Homo Digitalis has filed 2 strategic complaints with the Hellenic Data Protection Authority (DPA). The complaints are directed against the Greek Police and concern the storage on its part in a central database of the fingerprints of all holders of Greek passports.

With its 2 complaints (reg. number. 3721/01-06-2020 & 3767/02-06-2020, respectively) Homo Digitalis examines the following sub-issues:

1. The legality of the storage of fingerprints by the Greek Police in its central database and the refusal to delete such personal data.

The Police claims that Presidential Decree 178/2014 allows the storage of the fingerprints of all Greek passport holders in its central database. However, Homo Digitalis argues that the provisions of the Presidential Decree:

– do not refer to the storage of fingerprints in a central database,

– are not in line with recent strict legislation in the field of personal data, and

-do not provide the necessary safeguards to offset the risks of the rights of citizens holding Greek passports.

2. The delayed fulfillment by the Police of the right to information of the data subjects regarding the processing of their data and the way of exercising their rights.

The Police should have published on its website from the end of August 2019 all the necessary information set by Law 4624/2019 to inform what are the rights of data subjects and how these rights can be exercised in practice. However, EL.AS. published this information after 6 months. Homo Digitalis claims that this lack of information created confusion among data subjects about the ways in which they could exercise their rights and significantly delayed their submission of access requests to the Hellenic Post.

3. The representation of data subjects before the Hellenic DPA by civil society organizations, such as Homo Digitalis.

European law obliges EU Member States to allow data subjects to be represented by organizations such as Homo Digitalis when they consider that the protection of their personal data is being violated by police authorities. However, Greek law has not included the relevant provision. Homo Digitalis considers that this shortcoming is a significant violation of European law and acts as a deterrent to the protection of personal data of subjects.

The above two complaints are urgent due to the category of data that are being illegally processed by the Greek Police. (biometric data / fingerprints), as well as the large number of subjects involved in the illegal processing (total holders of Greek passports). Homo Digitalis asked the Hellenic DPA to consider the complaints as an immediate priority.

You can find a brief and understandable information in the form of illustrations regarding the specific complaints here.

You can read the detailed legal analysis regarding the specific complaints here.

This action was carried out completely voluntarily by a group of professionals and scientists, members of Homo Digitalis, without any funding from public or private bodies. If you want to support our actions you can do it here.

On Thursday, 5/6/2020 the Center for Democracy and Technology sent an open letter to the Transport, Telecommunications and Energy Council of the Council of the EU, the Executive Vice-President of the European Commission, M.Vestager and the Commissioner for Internal Market, T.Breton as regards the upcoming legislative proposal on Digital Services (Digital Services Act – DSA).

Homo Digitalis co-signs the letter by the Center for Democracy and Technology along with other known civil society organisations, such as: Access Now, Article 19, Liberties, Civil Right Defenders, Digitale Gesellschaft, epicenter.works, HRMI, Justitia, The Peace Institute and Rights International Spain.

You may read the full text of the open letter in English here.

On Wednesday June 3rd 2020 Homo Digitalis will have the great honour and pleasure of making a contribution on the topic “Algorithms and big data” to the video conference on e-commerce held by the Hellenic Competition Commission.

It is an extraordinary honour for our Organisation that the Competition Commission, having read the relevant memorandum and the proposals (link in Greek) we had submitted mid-May, invited us to participate by making a contribution to its video conference. We warmly thank the Commission for the invitation.

The video conference will present an excellent opportunity for us to elaborate on our positions and proposals as well as exchange ideas and opinions with the President of the Competition Commission, the Rapporteurs and the Investigation team of the Commission and the other contributors and participants of the video conference.

Once again, the praise goes to the editorial team of the relevant memorandum of Homo Digitalis which is comprised of our members: Vamvaka Elpida, Volikou Adamantia, Volikou Eirini, Gakis Dionysis, Konstantinou Stergios and Chelioudakis Lefteris.

Our President and member of the editorial team for the memorandum, Elpida Vamvaka, will represent us at the video conference.

Homo Digitalis submitted today its positions and proposals to the European Commission on the European Data Strategy by participating in the relevant open consultation.

You can find our answers to the relevant questionnaire of the European Commission here, as well as the additional memorandum we submitted with our proposals here.

On April 2, more than 100 civil society organizations, including Homo Digitalis, signed a joint statement for privacy issues related to the COVID-19 pandemic.

The organizations include among others Access Now, Amnesty International, Human Rights Watch, Privacy International, European Digital Rights (EDRi) and Homo Digitalis.

The statement is available here.

On 29 March, Homo Digitalis signed the European Academy for Freedom of Information and Data Protection (ΕΑΙD) Declaration on personal data protection and freedom of information during the COVD-19 pandemic.

The letter calls all of us to stay vigilant so that the encounter of COVID-19 measures does not violate human rights. The civil rights and liberties are inherent to modern democracies and should be protected even under the serious pandemic we are facing.

Many prominent scientists and human rights advocates sign the declaration.

The declaration is available here.

On March 27, European Digital Rights (EDRi) and many more civil society organizations, including Homo Digitalis, sent a joint letter to the Council of the EU regarding the suggested EU Terrorist Content Regulation (TERREG).

In the letter, we note our grave concerns regarding the suggested text, as well as privacy, freedom of expression and freedom of information concerns.

You may read the letter in the EDRi website or here.

Today, 19.03.2020, Homo Digitalis filed a request to the President of the Greek DPA for the issue of an opinion  regarding the agreement for the provision of smart policing systems between the Greek Police and INTRACOM TELECOM

This agreement provides for the processing of citizens’ biometric data (fingerprints and photos) through portable devices, among others.

It is essential that the Greek DPA provides its opinion on the issue, taking into account the important privacy challenges for all data subjects in Greece.

The full text of our request in Greek is available here.

Today, 09.03.2020, Homo Digitalis sent a letter to the Minister of Civil Protection, the Minister of Justice and the Permanent Representation of Greece in the EU concerning important safeguards that should be taken into account in the TERREG text.

With this letter we underline various provisions in the suggested text, which might be extremely harmful for privacy, freedom of expression and freedom of information.

The said letter is aligned to the positions expressed by European Digital Rights (EDRi) as well as the pertinent Opinion of the EU Fundamental Rights Agency (FRA).