Smart cameras remain not fully operational, with delays in compliance with Law 5256/2025
Following relevant legal actions taken by Homo Digitalis, it has been revealed that the Unified Electronic System for recording and managing Road Traffic Code violations and fines (E.I.S.), established by Law 5256/2025 in December 2025, remains not fully operational, while there is also insufficient compliance with both the prescribed timelines and the legal obligations.
Road safety and the protection of all drivers, passengers, and pedestrians constitute an important objective. However, the manner in which the recently adopted legal framework is being implemented, as well as the installation and use of the relevant surveillance systems and their accompanying algorithms, creates challenges both for the accountability of the competent authorities and for the protection of everyone’s rights.
Numerous reports in print, television, and online media circulated inaccurate information for a prolonged period, claiming that the E.I.S. is not only fully operational, but also already capable of automatically imposing fines for violations such as mobile phone use, failure to wear a helmet, or failure to use a seatbelt while driving.
In February and March 2026, Homo Digitalis decided to make use of every legal instrument and all guarantees provided by law in order to ascertain the progress of the implementation of the E.I.S., and whether the timelines, as well as the adoption of the relevant ministerial decisions and cooperation protocols required by law, have been observed.
Specifically, on 24 February, we submitted a Request for Access to Documents to Mr. Ioannis Melas, Director of the Independent Service named “Road Supervision and Safety Systems Service (OD.Y.S.E.A.S.)” of the Ministry of Infrastructure and Transport. Through this request, we sought access to the data protection impact assessment and the algorithmic impact assessment relating to the pilot application, which, according to the Diavgeia website, appear to have been prepared. Furthermore, since well before the adoption of the legal framework—and in particular since 31/07/2025—a direct award had been published on Diavgeia to the company “EVR.ILEK LIMITED LIABILITY COMPANY” for the Development of a Pilot Information System for recording and analyzing traffic violation data, we also called upon OD.Y.S.E.A.S. to grant us access to this contract.
We also requested the Service, as required under Law 5256/2025, to inform us about the criteria and methodology on the basis of which the specific locations for the installation of the pilot system were selected, as well as the objective and technical criteria that led to the differentiation of the technologies used at each installation point (integrated radar for “Spot Speed” control, systems for detecting non-use of helmets, non-use of seatbelts, use of mobile phones while driving, as well as systems for recording red light violations, etc.).
Moreover, pursuant to Article 23(11) of Law 5256/2025, which provides that all technical and detailed matters concerning the protection of natural persons against processing carried out through the E.I.S. are to be regulated by a joint ministerial decision of the Ministers of Infrastructure and Transport, Digital Governance, and Citizen Protection, in accordance with Article 16 (Personal data protection issues), we requested that OD.Y.S.E.A.S. provide us with a copy of this Joint Ministerial Decision or, alternatively, inform us of the exact web address where it has been lawfully published. In addition, we requested information regarding the date of commencement of the system’s operation.
Finally, given that Article 23(12) of Law 5256/2025 provides that, by joint decision of the Ministers of Digital Governance, National Economy and Finance, Interior, Justice, and the competent Minister, following an opinion of the Hellenic Data Protection Authority, the operation of the E.I.S. under Article 4 shall determine: (a) the procedure for transmitting data to competent judicial, prosecutorial, and administrative authorities upon lawful request in the exercise of their duties, (b) the manner in which the controller informs the public that they are about to enter an area covered by installed or portable surveillance systems, the content of such information, and additional rights of data subjects beyond those already established under the General Data Protection Regulation and Law 4624/2019, and (c) any other specific or technical matter necessary for the implementation of Article 16, we requested to be informed whether the relevant opinion has been issued by the Hellenic Data Protection Authority.
However, OD.Y.S.E.A.S. tacitly refused to respond to the above request.
At the same time, on 27 February, we filed a complaint before Ms. Alexandra Rogakou, Governor of the National Transparency Authority (NTA), regarding the omission of significant transparency obligations by OD.Y.S.E.A.S. in relation to the pilot operation and use of the E.I.S. More specifically, pursuant to Articles 4 and 5 of Law 4961/2022, public sector bodies using artificial intelligence systems in decision-making processes or in support thereof, affecting the rights of natural or legal persons, are required to carry out an Algorithmic Impact Assessment prior to the system’s operation. Furthermore, under Article 6 of Law 4961/2022, such bodies are subject to transparency obligations, meaning they must publicly provide information on: (a) the date of commencement of the system’s operation, (b) the operational parameters, capabilities, and technical characteristics of the system, (c) the categories of decisions taken or acts issued with the participation or support of the system, and (d) the conduct of an algorithmic impact assessment. Based on the above, we called upon the NTA to examine OD.Y.S.E.A.S.’s compliance with these obligations.
On 23 April, the NTA officially responded to our complaint, informing us that, based on the investigation, the views of the competent service indicated that the joint ministerial decision of the Ministers of Digital Governance, Interior, Citizen Protection, and Infrastructure and Transport, which certifies the full operation of the E.I.S. and its necessary interconnections, has not yet been issued. Furthermore, the NTA sent a document to the competent service requesting information on the date of commencement of the system’s full operation, in order to assess, at a later stage and once the aforementioned certifying act is issued, the service’s compliance with its obligations.
In early March, a further request for access to documents was submitted by Homo Digitalis, this time to the Hellenic Police. According to Article 16(2)(b) of Law 5256/2025, within three (3) months from the entry into force of the law, the joint controllers are required to sign a cooperation protocol defining their relations with data subjects and their respective responsibilities for compliance with obligations arising from the GDPR. Under Article 49 of Law 5256/2025, the law entered into force upon its publication in the Government Gazette, namely on 8 December 2025. Therefore, the Hellenic Police, together with the other joint controllers, should have signed the protocol by 8 March 2026. This protocol is a crucial document, as it defines the relationship between joint controllers and data subjects, as well as their respective responsibilities under the GDPR.
However, the Hellenic Police also tacitly refused to respond to this request.
In conclusion, the implementation of the E.I.S., as established by Law 5256/2025, remains incomplete and is accompanied by significant shortcomings in compliance with the prescribed regulatory and organizational obligations. Homo Digitalis will continue its actions to monitor compliance with the applicable legal framework, in order to ensure both the effectiveness of the system and the full safeguarding of the rights of data subjects at the stage of its future full operation.
We are pleased to grant our auspices to the 16th Infocom Security!
It is a great pleasure for us to once again offer our support to InfoCom Security, a leading Conference & Expo on Cybersecurity.
Specifically, the event took place on April 29 & 30 at the Athens Conservatoire, and registration was free: https://www.infocomsecurity.gr/
Now in its 6th annual edition, it continues to serve as a hub for knowledge exchange, reflection, and progress, featuring keynote speeches, panel discussions, workshops, and the participation of leading organizations from Greece and abroad.
Congratulations to SmartPress S.A. and to Angeliki Nosti and Vlasis Amanatidis for the successful organization and collaboration!
22 Civil Society Organizations & Experts Raise Questions About OpenAI’s Entry into Greek Schools
Today, Monday, March 30, through an Open Letter addressed to the Minister of Education, Religious Affairs and Sports, Ms. Sofia Zacharaki, 22 civil society organizations and experts, including Homo Digitalis, requested official information regarding OpenAI’s programs “AI for Greece” and “Education for Countries” in Greece.
As we note, in September 2025 the Ministry announced the signing of a memorandum of cooperation with OpenAI במסגרת the “AI for Greece” program, without any prior open and transparent consultation with educators, students, parents, or relevant civil society organizations.
Moreover, the Ministry silently refused to respond to a formal request for access to relevant documents submitted by Homo Digitalis, despite the fact that it concerned critical issues such as the protection of students’ and teachers’ personal data in the use of ChatGPT Edu in public schools.
According to available information, the program is being piloted in 20 public secondary education schools and is unfolding in three stages. The first stage involves teacher training (October 2025 – November 2025), the second the use of AI tools by teachers themselves (December 2025 – February 2026), and finally the third the introduction of AI tools into the learning process and their use by students (March – June 2026).
In recent weeks, OpenAI has been at the center of international attention due to its cooperation with the U.S. Department of Defense, raising questions about the potential uses of its technologies beyond U.S. borders, particularly given the lack of clear positioning on issues such as the collection of data from citizens of third countries for surveillance purposes.
At the same time, while discussions at the European Union level intensify around digital sovereignty in the era of artificial intelligence—favoring transparent, auditable, and independent solutions—Greece appears to be moving in the opposite direction. The choice of closed, commercial systems by technology companies such as OpenAI in sensitive sectors like education raises further concerns.
In our open letter, we outline a landscape with more questions than answers regarding the introduction of artificial intelligence into Greek schools. We call for clarification on how the two OpenAI programs in Greece are interconnected, which schools are participating and based on what criteria they were selected, and whether this choice promotes equality or risks exacerbating existing inequalities.
At the same time, we highlight the need to clarify what the use of ChatGPT Edu in the classroom means in practice and whether alternative, transparent, and auditable solutions based on the principles of free and open-source software were considered.
Finally, the issue of personal data protection remains central, as we pose critical questions to the Minister regarding what data is being collected, the purposes of its processing, and the private entities managing it.
You can read the full text of the letter here (EL).*
*On 7 April, the number of legal and natural persons who signed the Open Letter increased. Specifically, signatures were added from NGI Zero and Marianthe Stavridou, NGI Zero Representative for Greece and Vice-Chair Internet Society -CH
Homo Digitalis participates in the 2nd Consultation of the Ministry of Digital Governance on the AI Act
The participation of Homo Digitalis was successfully completed today, March 26, at the 2nd Consultation Forum on the implementation of the Artificial Intelligence Regulation in Greece. The forum was organized by the Special Secretariat for Artificial Intelligence and Data Governance of the Ministry of Digital Governance and Artificial Intelligence, together with Expertise France, within the framework of the project “Integrating AI Technologies in the Greek Public Administration.”
The topics discussed included the outcomes of the 1st Consultation Forum, the EU’s Digital Omnibus on AI package and Greece’s related positions, the draft law for the implementation of the AI Act, proposals for the operation of AI regulatory sandboxes in public administration, the use of Generative AI in the public sector, the new data governance strategy and tools, as well as the proposal for a comprehensive AI governance framework.
We welcome the Secretariat’s initiative to develop a communication channel and to foster a transparent public discussion regarding the progress of the implementing law for the AI Act, and we thank them for the inclusion. Homo Digitalis was represented by our Executive Director, Eleftherios Chelioudakis.
We enhance accountability at Homo Digitalis
At Homo Digitalis, we are committed to being a trustworthy and transparent organization, maintaining high-quality relationships with our team, donors, partners, suppliers, and all stakeholders.
As part of this commitment, we provide a confidential and independent reporting line available 24/7, allowing anyone to anonymously submit concerns or observations.
We would like to extend a heartfelt thank you to AAB for their collaboration in implementing this initiative, and to European AI & Society Fund for their continuous support and trust in the professionalisation of Homo Digitalis!
Read more and access the form in this link.
We filed a complaint against the National Technical University of Athens over the use of cameras!
The National Technical University of Athens features the mythical hero Prometheus in its logo, symbolizing forethought and prudence before action. However, in the case of the cameras, it appears that the institution itself did not demonstrate the foresight that Prometheus represents.
Specifically, noting that there does not appear to be a legal basis allowing the university to operate cameras, and given that the institution itself does not clearly specify in its Data Protection Policy which legal basis it relies on, we submitted an access request on January 13 in order to obtain the answers we are entitled to receive.
The deadline to receive a response passed, and despite our polite reminder, no one responded to our request. Therefore, yesterday we proceeded to file a complaint before the Hellenic Data Protection Authority. You can read more in our Press Release here.
The complaint follows joint actions with the organizations Reporters United and Vouliwatch, within the framework of which a joint request had already been submitted, since September 2025, before the HDPA for the exercise of its investigative powers.
In fact, following a related journalistic report that highlighted these actions in December 2025, the National Technical University of Athens sent an extrajudicial notice to journalist Dafni Karavola of Reporters United in February 2026. You can read more at the new report by Reporters United here.
Homo Digitalis successfully participated in a scientific online event on the Digital Omnibus package
On Thursday, February 26, 2026, Homo Digitalis had the honor of delivering a presentation at a scientific online event organized by the Society of Administrative Studies in collaboration with the European Laboratory for Bioethics, Technoethics and Law of Panteion University, on the topic of the European Commission’s proposals to amend provisions on personal data protection (Digital Omnibus).
Homo Digitalis was represented by Stefanos Vitoratos, while presentations were also delivered by Dr Giorgos Rousopoulos (Hellenic Data Protection Authority) and Dr Zoe Kardasiadou (Official at the European Commission, Directorate-General for Justice and Consumers).
The discussion was moderated by Dr. Fereniki Panagopoulou-Koutnatzi, Associate Professor at Panteion University, while opening remarks were delivered by Dimitrios Skaltsounis, President of the Society of Administrative Studies and former President of the Council of State.
We express our warm thanks to the organizers for the honorable invitation and for the opportunity they offered us to participate in a fruitful dialogue and a meaningful exchange of arguments and views.
Homo Digitalis successfully completed its participation in the AI & Ethics Conference
On Friday, February 20, Homo Digitalis had the great pleasure of speaking at the AI & Ethics Conference!
The conference panels sparked discussions with a critical perspective, while public institutions, the academic community, the market, and civil society exchanged ideas and views on how artificial intelligence can remain human-centered while also being compatible with the protection of Fundamental Rights.
We would like to warmly thank the organizers for their kind inclusion, KEAN – Cell of Alternative Youth Activities, as well as Raina Melissinou and Konstantinos Kechagias for their gracious invitation. Our team was represented by our Executive Director, Eleftherios Chelioudakis.