information: Joint Declaration on Freedom of Expression and "Fake News[END_REF][START_REF]Commission: Tackling online disinformation: a European Approach[END_REF]. At EU level, therefore, "empower[ing] users with tools enabling a customised and interactive online experience so as to facilitate content discovery and access to different news sources representing alternative viewpoints" was set as a goal [START_REF]Commission: Tackling online disinformation: a European Approach[END_REF][START_REF]High level Group on fake news and disinformation: A multi-dimensional approach to disinformation[END_REF][START_REF][END_REF]. Interestingly, the EU Commission's independent High Level Expert Group on Fake news and Online Disinformation, when defining '[a]ctions in support of press freedom and pluralism' in the final report concerning their approach on disinformation, stated, amongst others, that public authorities must ensure the "protection of [a] basic right[…] to […] diverse information" (emphasis added) [START_REF]High level Group on fake news and disinformation: A multi-dimensional approach to disinformation[END_REF]. In that context, the question arises whether, and to what extent, the right to freedom of expression and information, laid down in both Article 10 of the European Convention on Human Rights ('ECHR') [START_REF]European Convention for the Protection of Human Rights and Fundamental Freedoms[END_REF] under which positive obligations1 may arise [START_REF]Positive obligations on member States under Article[END_REF] and Article 11 of the Charter of Fundamental Rights of the European Union ('Charter') [START_REF]Charter of Fundamental Rights of the European Union[END_REF], indeed includes a right to receive diverse information. Its existence, including a corresponding responsibility for authorities to take affirmative action to ensure its effective exercise [START_REF] Mcgonagle | Positive obligations concerning freedom of expression: mere potential or real power?[END_REF], would enable citizens to force policymakers to adopt measures guaranteeing them access, potentially offline as well as online, to a diversity of information.

In its first paragraph, Article 10 ECHR puts forward that:

"Everyone has the right to freedom of expression. This right shall include freedom to hold opinions and to receive and impart information and ideas without interference by public authority and regardless of frontiers […]." (emphasis added)

On numerous occasions, the European Court of Human Rights ('ECtHR') has interpreted the 'freedom to receive information and ideas'. Indeed, already in the 1979 case of Sunday Times v. the UK, the Court stated that "[n]ot only do the [mass] media have the task of imparting […] information and ideas [concerning matters of public interest]; the public also has a right to receive them" (emphasis added) [START_REF][END_REF]. In the Informationsverein Lentia and Others v. Austria judgment from 1993, it added that "[s]uch an undertaking cannot be successfully accomplished unless it is grounded in the principle of pluralism, of which the State is the ultimate guarantor" (emphasis added) and that "[t]his observation is especially valid in relation to audio-visual media, whose programmes are often broadcast very widely" [30]. On 8 July 1999, in the context of its decision in a number of cases against Turkey, all concerning the criminal convictions of the applicants in view of their involvement in the spread of separatist or pro-Kurdish propaganda [START_REF] Voorhoof | IRIS Themes -Vol. III -Freedom of Expression, the Media and Journalists. Case-law of the European Court of Human Rights[END_REF], the ECtHR explicitly referred to "the public's right to be informed of a different perspective" and considered that the domestic authorities failed to sufficiently respect their negative obligation in that regard [START_REF] Erdoğdu | [END_REF]. It furthermore concretised its by then settled Sunday Times case-law referred to above, by finding that "[i]t is […] incumbent on the press to impart information and ideas on political issues, including divisive ones" (emphasis added), whilst the public is entitled to receive them [START_REF][END_REF]. In the Khurshid Mustafa and Tarzibachi v. Sweden case of 2008, which concerned (a prohibition of) the reception of information by means of a satellite dish, it was held in very clear terms that, "[i]n addition to the primarily negative undertaking of a State to abstain from interferences in Convention guarantees", "the genuine and effective exercise of freedom of expression under Article 10 may require positive measures of protection, even in the sphere of relations between individuals" (emphasis added) [34]. In the 2009 Times Newspapers LTD (Nos. 1 and 2) v. the United Kingdom case, it was considered that "the Internet plays an important role in enhancing the public's access to news and facilitating the dissemination of information in general" [35]. Late 2009, in the Manole and Others v. Moldova judgment, the Strasbourg Court ruled that "the State [must] ensure […] that the public has access through television and radio to impartial and accurate information and a range of opinion and comment, reflecting inter alia the diversity of political outlook within the country" (emphasis added) [36]. Finally, in 2012, in Centro Europa 7 S.R.L. and Di Stefano v. Italy, it was clarified that, considering the sensitive nature of the audio-visual media sector, member States have a positive obligation to "put in place an appropriate legislative and administrative framework to guarantee effective pluralism" (emphasis added) [START_REF] Stefano V | Centro Europa 7[END_REF].

Article 11 of the Charter provides that: "1. Everyone has the right to freedom of expression. This right shall include freedom to hold opinions and to receive and impart information and ideas without interference by public authority and regardless of frontiers.

2. The freedom and pluralism of the media shall be respected." (emphasis added)

Article 52(3) of the Charter stipulates that "[i]n so far [the] Charter contains rights which correspond to rights guaranteed by the Convention for the Protection of Human Rights and Fundamental Freedoms, the meaning and scope of those rights shall be the same as those laid down in the European Convention on Human Rights". Clearly, such is the case for Article 11(1) [START_REF]Explanations relating to the Charter of Fundamental Rights[END_REF]39]. Moreover, Article 51(1) EU Charter puts forward that the provisions of the Charter are addressed to the institutions, bodies, offices and agencies of the Union and to its member states only when they are implementing Union Law. They should therefore "respect the rights, observe the principles and promote the application thereof in accordance with their respective powers and respecting the limits of the powers of the Union as conferred on it in the Treaties" [27 art 51 [START_REF]for you: The New York Times[END_REF]]. Leaving aside the discussions concerning the exact scope of application of EU fundamental rights in respect of actions of member states on the basis of Article 51(1) of the Charter [START_REF] Beijer | Limits of Fundamental Rights Protection by the EU: The Scope for the Development of Positive Obligations[END_REF], several scholars have argued that this provision confers on the Union an indirect power to adopt rules or measures protecting fundamental rights in the course of exercising its specific competences under the Treaties [START_REF] Beijer | Limits of Fundamental Rights Protection by the EU: The Scope for the Development of Positive Obligations[END_REF]. However, such a power would not allow the Union to take action if the protection of fundamental rights were to be the only or primary aim thereof [START_REF] Beijer | Limits of Fundamental Rights Protection by the EU: The Scope for the Development of Positive Obligations[END_REF]. It appears, for example, that by means of Article 15 as well as recitals 48 and 55 of the Audiovisual Media Directive [41], the EU legislator has sought to safeguard the right to receive information and to promote pluralism of the media by ensuring diversity in the production and programming of news in the EU, and therefore to respect the principles recognised by both paragraphs of Article 11 of the Charter [START_REF] Beijer | Limits of Fundamental Rights Protection by the EU: The Scope for the Development of Positive Obligations[END_REF]. In its 2013 Opinion in Sky Österreich, the Court of Justice of the European Union ('CJEU'), confirmed that the EU legislature was indeed 'entitled'though not, on the basis of positive obligations, 'required'to do so and to take measures to ensure public access to a diversity of information [42].

In conclusion, the ECtHR has clearly recognised a right of the public to be informed about different viewpoints concerning matters of general importance. The State is ultimately responsible for the effective exercise thereof, and this indisputably within the context of the audio-visual media sector. While the ECtHR so far has not recognised such a duty vis-à-vis States in relation to the public's right to receive information and ideas in the online environment, it indeed very well could, given its acknowledgment of the importance of the Internet in enhancing access to news and facilitating the dissemination of information [43]. The CJEU has also stressed the importance of media pluralism and diversity of information available to the public. Whereas the CJEU does not (yet) consider the Unionin view of its nature and competences [START_REF] Beijer | Limits of Fundamental Rights Protection by the EU: The Scope for the Development of Positive Obligations[END_REF] to be directly responsible for taking positive action to that end, it found that the latter certainly may do so when exercising its attributed competences.

Considering the potential impact a right to diverse information could have in our contemporary society, we presented the participants with the following questions: one, do we need such a right, and two, should the government play a role in ensuring that citizens can access diverse information? The first question was collectively answered in the affirmative. One attendee in particular argued that one should have access to diverse information as it is enables him or her to make informed decisions. Thoughts in relation to the second question were, on the other hand, more varied. One group of participants noted that in countries where confidence in publicly-funded news is high, the government could also be trusted to guarantee diverse exposure to information. Others, however, stated that such involvement could very easily go wrong. They considered, more specifically, that it may lead to a situation in which people would only be shown content the authorities want them to see.

Unravelling news diversity

As argued above, it becomes clear that today's news recommender systems do not take into account news diversity, even though the idea of receiving diverse information is an important prerequisite for maintaining a democratic society. This neglect also contrasts with the academic field of communication sciences in which news diversity has a long tradition in helping to understand and evaluate the role of news media in the public sphere [START_REF] Mcquail | Media Performance[END_REF][START_REF] Van Der Wurff | Do audiences receive diverse ideas from news media? Exposure to a variety of news media and personal characteristics as determinants of diversity as received[END_REF]. In fact, most research on news diversity date back to the arrival of audio-visual and digital media such as television and the web (i.e., 1995-2005, see e.g. [START_REF] Day | Source and content diversity in Op-Ed Pages: assessing editorial strategies in The New York Times and the Washington Post[END_REF][START_REF] Rodgers | Two Papers in Joint Operating Agreement Publish Meaningful Editorial Diversity[END_REF][START_REF] Voakes | Diversity in the News: A Conceptual and Methodological Framework[END_REF]). Despite the existence of a significant body of literature around the concept of news diversity, however, communication scholars are still struggling with the question of what it means, and how it should be measured [START_REF] Voakes | Diversity in the News: A Conceptual and Methodological Framework[END_REF][START_REF] Raeijmaekers | Media, pluralism and democracy: what's in a name? Media[END_REF]. Consequently, a wide range of diversity dimensions, assessments and assumptions are currently used to study news diversity [START_REF] Napoli | Deconstructing the diversity principle[END_REF].

The broad and ambiguous use of the concept is argued to have several academic and political implications. First, it endangers the broader validity and reliability of existing and future research, which is, in turn, essential for the organisation and application of scientific findings related to news diversity [START_REF] Liu | Task complexity: A review and conceptualization framework[END_REF]. Second, and linked with the previous, there is a risk of formulating inadequate policy recommendations. For instance, with regard to the discussions on the existence of selective exposure or filter bubbles in the digital environment, the current literature is not able to present a clear overview on the state and outcome of diversity research in the digital environment. As a consequence, policy recommendations are rather limited to 'more research should be done' or 'insight into filter bubbles are indispensable' [START_REF] Borgesius | Should we worry about filter bubbles?[END_REF].

We argue that a clear description of what news diversity constitutes may be a first stepping stone to solve the above-mentioned issues. First, it may help scholars to map the current field and identify areas of ambiguity or neglect. Second, it enables news diversity scholars to make informed decisions when studying news diversity. This might be of particular importance for future diversity research, but also for the development of news recommenders.

In this section, we forward an approach to unravel the normative and conceptual assumptions underlying this concept ( [START_REF] Joris | News diversity reconsidered: A systematic literature review unravelling the diversity in conceptualizations[END_REF] for an extensive overview). These assumptions range from explicitly formulating the normative position to deciding on what kind of dimensions to measure (see Table 1). We will further elaborate on these assumptions by presenting three leading questions that enable the discussion on the meaning of news diversity.

Table 1. Distinguishing normative and conceptual assumptions of news diversity

Assumption

Leading question Normative assumption: normative stance Should news media reflect the diversity in society or should it treat all categories under study equally? Conceptual assumption: sample selection What or whom is studied: production, consumption or distribution?

Conceptual assumption: diversity dimensions Which dimensions in news media content (e.g., gender, sentiment) or structure (e.g., ownership) are studied?

Normative assumptions

The first leading question is concerned with the idea of open and reflective diversity [START_REF] Mcquail | Diversity as a Media Policy Goal: a Strategy for Evaluative Research and a Netherlands Case Study[END_REF][START_REF] Takens | Old ties from a new(s) perspective: Diversity in the Dutch press coverage of the 2006 general election campaign[END_REF]. The former evaluates diversity as an equal media representation of all categories. The latter argues that media should reflect the diversity in society [START_REF] Mcquail | Media Performance: Mass Communication and the Public Interest[END_REF]. Take, for instance, research on the diversity of political opinions in the news. From an open point of view, diversity would be evaluated as an equal representation of all voices in the political spectrum. From a reflective viewpoint, evaluation of diversity would be based on the question to what extent these voices coincide with the current distribution of political opinions in society.

Conceptual assumptions

A second question is related to what or whom is studied. Traditionally, this means a choice between the production side, in which news is made available, and the consumption side, in which people engage news. However, in the current news environment, distribution actors such as search engines, recommendation systems, and aggregators could also be considered (e.g. [START_REF] Möller | Do not blame it on the algorithm: an empirical assessment of multiple recommender systems and their impact on content diversity[END_REF]).

The third question deals with the most fundamental part of what constitutes news diversity: the studied dimension(s) of diversity. It concerns the focus of analysis, what researchers actually measure to make conclusions about news diversity. This might be centered on dimensions in the content or structure of news media. To name a few examples, we explain the content dimensions 'actor diversity' and 'party diversity'. The former refers to the affiliation or occupation of the actors who are quoted or paraphrased in the news [START_REF] Masini | Actor diversity and viewpoint diversity: Two of a kind?[END_REF]. The latter is concerned with the number of political parties across which a medium distributes its attention, either implicitly in terms of topics or explicitly in terms of party name [START_REF] Takens | Old ties from a new(s) perspective: Diversity in the Dutch press coverage of the 2006 general election campaign[END_REF].

To conclude, we want to emphasize that news diversity is a very broad concept, covering several aspects related to news, media and democracy. As such, news diversity remains an ambiguous concept when it is not accompanied by explications of the assumptions underlying this concept. Especially in the context of news recommendations systems, informed decisions on each of these assumptions as well as explicit statements should be made. Audiences, in the first place, but also other stakeholders such as policymakers should be aware of what kind of diversity is tweaked and which ideal is pursued.

During the workshop, the participants were asked to give their opinions in relation to the normative assumption related to news diversity. In particular, they were asked whether news media should reflect the diversity in society (i.e., reflective diversity) or should news media treat all categories under study equally (i.e., open diversity). Interestingly, a majority leaned towards 'open diversity'. Participants pointed out that while reflective diversity indeed mirrors society, it could, when taken too far, limit the forming of opinions. Instead, there could be a 'free market of diversity', in which an increase in reports on right-wing opinions would for example trigger a rise in the distribution of left-wing points of view (and vice versa). As such, a kind of equilibrium could be achieved. Other participants, moreover, pointed out that open diversity would allow niche opinions to grow and even become the majority. Therefore, it could also encourage change. For example, participants pointed to the idea that more coverage of female football, female scientists etc. could have a positive effect on the emancipation of women in society. Nonetheless, the participants discussed whether also the most extreme opinions should be allowed to circulate. Where one attendee stated to prefer to know of their existence, because this helps to assess one's own position on the spectrum, another considered that the right to access diverse information should be restricted in the same way as the freedom to express opinions. Accordingly, a diversityenhancing news recommender should not promote content involving hate speech.

Concluding this discussion, we want to stress the importance of reflecting on the normative assumptions related to news diversity. As this workshop has shown, several (counter-)arguments may be used in favour or against open/reflective diversity. Future diversity research should focus on these (counter-)arguments to explore the consequences of each assumption.

Automated extraction of content dimensions in written news

This section zooms in on a number of diversity dimensions that can be detected in written news content. As indicated previously, several possibilities, such as actor diversity or the prominence of political parties, have been investigated in this field. These analyses often rely on manual coding of news items. Whereas manual analysis is powerful, it also practically restricts the number of media items that can be parsed, and easily leads to methodological differences between individual researchers. Automating the extraction of relevant dimensions, using techniques from the fields of computational linguistics and artificial intelligence, on the other hand, would allow for a standardised and fine-grained feeding of news algorithms on a large scale. The #NewsDNA research project focusses on the automated extraction of two possible content dimensions that can serve as building blocks for a diversity-driven news recommender: news topics and news events.

Topics

An intuitive analysis of the content of news articles is centred around news topics. In this context, topics are the general areas on which an article touches, such as politics, international news, or entertainment. News publishers use topics tags to organise their own news output. While some features of a topic taxonomy tend to recur, there is considerable variation between news outlets, making it hard to establish a mapping between them. Additionally, depending on the outlet, articles may belong exclusively to a single topic or to multiple topics. Variable tags based on current events, like Brexit or immigration, may be used alongside general tags. This lack of uniformity makes it generally impractical for the researcher to use outlet-provided topics tags for automatic analysis across publishers. Some efforts exist to encourage consistent use of media topics in the news industry. An example of a topics framework promoted as a global standard is the IPTC Media Topics taxonomy [START_REF]Media Topics[END_REF]. It defines 17 top-level codes which hierarchically subdivide into subtopics up to five levels down. For example, the bottom-level code "housing and urban planning" can be traced back through "interior policy" and "government policy" to the top-level code "politics". The deeper into the tree, the more granular the topic definitions become.

Events

Topics provide a general idea of the content of an article by describing which aspects of society it touches on, but they do not say anything about its specific contents. More semantics-driven algorithms can shed light on the events described in the text. We briefly discuss one such technique applied in the #NewsDNA project and illustrate the research effort involved.

An attractive and little-explored dimension of analysis is that of news events, i.e. the real-world events which provide the material and context for news articles. For example, in a fictional example entitles "Russian spies arrested in England", the arrest of the Russian spies is the event that leads to the article being written. The goal of event extraction is to identify the real-world events referred to in news texts, as well as information on the actors, time, place, etc. involved in the event. In the example, the "Russian spies" are entities involved in the event and "England" is its stated location. Note that upstream technologies such as named entity extraction can play a role in discovering these participants [START_REF] Colruyt | EventDNA : guidelines for entities and events in dutch news texts[END_REF].

An event extraction system, then, is an algorithm which takes as input a text and returns a number of event descriptions it has found in the text. Such a model is obtained through machine learning. First, a set of articles is prepared in which event descriptions have been manually annotated. Second, a machine-learning algorithm goes over this set and, through trial and error, learns to identify event descriptions matching the humanmade gold standard. The system can then be run on previously unseen articles to produce new event descriptions.

Inevitably, to extract news events, we need to define what we consider to be a news event. Many different conceptions of "events" have been examined, some of which focus on the discovery of real events in text (see e.g. NewsReader [START_REF] Vossen | Newsreader Public Summary[END_REF], the ACE/ERE programs [START_REF] Doddington | The Automatic Content Extraction (ACE) Program -Tasks, Data, and Evaluation[END_REF][START_REF] Aguilar | A Comparison of the Events and Relations Across ACE, ERE, TAC-KBP, and FrameNet Annotation Standards[END_REF], RED [START_REF] O'gorman | Richer Event Description: Integrating event coreference with temporal, causal and bridging annotation[END_REF]) and some of which focus on fine-grained text semantics (e.g. the FrameNet project [START_REF] Ruppenhofer | FrameNet II: Extended theory and practice[END_REF]).

Typically, a taxonomy of event types is used, such that each event mention found in the text can be classified in a semantic category such as "Conflict-Attack" or "Transaction-TransferOwnership" (from ERE [START_REF] Aguilar | A Comparison of the Events and Relations Across ACE, ERE, TAC-KBP, and FrameNet Annotation Standards[END_REF]). The advantage of a fixed taxonomy is that it naturally defines the scope of news events: events that cannot be classified are not recognised.

A sizeable body of work (around the previously cited research programs [START_REF] Doddington | The Automatic Content Extraction (ACE) Program -Tasks, Data, and Evaluation[END_REF][START_REF] Aguilar | A Comparison of the Events and Relations Across ACE, ERE, TAC-KBP, and FrameNet Annotation Standards[END_REF][START_REF] Vossen | NewsReader at SemEval-2018 Task 5: Counting events by reasoning over event-centric-knowledge-graphs[END_REF]) focuses on event extraction in a closed data context, where the corpus of articles is given and the event type taxonomy is fixed. This leads to systems that perform well at extracting those specific categories of events, but fail at handling unrestricted news text discussing a wider variety of events. In an open data context, an automatic system must capture all relevant events from in-coming news texts. Designing a taxonomy for this is a difficult balancing act: a small taxonomy will exclude many relevant events, while a taxonomy with many different types will suffer from data sparsity (i.e. some event types are so rare that they cannot be learned or extracted reliably). Additionally, a fixed taxonomy may not adapt well to a stream of news whose tone changes with time. This imposes a process of constant retraining of the algorithm, which is feasible provided that data are available. For instance, suppose that incoming news focuses on a certain terrorist attack one month, whereas the big story of the next month is centred around the question of immigration. A system trained on data from one period in time may be disadvantaged when dealing with news from another. A natural way to sidestep this limitation is to allow for events of type 'unknown' to be extracted, but even in that case care needs to be taken so that 'unknown' events remain a minority within the training data [START_REF] Colruyt | Comparing event annotations: notes on the EventDNA corpus IAA study[END_REF]. The prediction of events without type has not been fully explored, as the theoretical applications of this technology tend to presume event type prediction is a desirable feature, or, at least, useful for other downstream applications.

For the purposes of news recommendation, the appeal of event extraction lies in linking event descriptions across articles. Given two event descriptions, specialized systems can establish identity links between them; two mentions that refer to the same event are called co-referent. Co-reference links can be established within but also across articles. It has been thoroughly researched for nominal entities, but not for events, and even less across documents [START_REF] Lu | Event Coreference Resolution: A Survey of Two Decades of Research[END_REF]. It allows us to link together articles based on a deep semantic interpretation. For instance, using a topic-based system, we are able to cluster articles based on tags such as politics or business, or if our system is capable of finegrained topic analysis, more current tags such as Brexit or economic crisis. If we know the specific events that occur in the articles, and if we know how to establish co-reference links between events across articles, we can create clusters based on single events. For example, we could gather all articles discussing Theresa May's resignation in June, with far greater precision than using topic-based methods. In terms of addressing diversity, we could also use these clusters and links to broaden the scope of recommendations in a more organic way by, for example, recommending articles located at the edge of a cluster or from closely neighbouring ones.

Cross-document event recognition and co-reference is key to moving the state of the art in natural language understanding and personalised recommendation. While solutions based on dimensions such as topics and actors work well with recommender systems, we propose that a more granular semantic analysis based on events can further enhance the precision of news recommenders.

After having explained the difference between 'topics' and 'events, we asked our audience to think of other content dimensions which could be of relevance in the context of automated text analysis. A first participant considered it would be interesting to categorise new articles according to their 'level of argumentation'. Well-argued opinions could consequently be singled out and further discussed, which in turn may facilitate public debate. Another attendee suggested that content extraction techniques could be used to verify whether the title -rather than functioning as a 'clickbait' -matches the information contained in an article. The detection of 'viewpoints' also put forward as an option. In that regard, others put forward that structural elements, such as an author's affiliation or background, or his or her country of origin, could also serve as indicators of 'bias' in a news items.

Towards a diversity-promoting news recommender

In this article, we addressed the conceptual development of a news diversity-enhancing recommendation system. To do so, we approached news recommendations from four different academic domains: computer sciences, law, communication sciences, and computational linguistics.

In the first section (i.e. computer sciences), we reviewed the state of the art of current news recommendation systems. In particular, we described two dominant methodologiescollaborative and content-based filteringand unravelled their assumptions and drawbacks. We ended this section with a critique in that citizenoriented concepts such as news diversity are currently underrepresented in these methodologies. Other concepts, such as accuracy or maximisation of the overlap between users' behavior, currently dominate the discourses in this field.

In the second discussion (i.e. law), we discussed the existence of a so-called 'right to diverse information'. By means of an analysis of relevant fundamental rights documents and case-law of the ECtHR and CJEU, we were able to support this statement. As a result, we concluded that governments carry the ultimate responsibility for the effective exercise of this right, in the past predominantly with respect to audio-visual media, but in the future potentially also with regard to the accessibility of online news.

In the third section (i.e. communication sciences), we explored the meaning of the mere notion of news diversity. As argued, diversity may function as an alternative, more citizen-oriented strategy to design news recommendation systems, yet the concept itself is characterized by ambiguity. As such, we started our discussion with the conceptual difficulties of this concept and their implications. Then, we presented an approach to unravel the normative and conceptual assumptions underlying this concept.

In the fourth discussion (i.e. computational linguistics), we explored how computational methods may enrich manual analysis in order to extract news content dimensions such as topics and events. We illustrated the usage of topic tags, and introduced automatic event extraction, citing applications, drawbacks and obstacles that emerge when these methods are set into practice.

Based on the feedback we received from the participants of the 2019 IFIP workshop on 'co-designing a personalised news diversity algorithmic model based on news consumers' agency and fine-grained content modelling', we consider that ensuring and promoting diversity in information exposure is an important public policy goal. As future developments in the fields of recommender systems and automated content extraction may contribute to its achievement, further research into the conceptualization of a news-diversity enhancing algorithm will continue to be undertaken in the #NewsDNA project across the four disciplines. On the one hand, conceptual questions stemming from the fields of communication science and law will be considered on a fundamental level. This concerns questions such as 'which dimensions should be selected to conceptualise news diversity?' or 'what is the optimal outcome of diversity to which audiences are steered?' to which no unequivocal answers yet exist. On the other hand, the fields of computational linguistics and computer sciences, which enable such a recommender system, still carry operational questions and difficulties. Relevant content dimensions must be translated into content extraction algorithms, which is not a solved issue. The design of the recommendation algorithm must also be carefully considered, as the right balance has to be made between relevance and diversity.

Negative obligations require States not to interfere in the exercise of rights, while positive obligations entail a duty to take the necessary measures to safeguard a right, or, more specically, to adopt reasonable and suitable measures to protect the rights of individuals" in[START_REF] Akandji-Kombe | Positive obligations under the European Convention on Human Rights. A guide to the implementation of the European Convention on Human Rights[END_REF].


Judith Vermeulen

Recommended For You: "You Don't Need No Thought Control" An Analysis of News Personalisation in light of Article 22 GDPR

Keywords: News Personalisation, News Websites, Automated Individual Decision-making, Article 22 GDPR, Fundamental Rights, Freedom of Thought, Freedom of Opinion

More and more often personalisation at news websites is being introduced. In order to be capable of providing suggestions, recommender systems create and maintain a user profile per individual consumer that captures the latter's preferences over time. This requires the processing of personal data, and more specifically its collection and use for both profiling purposes and the eventual delivery of recommendations. In view of the fact that providing users with individualised news recommendations is usually realised by solely automated means and may in some cases violate people's absolute and non-derogable rights to freedom of thought and freedom of opinion, it could be prohibited on the basis of Article 22(1) of the EU General Data Protection Regulation. Online newspapers ideally abstain from becoming personalisation-only forums and give users some form of control as regards the determination of their reading preferences and interests.

Introduction

A banner titled "your privacy" pops up when visiting the website of The Guardian: "We use cookies to improve your experience. To find out more, read our privacy and cookie policy" [1]. Such 'improvement', so a (rare) consultation of the latter reveals, includes amongst others "showing readers journalism that is relevant to them" [START_REF]Cookies on the Guardian website[END_REF]: a bespoke offer based on what you like. Which proportions said customisation takes on, how such impacts user interfaces, and to what extent items are still distributed to everyone in the same way, is not clarified. The reinvention by this newspaper of its service of providing people with news as well as its way of announcing it appears to be no stand-alone example, on the contrary. Thus seemingly unnoticedhardly anyone actually runs through those policies before pressing the prominent button "I'm OK with that" -, news personalisation by online news providers, both web-editions of traditional news outlets and digital-only news sites, appears to become commonplace. Simultaneously, the era of mass distribution of information and opinions by the press to all citizens alike may be coming to an end.

In what follows, first, the phenomenon of news personalisation at news websites will be described; second, it will be analysed whether this practice falls within the scope of Article 22 GDPR, which contains a general prohibition on automated individual decision-making having legal or similarly significant effects, and if so, what would be the consequences thereof; finally, there will be a conclusion.

News personalisation at news websites

Neil Thurman, Professor of Computational Journalism, has been studying the phenomenon of news 'personalisation', 'customisation' or 'individualisation' already since 2011 [START_REF] Thurman | Making 'The Daily Me': Technology, economics and habit in the mainstream assimilation of personalized news[END_REF]4]. He, together with Steve Stifferes, Professor of Financial Journalism, defines it as "a form of user-to-system interactivity that uses a set of technological features to adapt the content, delivery, and arrangement of a communication to individual users' explicitly registered and/or implicitly determined preferences" [5,[START_REF] Thurman | The Paradox of Personalization: The Social and Reflexive Turn of Adaptive News[END_REF]. They consider it to be the result of a set of "complex interactions that exist between computer algorithms and those behind their logic, data about individual and aggregated user behaviour, decisions on classification and indexing, explicit user choices, editorial and journalistic decisions, and user profiles, demographics and location" [START_REF] Thurman | The Paradox of Personalization: The Social and Reflexive Turn of Adaptive News[END_REF]. From their definition, it is moreover clear that these authors make a distinction between two different ways to determine user preferences: explicit and implicit personalisation [START_REF] Thurman | The Paradox of Personalization: The Social and Reflexive Turn of Adaptive News[END_REF]. In the former case, users actively register their interests [START_REF] Thurman | Making 'The Daily Me': Technology, economics and habit in the mainstream assimilation of personalized news[END_REF][START_REF] Thurman | The Paradox of Personalization: The Social and Reflexive Turn of Adaptive News[END_REF]. They could, for example, be allowed to select their favourite topics or columns and be enabled to always easily access them via a "My Page" or "My News Feed"-function [START_REF]Mis niets over uw favoriete thema's via "Mijn dS[END_REF]. The latter technique on the other hand covers situations in which user preferences are inferred "from data collected, for example, via a registration process or via the use of software that monitors user activity" [START_REF] Thurman | Making 'The Daily Me': Technology, economics and habit in the mainstream assimilation of personalized news[END_REF][START_REF] Thurman | The Paradox of Personalization: The Social and Reflexive Turn of Adaptive News[END_REF]. There, the goal could be to personalise what stories people see on the homepage [START_REF] Slefo | New York Times" plans to invest heavily in AI[END_REF].

Personalisation at news websites could also take the form of recommendations as to what to read next in a sidebar or below articles, a customised page besides a homepage, mobile editions or apps offering customisation options etc. [START_REF] Kunert | The Form of Content Personalisation at Mainstream, Transatlantic News Outlets: 2010-2016[END_REF][START_REF] Eskens | A right to reset your user profile and more: GDPR-rights for personalized news consumers[END_REF].

From a computer science perspective, research regarding news recommender systems has for the most part concerned either content-based filtering, collaborative filtering or hybrid approaches [START_REF] Karimi | News recommender systems -Survey and roads ahead[END_REF][START_REF] Moreira | News Session-Based Recommendations using Deep Neural Networks[END_REF]. The first-mentioned method consists in the analysis of a set of items by means of feature extraction techniques in order to represent their content in a form suitable for the next processing steps; the subsequent building of a model comprising a structured representation of user interests based on the features of the items 'rated' (see infra) by that user; and, finally, the recommendation of new interesting items using these profiles [START_REF] Lops | Content-based Recommender Systems: State of the Art and Trends[END_REF]. Collaborative filtering, on the other hand, relies on user-item responses or 'ratings' (see infra) of an individual user u as well as those of other users in the system [START_REF] Desrosiers | A Comprehensive Survey of Neighborhood-based Recommendation Methods[END_REF]. Recommendations are made by finding correlations among users of a recommendation system [START_REF] Pazzani | A Framework for Collaborative, Content-Based and Demographic Filtering[END_REF]: "[t]he key idea is that the rating of u for a new item i is likely to be similar to that of another user v if u and v have rated other items in a similar way. Likewise, u is likely to rate two items i and j in a similar fashion, if other users have given similar ratings to these two items" [START_REF] Desrosiers | A Comprehensive Survey of Neighborhood-based Recommendation Methods[END_REF]. User-item ratings can, moreover, either be used directly to predict ratings for new items, or employed to learn a predictive model [START_REF] Desrosiers | A Comprehensive Survey of Neighborhood-based Recommendation Methods[END_REF]. Hybrid systems combine several filtering techniques, such as the aforementioned ones, in order to further improve their results [START_REF] Ricci | Recommender Systems Handbook[END_REF][START_REF] Vozalis | Collaborative filtering enhanced by demographic correlation[END_REF].

Figure 1. Collaborative filtering and content-based filtering [START_REF] Mohamed | Recommender Systems Challenges and Solutions Survey[END_REF].

In order to be capable of providing suggestions, recommender systems, in any event, need to create and maintain a user profile per individual consumer that captures the latter's preferences over time [START_REF] Karimi | News recommender systems -Survey and roads ahead[END_REF]. Each type of recommender system however has its own approach to learning user profiles as they use different kinds of data and represent information in a different manner [START_REF] Pazzani | A Framework for Collaborative, Content-Based and Demographic Filtering[END_REF]. Often, the content of read news items is used to deduct consumer interest (content-based filtering) and/or user features are being considered in comparison to those of others (collaborative filtering) [START_REF] Karimi | News recommender systems -Survey and roads ahead[END_REF]. Some approaches, in addition, consider people's demographic information, for example, to overcome the so-called cold-start problem, which refers to situations where either little is known about a user's preferences or an item has not sufficiently been viewed or rated [START_REF] Karimi | News recommender systems -Survey and roads ahead[END_REF][START_REF] Lika | Facing the cold start problem in recommender systems[END_REF].

In as far as the provision of customised reading suggestions to consumers is based on 'information relating to an identified or identifiable individual'thus leaving aside item-only data used in content-based filtering -, the data used qualifies as 'personal data' within the meaning of Article 4(1) of the EU's General Data Protection Regulation ('GDPR') [START_REF]Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data[END_REF]. In terms of personal data 'processing', which the GDPR defines as "any operation or set of operations [that] is performed on personal data or on sets of personal data" [20 art 4(2)], news personalisation essentially evolves in three stages: collection, profiling and recommending [START_REF] Verdoodt | Targeting children with personalised advertising : how to reconcile the (best) interests of children and advertisers[END_REF].

First of all, news providers, gather several data points per reader. Hence, they keep record of information provided by users when creating an account (e.g.: gender, age, location) or for receiving newsletters (e.g.: email address), as well as of so-called user 'ratings' [START_REF]Overeenkomst voor gegevensgebruik ('agreement for data use') Mediahuis[END_REF]. The latter take a variety of forms as they can be either scalar/numerical (e.g.: 1-5 stars), ordinal (e.g.: agree, neutral, disagree), binary (e.g.: like/dislike), or unary in case the interaction of a user with an item is implicitly captured (e.g.: time spent browsing it). The amassing of the latter can take place through the use of cookies, which can be described as small pieces of data a site asks your browser to store on your computer, tablet or mobile phone [23]. They allow the recognition of your device upon return and remember, depending on their specific function, certain of your actions and preferences over time [23]. In a second step, the collected material is evaluatedwhere appropriate in combination with data relating to other usersusing statistics and artificial intelligence, to predict a news consumer's preferences or interests, and consequently, what news items are most suitable to recommend to him or her [START_REF] Ricci | Recommender Systems Handbook[END_REF][START_REF]European Data Protection Supervisor: Towards a new digital ethics. Data, dignity and technology[END_REF]. This process coincides with the GDPR-definition of 'profiling' [20 art 4(4)]. Finally, users are offered recommendationswhich can be reflected in user interfaces in several manners (see supra)in relation to specific items when (re-)visiting news sites.

A prohibition based on Article 22 GDPR and freedom to form thoughts and opinions concerning matters of general interest

In view of the foregoing, the question arises whether Article 22 GDPR on 'automated decision-making, including profiling' applies to news personalisation as described and if so, what would be the implications thereof.

The first paragraph of said provision provides that:

"The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her".

According to the Article 29 Data Protection Working Party, the previous independent European advisory body on data protection and privacy and predecessor of the European Data Protection Board, Article 22(1) contains a general prohibition and is accordingly relevant regardless of whether a potentially affected individual takes any action [START_REF]Article 29 Data Protection Working Party: Guidelines on Automated individual decision-making and Profiling for the purposes of Regulation[END_REF]. Instead, its applicability depends on the fulfilment of two requirements: a decision involving a natural person must be made 'solely' as a result of automated processing, including profiling, and affect a data subject's legal rights or produce an effect concerning him or her that is equivalent or similarly significant in its impact [START_REF]Article 29 Data Protection Working Party: Guidelines on Automated individual decision-making and Profiling for the purposes of Regulation[END_REF].

Generating news recommendations by solely automated means

As regards the first criterion, the Article 29 Group explains that "[a]n automated process produces what is in effect a recommendation concerning a data subject" [START_REF]Article 29 Data Protection Working Party: Guidelines on Automated individual decision-making and Profiling for the purposes of Regulation[END_REF]. As becomes clear from the descriptions above, in case of news personalisation, a set of operations is performed on personal (user), and in case of content-based filtering also nonpersonal (item), data which results in (a list of) recommended content [START_REF] Ricci | Recommender Systems Handbook[END_REF]. For the purposes of Article 22, each individual suggestion can be considered a 'decision' based on the 'processing' of personal data, and more specifically, on its collection for learning user profiles and predicting individuals' (lack of) interest in certain items, and use to eventually offer news consumers individualised suggestions [START_REF] Eskens | A right to reset your user profile and more: GDPR-rights for personalized news consumers[END_REF]. Recommendations are moreover generated by 'solely automated means', which entails that an algorithm decides which articles will be proposed and that their delivery to the reader happens automatically, without any prior meaningful assessment by a human [START_REF]Article 29 Data Protection Working Party: Guidelines on Automated individual decision-making and Profiling for the purposes of Regulation[END_REF]. Recommender systems, indeed, "provide automated and personalised suggestions […] to consumers" (emphasis added) [START_REF] Desrosiers | A Comprehensive Survey of Neighborhood-based Recommendation Methods[END_REF]. They "have evolved to fulfil the natural dual need of buyers and sellers by automating the generation of recommendations based on data analysis" (emphasis added) [26 at "Recommender Systems"].

Limitations on the basis of the freedom to form thoughts and opinions concerning matters of general interest

To fall within the scope of Article 22 GDPR, decision-making furthermore needs to produce either 'legal' or 'similarly significant' effects concerning the data subject [START_REF]Article 29 Data Protection Working Party: Guidelines on Automated individual decision-making and Profiling for the purposes of Regulation[END_REF].

We argue that news personalisation may potentially interfere withand thus violate (see infra) -a person's fundamental rights to freedom of thought and freedom of opinion and could therefore indeed affect his or her legal rights in breach of the prohibition laid down by said provision [START_REF]Article 29 Data Protection Working Party: Guidelines on Automated individual decision-making and Profiling for the purposes of Regulation[END_REF].

Freedom of thought and freedom of opinion are respectively contained in two consequent provisions of the European Convention on Human Rights ('ECHR') [START_REF]European Convention for the Protection of Human Rights and Fundamental Free[END_REF]. More specifically, Article 9(1) ECHR provides that "everyone has the right to freedom of thought"as well as of "conscience and religion" -, while Article 10(1) ECHR, on freedom of expression, grants individuals "freedom to hold opinions". According to the majority opinion in legal doctrine, these two freedoms essentially overlap in scope [START_REF] Nowak | Covenant on Civil and Political Rights: CCPR commentary[END_REF][START_REF] Velaers | De beperkingen van de vrijheid van meningsuiting[END_REF], which is why we consider them as one and the same for the purposes of the analysis in this contribution. Statements concerning either one of them will therefore also be considered true in relation to the other. These freedoms involve the area often referred to as the forum internum [START_REF] Murdoch | Freedom of thought, conscience and religion. A guide to the implementation of Article 9 of the European Convention on Human Rights[END_REF]. It is crucial to note that they are absolute and unconditional and can therefore not be restricted or interfered with without being violated [START_REF] Nowak | Covenant on Civil and Political Rights: CCPR commentary[END_REF][START_REF] Schabas | The Universal Declaration of Human Rights: the Travaux Préparatoires[END_REF][START_REF][END_REF]. Indeed, Article 9(2) ECHR only allows limitations in relation to the freedom to manifest one's religion or beliefs. Whereas Article 10(2) ECHR, on the other hand, in general terms provides that the exercise of the freedoms listed in its first paragraph (see infra) may be subject to restrictions, the Council of Europe's Committee of Ministers has stated that allowing any in relation to the freedom to hold opinions "will be inconsistent with the nature of a democratic society" [START_REF] Macovei | Freedom of expression. A guide to the implementation of Article 10 of the European Convention on Human Rights[END_REF].

The right to freedom of thought and opinion, apart from freedom to have and hold thoughts and opinions (first dimension), also guarantees freedom to form and develop them (second dimension) [START_REF] Schabas | The Universal Declaration of Human Rights: the Travaux Préparatoires[END_REF][START_REF] Murdoch | Protecting the right to freedom of thought, conscience and religion under the European Convention on Human Rights[END_REF]. This latter liberty in particular constitutes the subject of further analysis in the context of this contribution. In the past, States have not found it difficult to allow people freedom to think [START_REF] Scheinin | The Universal Declaration of Human Rights: a commentary[END_REF]. Some even considered it impossible to restrict this freedom as it protects the realm of the mind (forum internum) [START_REF] Velaers | De beperkingen van de vrijheid van meningsuiting[END_REF]. This may explain the lack of case-law specifically dealing with the freedoms of thought and opinion up to now. In view of the emergence of new technologies such as those described above, their value may nonetheless become more tangible [START_REF]Committee of Ministers: Declaration on the manipulative capabilities of algorithmic processes[END_REF][START_REF]European Data Protection Supervisor: Online manipulation and personal data[END_REF][START_REF]European Data Protection Board: The use of personal data in the course of political campaigns[END_REF][START_REF]Amnesty International: Surveillance giants: how the business model of google and facebook threatens human rights[END_REF]. Importantly, the guarantee of the right to freely form and develop thoughts and opinions depends on the right to receive information and ideas. Indeed, the free formation of thoughts and opinions is only possible when one is properly informed [START_REF] Velaers | De beperkingen van de vrijheid van meningsuiting[END_REF]. People are influenced by the information they are presented with [START_REF] Bowman V | the United Kingdom[END_REF]. When such influencing reaches an unacceptable level, the right to freedom of thought and opinion will however be considered interfered with [START_REF] Nowak | Covenant on Civil and Political Rights: CCPR commentary[END_REF][START_REF] Bossuyt | Guide to the "travaux Préparatoires" of the International Covenant on Civil and Political Rights[END_REF][START_REF] Vermeulen | Permissibility of news personalisation in view of the freedoms of thought and opinion[END_REF][START_REF]nature and scope of the right to freedom of opinion and expression, and restrictions and limitations to the right to freedom of expression[END_REF]. The freedom of opinion formation, in turn, constitutes a prerequisite for the realisation of a person's right to freely express his or her thoughts and opinions, for these have to be conceived before the can be voiced [START_REF] Schabas | The Universal Declaration of Human Rights: the Travaux Préparatoires[END_REF]. This latter right as well as the freedoms to receive and impart information and ideas are also encompassed in Article 10(1) ECHR. It may be pointed out that these, unlike the freedom of thought and opinion, can justifiably be restricted, provided that the conditions thereto laid down by Article 10(2) ECHR in that regard are fulfilled [START_REF] Velaers | De beperkingen van de vrijheid van meningsuiting[END_REF].

At this point, it is important to note that the freedom of expression rights serve a dual purpose. More specifically, they are directed at both the individual and the citizen [START_REF] Velaers | De beperkingen van de vrijheid van meningsuiting[END_REF]. In the first place, freedom of expression, as other liberal rights, enables individuals to ward off interferences by the State [START_REF] Nowak | Covenant on Civil and Political Rights: CCPR commentary[END_REF]. As such it delineates a sphere of freedom or autonomy for their personal development [START_REF] Velaers | De beperkingen van de vrijheid van meningsuiting[END_REF]. People are free to form innerpurely privatethoughts and opinions as well as to express them publicly in the "market place of ideas" without fear of repression [START_REF] Nowak | Covenant on Civil and Political Rights: CCPR commentary[END_REF]. While the latter takes place in public, it is nonetheless considered an essential component of the individual's privacy being the externalization of one's personality [START_REF] Nowak | Covenant on Civil and Political Rights: CCPR commentary[END_REF][START_REF] Velaers | De beperkingen van de vrijheid van meningsuiting[END_REF]. Next to 'liberté-autonomie', the freedom of expression is also conceived as 'liberté-participation' [START_REF] Nowak | Covenant on Civil and Political Rights: CCPR commentary[END_REF]. As such, it aims at the social integration of a person in society rather than at warding off interferences [START_REF] Nowak | Covenant on Civil and Political Rights: CCPR commentary[END_REF]. In accordance with settled case-law of the European Court of Human Rights ('ECtHR'), citizens have, more specifically, the right to express their opinions on political matters as well as regarding issues of public interest more generally and, accordingly, to take part in public debate [START_REF] Slovakia | [END_REF][START_REF][END_REF]. The Court considers, more generally, that "freedom of political debate"to be understood as including debate on all matters of public interest [START_REF] Mendel | Freedom of Expression: A Guide to the Interpretation and Meaning of Article 10 of the European Convention on Human Rights[END_REF] -"is at the very core of the concept of a democratic society which prevails throughout the Convention" [47]. Accordingly, it ruled on several occasions that it requires "very strong reasons for justifying restrictions on such debate" [START_REF][END_REF]48]. The twofold function of Article 10 of the European Convention was famously underscored by the ECtHR for the first time in its Handyside v. the UK judgment where it stated that "[f]reedom of expression constitutes one of the essential foundations of [a democratic] society, one of the basic conditions for its progress and for the development of every man" [START_REF] Handyside V | the United Kingdom[END_REF]. Both purposes are moreover complementary. Whereas 'uninfluenced'in as far as that is possibleopinions of individuals form the basis of democratic debate, taking part therein as a citizen constitutes the best method to safeguard the autonomous sphere [START_REF] Velaers | De beperkingen van de vrijheid van meningsuiting[END_REF].

Importantly, the Court in Strasbourg views the press as the most important enabler for the realisation of the public debate freedom [START_REF] Van Hoboken | Search engine freedom: on the implications of the right to freedom of expression for the legal governance of Web search engines[END_REF]. This explains both why this actor is attributed special protection (which will however not be the subject of further discussion here) and assigned certain responsibilities under Article 10 of the Convention [START_REF] Van Hoboken | Search engine freedom: on the implications of the right to freedom of expression for the legal governance of Web search engines[END_REF]. In Leander v. Sweden, it was decided that a person, in general, has a right to receive information and ideas that others wish or may be willing to impart to him or her [START_REF] Leander V. Sweden | [END_REF]. However, in cases such as Lingens v. Austria and Şener v. Turkey, the Court held that the press has the task of imparting information and ideas on political issues just as on those in other areas of general interest and that the public has a right to receive them [47,[START_REF] Turkey | [END_REF]. This was explained by the fact that freedom of the press affords the public one of the best means of discovering and forming an opinion [47,[START_REF] Turkey | [END_REF]. In the case of Khursid Mustafa v. Sweden, which concerned a conflict between two private parties, the Court confirmed that also individual applicants are free to receive "political and social news" or "reports on events of public concern" as they constitute "the most important information protected by Article 10" [START_REF] Mustafa | [END_REF]. The freedom to receive information and ideas can thus be considered dependent on the freedom to impart information and ideas [START_REF] Macovei | Freedom of expression. A guide to the implementation of Article 10 of the European Convention on Human Rights[END_REF].

Freedom to receive information and ideas moreover entails that people are free to consume available content and undertake the necessary steps to inform themselves [START_REF] Velaers | De beperkingen van de vrijheid van meningsuiting[END_REF]. They may gather information through all possible lawful sources [START_REF] Macovei | Freedom of expression. A guide to the implementation of Article 10 of the European Convention on Human Rights[END_REF] . As such, everyone has the right to buy books, magazines or newspapers [START_REF] Velaers | De beperkingen van de vrijheid van meningsuiting[END_REF]. Whereas publishing can be considered to take place in the public sphere, reading on the other hand is in essence a private activity [START_REF] Van Hoboken | Search engine freedom: on the implications of the right to freedom of expression for the legal governance of Web search engines[END_REF]. In that regard, it can be noted that the EU High-Level Expert Group on Artificial Intelligence identified 'respect for human autonomy' as the first of four ethical principles which should be respected in order to ensure that AI systems are developed, deployed and used in a trustworthy way [START_REF]High-Level Expert Group on Artificial Intelligence: Ethics Guidelines for Trustworthy AI[END_REF]. Rooted in human rights theory, this norm puts forward that "humans interacting with AI systems must be able to keep full and effective self-determination over themselves, and be able to partake in democratic process" [START_REF]High-Level Expert Group on Artificial Intelligence: Ethics Guidelines for Trustworthy AI[END_REF]. As explained above, the participation of citizens in society indeed necessitates individual autonomy (and vice versa) [START_REF] Velaers | De beperkingen van de vrijheid van meningsuiting[END_REF]. The right to freedom of thought and opinionin its second dimensionis however only interfered with when one's thoughts and opinions are being influenced to an extent their free formation could be corrupted and such thus exceeds a certain threshold [START_REF] Nowak | Covenant on Civil and Political Rights: CCPR commentary[END_REF][START_REF] Bossuyt | Guide to the "travaux Préparatoires" of the International Covenant on Civil and Political Rights[END_REF][START_REF] Vermeulen | Permissibility of news personalisation in view of the freedoms of thought and opinion[END_REF][START_REF]nature and scope of the right to freedom of opinion and expression, and restrictions and limitations to the right to freedom of expression[END_REF]. The question is, therefore, whether the (lack of) information one receives as a result of the customisation of his or her online news offer at a news website can reasonably be considered to have a 'sufficiently' significant effect on the formation or development of one's inner ideas concerning matters of general interest. Rather than evaluating the (in)existence or dangers of filter bubbles [START_REF] Borgesius | Should we worry about filter bubbles?[END_REF][START_REF] Möller | Filterbubbels in Nederland[END_REF], the aim is thus to assess whether news personalisation could impede citizens from being adequately informed and, as a consequence thereof, from forming their opinions. In view of the fact that establishing the actual impact of phenomena such as news personalisationin all its formsrequires extensive and continuously updated empirical findings [START_REF] Susser | Online Manipulation: Hidden Influences in a Digital World[END_REF], this contribution presents a theoretical framework for analysis and is based on legal research.

It can be noted that the media, irrespective of their intentions with respect to personalisation, presume an important gatekeeper role [START_REF] Van Hoboken | Search engine freedom: on the implications of the right to freedom of expression for the legal governance of Web search engines[END_REF]. They function as intermediaries between speakers and sources of information on the one hand, and the public on the other [START_REF] Van Hoboken | Search engine freedom: on the implications of the right to freedom of expression for the legal governance of Web search engines[END_REF]. However, as explained, the ECtHR expects the press to at least inform people on events of interest [START_REF] Nowak | Covenant on Civil and Political Rights: CCPR commentary[END_REF]47,[START_REF] Turkey | [END_REF]. In Lingens v. Austria, the Court added that it could not accept the opinion of the Austrian domestic authorities "to the effect that the task of the press was to impart information, the interpretation of which had to be left primarily to the reader" [47]. The Court, in the case of Stoll v. Switzerland, in a similar vein, pointed to the influence wielded by the media in contemporary society: "not only do they inform, they can also suggest by the way in which they present the information how it is to be assessed" [START_REF] Stoll V | [END_REF]. Provided that journalists "are acting in good faith and on an accurate factual basis and provide "reliable and precise" information in accordance with the ethics of journalism" [START_REF] Stoll V | [END_REF], it is thus accepted for media outlets to be influencing their audience by means of how they report on issues of public concern. Manfred Nowak, Professor of International Human Rights [START_REF] Professor | [END_REF], considered, however, that "[i]t is not easy to delineate between the (impermissible) interference with freedom of opinion and (permissible) daily influencing of the formation of our opinions […] by all the news, commentary and information disseminated by the mass media in our communications and information society" [START_REF] Nowak | Covenant on Civil and Political Rights: CCPR commentary[END_REF]. This seems to suggest that the latter, distributing news items to every consumer alike, are nonetheless at the limits of what can be considered acceptable influence. Therefore, and having regard to the freedom to consume published informationparticularly relating to matters of public interest -, the individualisation of people's feeds might go too far. In that regard, it may be interesting to note that according to the New York Times even its most active users only read a handful of the 200 news stories it puts out each day [START_REF] Slefo | New York Times" plans to invest heavily in AI[END_REF].

Moreover, in line with what David Kaye, the current Special Rapporteur on the promotion and protection of the right to freedom of opinion and expression, stated in his 2018 Annual Report, online content curation by means of technology may negatively impact an individual's capacity to form opinions in view of the fact that algorithmic ranking may induce users to believe that items recommended to them are particularly worth reading at a given moment in time [43 point 24-25]. He noted moreover that "media outlets elevate particular stories to the front page with the intention of shaping and influencing individual knowledge about significant news of the day" [60 point 24]. Having regard to the case-law of the ECtHR referred to above, this seems indeed what the structuring or placement of articles by news media, both print and electronic, first and foremost should lead to.

Therefore, we argue that news personalisation at news websites, to the extent it would impede people from having the possibility of being informed (1a) and/or informing themselves about matters of public concern (1b), and/or impair their intellectual capacity to assess the general importance of the news items they are being recommended (2), surpasses the limits of influencing acceptable in light of the freedom of thought and opinion.

When online newspapers offer recommendations only in addition and next to the main news items of the day, provided that the latter can be distinguished from the former, are bundled together and displayed in order of importance, neither of these issues (1a, 1b and 2) seem to be present. In such circumstances, readers wishing to be informed concerning matters of interest to accordingly form their opinions are not hindered in that respect (1) and are enabled to assess the respective public interest value of the items [START_REF]Cookies on the Guardian website[END_REF]. Personalisation would as such not negatively affect public debate. News providers could for example maintain a general page and as a supplementary service offer their audience personalised reading suggestionsby means of sidebars, below articles, via an additional personal page etc. Considering personalisation in such circumstances only concerns articles lacking public interest value, the fact whether or not a user has an explicit say regarding the determination of his or her preferences (see supra) is of secondary importance in the context of this analysis. The same cannot be said in case news personalisation at news websites takes the form of a personalised page without there being available a designated section regarding important items. Instead, such articles would be shown more or less prominently depending on the individual profile of the reader concerned. If generated recommendations would moreover be based on one's implicitly inferred interests, a reader might not only miss out on articles concerning issues of general interest (1a), but would at the same time be deprived of the freedom to consume the news items amongst those of importance which they themselves consider the most relevant (1b). Considering people, in case of implicit personalisation, would be offered a list of recommendations in accordance with their presumed preferences, it can moreover be assumed that their ability to assess their respective societal weightiness would be affected as well [START_REF]Cookies on the Guardian website[END_REF]. Explicit personalisation on the contrary empowers (1b) users to a certain extent as it allows them to ban certain types of content from their feed while giving them the opportunity to 'adjust' their preferences and perhaps even 'select all' (1a) available predetermined topics, events, etc. In the latter case they should however again somehow be enabled to distinguish between information of general interest and other news (2).

Personalisation

Additional -only Explicit 1a, 1b, 2 1a(?), 1b, 2(?) Implicit 1a, 1b, 2 

In order to put this analysis into perspective, the potential effects of news personalisation can be compared to those of (political) micro-targeting practices, which are also considered to violate people's freedom of opinion in some case [START_REF]Committee of Ministers: Declaration on the manipulative capabilities of algorithmic processes[END_REF][START_REF]European Data Protection Board: The use of personal data in the course of political campaigns[END_REF]. As explained, the former could influence the formation of one's thoughts on issues of general interest in view of the fact that it may impede a person from receiving information about such matters and from assessing the respective importance of the articles he or she is recommended. The latter, on the other hand, is problematic when it amounts to manipulation and affects our cognitive autonomy [START_REF]Committee of Ministers: Declaration on the manipulative capabilities of algorithmic processes[END_REF]. A manipulator seeks to insinuate himself in a target's decision-making process and thus deprives the individual of the authorship over his or her ideas [START_REF] Susser | Online Manipulation: Hidden Influences in a Digital World[END_REF]. Whereas micro-targeting could hinder the free development of thoughts (second dimension), it might also affect the freedom to have a personal opinion as its purpose is to have people adopt another point of view (first dimension).

Explicit consent as an exception

Considering the fact that Article 22(1) GDPR sets out a general prohibition, online newspapers should in principle not engage in a type of news individualisation that could violate Articles 9 and 10 ECHR [START_REF]Article 29 Data Protection Working Party: Guidelines on Automated individual decision-making and Profiling for the purposes of Regulation[END_REF]. However, Article 22(2) contains three exceptions to this rule. Considering its problematic nature, the following analysis will in that respect focus on implicit personalisation-only news websites. First of all, point (a) of Article 22(2) sets out that paragraph 1 shall not apply if the decision "is necessary for entering into, or performance of, a contract between the data subject and a data controller". The EDPB recently, in version 2.0 of its guidelines on the processing of personal data under Article 6(1)(b) GDPR in the context of the provision of online services to data subjects, acknowledged that "personalisation of content may (but does not always) constitute an intrinsic and expected element of certain online services, and therefore may be regarded as necessary for the performance of the contract with the service user in some cases" [START_REF]Guidelines on the processing of personal data under Article 6(1)(b) GDPR in the context of the provision of online services to data subjects[END_REF]. In the draft text, it stated that online news aggregator websites, whose services consist of "providing users with tailored content from multiple online sources through a single interface", may rely on contract as a legal basis for processing "because the function of the service directly relates to personalised content" [START_REF]Guidelines on the processing of personal data under Article 6(1)(b) GDPR in the context of the provision of online services to data subjects (Version for public consultation[END_REF]. In view of the fact that the press itselfmeaning (online) news providers (see supra)carries a great responsibility in informing the public so as to facilitate public debate, it cannot be accepted that their primary purpose could also be to customise their readers' news offer in accordance with the latter's preferences. The example concerning news aggregators has moreover been deleted in the second version of the EDPB guidelines. Therefore, we consider that online newspapers may not use Article 22(2)(a) GDPR to deploy a personalisation-only news service that relies on implicit profiling techniques. Secondly, point (b) provides that automated individual decision-making would be permissible in case its use "is authorised by Union or Member State law". As such is not the case for news personalisation, this exception too is not relevant here.

Of particular importance in this context however is third onepoint (c) -, which stipulates that the prohibition does not apply if the decision-making "is based on the data subject's explicit consent". To be validly expressed, consent must (amongst others) be 'informed' [20 art 4(11)]. According to recital 42 GDPR, this entails that the data subject should be aware of the purposes of the processing for which the personal data are intended. Article 29 Working Party has explained in that regard that "where the processing involves profiling-based decision making" it must be made clear to the person concerned "that the processing is for the purposes of both (a) profiling and (b) making a decision based on the profile generated" [START_REF]Article 29 Data Protection Working Party: Guidelines on Automated individual decision-making and Profiling for the purposes of Regulation[END_REF]. Moreover, data subjects must "understand exactly what they are consenting to" and "have enough relevant information about the envisaged use and consequences of the processing to ensure that any consent they provide represents an informed choice" [START_REF]Article 29 Data Protection Working Party: Guidelines on Automated individual decision-making and Profiling for the purposes of Regulation[END_REF]. In view of the analysis above, this means that online news providers engaging in implicit personalisation-only type of services should explain to potential consumers that the articles in their future news feed will be ranked in accordance with their own preferences rather than taking into account the societal interest of the items. The GDPR also requires a data subject's consent regarding the processing of his or her personal data to be 'freely given' [20 art 4(11)]. As stated in recital 42 of the GDPR, such is not the case "if the data subject has no genuine or free choice or is unable to refuse or withdraw consent without detriment". It has been argued that this requirement inherently conflicts with so-called "take it or leave it"-practices [START_REF] Gdpr | eu filed four complaints over "forced consent" against Google[END_REF] which lead to the de facto exclusion of data subjects from being provided with the service concerned in case they do not consent. Indeed, forcing users to accept the placement of so-called tracking cookies, which are used to collect user behaviour information (see supra), due to the fact that a refusal entails that a website simply cannot be accessed, is therefore often considered unlawful [START_REF]The CNIL's restricted committee imposes a financial penalty of 50 Million euros against GOOGLE LLC[END_REF][START_REF]Autoriteit Persoonsgegevens: Websites moeten toegankelijk blijven bij weigeren tracking cookies[END_REF][66]. This would imply that news personalisation at a specific news website should in fact never be mandatory, though, in contrast, always ought to be optional. In this context consent must moreover be 'explicit' and therefore manifested by means of an express statement [67]. When processing entails significant risks, a high level of control over personal data is thus deemed appropriate [START_REF]Article 29 Data Protection Working Party: Guidelines on Automated individual decision-making and Profiling for the purposes of Regulation[END_REF]. In the digital or online context, the Article 29 Working Party explains that "a data subject may be able to issue the required statement by filling in an electronic form, by sending an email, by uploading a scanned document carrying the signature of the data subject, or by using an electronic signature" [67]. A two stage verification of consent, whereby a person is requested to reply to an email in which is asked for consent by "I agree" and subsequently receives a verification link or code that must be clicked to confirm agreement, can also suffice [67]. In such circumstances, consenting through cookie banners (see supra) cannot be allowed.

In the context of their transparency obligations, Article 13(2)(f) GDPR moreover requires controllers [20 art 4(7)], at the time when personal data are obtained from the data subjectas we assume in this paper they would be -, to provide them with specific information in case they engage in processing activities as referred to in Article 22 GDPR. They must, first of all, inform readers about the fact that they do so, which in case the processing is based on consent they already should have (see supra). Secondly, and "at least in those cases, meaningful information about the logic involved" must be provided. According to the Article 29 Working Party this requires finding "simple ways to tell the data subject about the rationale behind, or the criteria relied on in reaching the decision" [START_REF]Article 29 Data Protection Working Party: Guidelines on Automated individual decision-making and Profiling for the purposes of Regulation[END_REF]. Finally, controllers should explain "the significance and the envisaged consequences of [the] processing". This requirement comes down to clarifying "how the automated decision-making might affect the data subject" [START_REF]Article 29 Data Protection Working Party: Guidelines on Automated individual decision-making and Profiling for the purposes of Regulation[END_REF]. As explained above, also this information should normally be obtained by the latter also earlier on and namely prior to agreeing to the processing.

Article 22(3) GDPR, in addition, states that "in the case […] referred to in point […] (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject's rights and freedoms", in casu being his or her right to freedom of thought and opinion. At the least, a person should be granted the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision [20 art 22(3)]. While in case of news personalisation the implications of these assurances are, admittedly, not straightforward, some ideas may nonetheless be posited in that respect. Considering that the Working Party put forward that any review must be carried out by someone who has the capability to change the decision, data subjects might be able to request the adjustment of their profileand with that the recommendations based thereonin case they feel impeded from receiving information and ideas of general importance. However, bearing in mind that user preferences are determined by algorithmic means (see supra) and therefore not readily adaptable by human beings, the only practical solution might be to completely reset a user profilesomething which is said to be also possible on the basis of the right to erasure ('right to be forgotten') laid down in Article 17 of the GDPR [START_REF] Eskens | A right to reset your user profile and more: GDPR-rights for personalized news consumers[END_REF]. The relevance of being able to express one's opinion and to contest the decision might be similar.

Lastly, it can be noted that Article 22(4) GDPR in principle prohibits decisions referred to in paragraph 2 to be based on special categories of personal data unless "the data subject has given explicit consent to the processing of those personal data for one or more specified purposes" or "processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law" [20 art 22(4), 9(1), 9(2)(a),(g)]. Article 9(1) GDPR specifies that such categories (amongst others) include data revealing political opinions and philosophical beliefs. Therefore, if a news consumer would, as a result of implicit personalisation, be recommended more articles concerning either left or right-wing political parties or touching upon topics associated with progressive rather than conservative convictions or vice versa, this could be problematic. In the context of this analysis, we consider moreover that only the first-mentioned exception can be applied.

Conclusion

More and more often, personalisation at news websites is being introduced. It can be done on the basis of explicitly registered or implicitly inferred user preferences, take several forms and rely on different types of (implicit) filtering techniques. Customising consumers' news offer, however, requires the processing of personal data, and more specifically its collection as well as use for profiling and the eventual delivery of recommendations. In view of the fact that providing users with individualised news recommendations is usually realised by solely automated means and has the potential to violate people's absolute and non-derogable rights to freedom of thought and freedom of opinion, it could be prohibited on the basis of Article 22(1) of the EU General Data Protection Regulation. The adaptation of news feeds according to implicitly inferred user profiles without there being available a designated section regarding important news does, in any event, not appear acceptable. However, news consumers could, as foreseen by Article 22(2) GDPR, nonetheless explicitly agree to such employment of their personal information, though only provided that they would be offered an informed and genuine choice in that regard. In such circumstances, online newspapers must also provide their readers with simple and meaningful information concerning the rationale behind the algorithm used and the recommendations it generates. The latter can moreover only be based on a person's political opinions or philosophical beliefs in case he or she gave its explicitly consented thereto. Ideally, online newspapers abstain from becoming personalisation-only forums and give users some form of control as regards the determination of their reading preferences and interests.

Figure 2 .

 2 Figure 2. Freedom of expression as a participatory right.

Figure 3 .

 3 Figure 3. Permissibility of Personalisation at News Websites.