Homo Digitalis participates in the European Commission's Open Consultation on General-Purpose AI
Yesterday, 18/9 Homo Digitalis submitted its responses to the European Commission’s Open Consultation under the title “FUTURE-PROOF AI ACT: TRUSTWORTHY GENERAL-PURPOSE AI”. The consultation covered issues concerning the future implementation of the AI ACT legislation and how to make the use of General-Purpose AI models trustworthy.
Homo Digitalis’ position paper on the Consultation was prepared by our organisation’s AI & Human Rights Director, Lamprini Gyftokosta and our member Tania Skrapaliori
You can read our statement here.
Letter from Homo Digitalis before NCRTV on the obligations arising from Regulation 2024/1083
On September 3, Homo Digitalis submitted an open letter (no. 4844-3-9-24) to the The National Council for Radio and Television (NCRTV), in which it raised two (2) questions regarding the application of the provisions of Article 25 of Regulation 2024/1083 on the establishment of a common framework for media services in the internal market.
In particular, as stipulated in Article 25, par. 2-3, the competent independent authorities in the Member States shall monitor and submit an annual report on the allocation of public advertising expenditure to media service providers and online platform providers. Those annual reports shall be made publicly available in an easily accessible format and shall be based on the information made public on an annual basis by electronic and user-friendly means by public authorities or entities that have incurred public advertising expenditure.
This information shall include at least:
(a) the official names of the media service providers or online platform providers from which services have been purchased,
(b) where applicable, the official names of the business groups to which any media service providers or online platform providers belong; and
(c) the total annual amount spent and the annual amounts spent per media service provider or online platform provider.
In view of the above, Homo Digitalis submitted the following two (2) questions before the NCRTV:
1 ) Has the NCRTV proceeded with the publication of the relevant annual report for the year 2023 regarding the allocation of state advertising expenditure to media service providers and online platform providers? If the NCRTV does not have the relevant competence, before which body should we appeal?
2) Does the NCRTV know whether public authorities or entities which have incurred expenditure on state advertising have complied with their obligation to publish annually by electronic and user-friendly means the information detailed in Article 25(2) of Regulation 2024/1083? In what ways could we as civil society monitor the respective activities of public authorities/entities in order to assist you in your work and inform you of any shortcomings in their compliance?
We hope to receive an answer to our questions soon.
Civil Society Common Statement: United Against Spyware Abuse in the EU and Beyond
Spyware isn’t just a privacy issue — it’s a threat to the very foundations of our democratic values. By undermining independent decision-making, restricting public debate, and silencing journalists and activists, spyware erodes the pillars of a healthy civic space.
As new European Union institutions prepare to take office following the EU elections, the growing threat of spyware has become a pressing global concern that demands immediate attention.
On Tuesday 3/9, Homo Digitalis joined Center for Democracy and Technology Europe (CDT Europe), alongside 30 civil society and journalists' organisations in publishing a joint statement urging the incoming EU institutions to prioritise action against the misuse of spyware in the new legislative term.
Some of our coalition’s key recommendations include:
- A ban on the production, sale, and use of spyware that disproportionately harms fundamental rights.
- Stronger export controls to prevent the misuse of these technologies beyond the EU.
- Transparency and accountability in government contracts involving spyware.
As Silvia Lorenzo Perez, Director of CDT Europe’s Security, Surveillance & Human Rights Programme, puts it: "The incoming EU institutions have the opportunity to correct the failures of the last legislature by taking concrete and decisive action against the abuse of spyware surveillance."
The new EU institutions must seize this moment to restore public trust, protect our fundamental rights, and uphold the values that define the Union.
You can read the EN version of the letter here, and the EL version of the letter here.
Homo Digitalis has also addressed related concerns, before the Council of Europe’s Commissioner for Human Rights in a recent Open Letter submitted in August. You can read more about this here.
We submitted an Open Letter to the Special Secretary of Foresight Strategy about the National AI Strategy and the enforcement of the AI Act
Today, 1/8/2024, on the occasion of the entry into force of the AI Act, Homo Digitalis sent a letter to the Special Secretary of Foresight Strategy of the Hellenic Government, Mr. Giannis Mastrogiorgiou, regarding the National Strategy for AI and the incorporation of the AI Act into national law! In addition, we communicated our concerns to the Prime Minister’s Office and the Ministry of Digital Governance.
Among other things, we raise critical questions about the national governance and oversight model, the creation of regulatory sandboxes (No. 57) and how the Greek public will be informed when subjected to the use of AI systems that create profiles or make decisions about them in the provision of public services.
At Homo Digitalis, we believe that the next steps of the Greek government will be crucial for the effective or not defence of digital rights in Greece, at a time when AI is a reality in our daily lives. The proper incorporation of such a technical and legally complex legislation into national law and the solutions adopted to address the ethical and social issues that arise are crucial for all of us.
You can see the full text of our letter here.
We requested from the Hellenic DPA and the Hellenic Authority for Communication Security and Privacy to issue an Opinion on the Draft Presidential Decree for the procurement of spyware by Greek authorities
Today, 30.7.2024, Homo Digitalis filed a request before the President of the Hellenic Data Protection Authority (HDPA), Mr.Menoudakos (no.6277/30-07-2024), and the President of the Hellenic Authority for Communication Security and Privacy (ADAE), Mr. Rammou (no. 2755/30-07-2024), in order for the two Independent Authorities to exercise their advisory powers and issue a joint Opinion regarding the Draft Presidential Decree of Articles 13 & 47 of Law 5002 /2022 on the procurement of contracts on behalf of governmental structures for the supply of spyware or surveillance devices.
The lack of transparency and openness regarding the whole process of drafting the text of the draft Presidential Decree, as well as the absence of an informed dialogue with the independent authorities of the country and with the advisory bodies of the state , combined with its late preparation, which contradicts the explicit provision of the legislator in Articles 13 and 47 of Law 5002 /2022, create additional concerns in the public sphere, as well as in certain professional circles, such as politicians, journalists, and lawyers, whose preservation of the confidentiality of communications is vital for democracy.
Homo Digitalis considers that, in the absence of immediate intervention by the two supervisory authorities, there is a serious risk that the provisions of the Draft Presidential Decree may not meet the requirements set out in Union law and the case law of the CJEU, may contravene the values enshrined in Article 2 TEU and the Fundamental Rights enshrined in the Charter and, in particular Articles 7, 8, 11, 11, 17, 21 and 47 thereof, fail to comply with the requirements laid down in Council of Europe law, in particular the values enshrined in the ECHR and Convention 108 and the case-law of the ECtHR, and infringe Articles 9A, 14 and 19 of the Greek Constitution.
Furthermore, Homo Digitalis considers that there is a serious possibility that the provisions of the said Draft Presidential Decree will create a lower level of protection in Greece than in other EU Member States, thus hindering the exchange of data and information between Greece and other Member States and leading to the impossibility of fighting serious crime and terrorism at a cross-border level whenever the use of spyware by the Greek authorities has taken place.
You can read our request in detail here.
We call on the Greek DPA to investigate the Ministry of Interior for the use of artificial intelligence algorithms for the reallocation of employees in the public sector
On 9 July Homo Digitalis filed a request (no. 5812/9.7.2024) before the Greek Data Protection Authority, in order for the latter to exercise its investigative powers against the Ministry of Interior.
In particular, following the Authority’s Decision 16/2024 in April 2024, by which it had imposed a record fine of 400,000 euros on the Ministry of Interior for significant breaches of data protection legislation, the Ministry is again in the spotlight, this time for the artificial intelligence tool it is developing for strategic staffing planning in the public sector.
The tool concerns the reallocation of existing staff and the estimation of the needs for new staff, while it will be piloted in 9 public sector institutions, namely the Development Programmes Organisation and Management Unit, the Independent Public Expenditure Authority, the Public Employment Service, the Athens General Hospital “G. Gennimatas Hospital, the Municipality of Thessaloniki, the Region of Attica, the Ministry of Education and Religious Affairs, the Ministry of Environment and Energy and the Ministry of Culture and Sports.
The project is expected to be completed in December 2025, at a cost of €11,708,543.
Because the tool needs to include functionalities for the collection, management and analysis of personal data, Homo Digitalis had filed a letter on 15 April 2024 before the then Minister of Interior Ms.Kerameos and the Data Protection Officer of the Ministry, in which it raised key questions regarding both the compliance required with the legislation on the protection of personal data and the legislation on the use of artificial intelligence and other emerging technologies in the public sector (Law 4961/2022). However, the Ministry did not provide any response, even after a written reminder of our request on 30 May, forcing us to address the DPA to investigate thoroughly the development, implementation and piloting of this tool and the implications for the rights of public sector employees.
You can see our request here (EL).
We submitted our report to the UN Special Rapporteur on the right to education regarding the use of AI in education
The United Nations Special Rapporteur on the right to education, Ms Farida Shaheed is preparing her upcoming report for the UN General Assembly in October 2024 on the promotion of the right to education based on artificial intelligence tools.
Homo Digitalis, after completing a tour of schools and conversations with teachers, students and parents, believes that the contribution of civil society with a practical look at this issue is important!
For this reason we have submitted our report before her on Monday 27 May. We would like to thank Anastasios and Viliy Karagiorgou and Lamprini Gyftokosta for their important contribution to the drafting and filing of this report!
Joint Statement of 18 organisations about EU’s White Paper on “How to master Europe's digital infrastructure needs”
Homo Digitalis joined epicenter.works and other 16 organisations, supporting an open internet and a competitive telecommunications market in the European Union!
With our statement, we express our concerns and observations on the current discussions on the future of the EU telecoms sector regulatory framework. Following the publication of the European Commission’s White Paper on “How to master Europe’s digital infrastructure needs” (the “White Paper”), and ahead of the upcoming Telecommunications Council of 21 May 2024, we call on EU Member States to take a pro-competitive, consumer centric approach and oppose any proposals for premature and unjustified changes to the EU telecommunications regulatory framework.
We are especially concerned that the European Commission’s White Paper, in its proposed scenario 5, second bullet point 2, suggests “recommending no markets for presumptive ex ante regulation”. This would amount to a removal of obligations for former monopolist Telecoms incumbents, measures which would result in reduced competition, hinder rollout of high-capacity infrastructure and limit the availability of affordable options for European consumers and businesses.
We therefore regret such considerations of the European Commission in the White Paper and in various public statements since its publication, including that “rules on interconnection should apply to everyone”, or that “an arbitration mechanism could be foreseen”.
We call on EU ministers to take a pro-competition, positive innovation, and consumer centric approach, strongly opposing any policy scenario that may result in legal uncertainty and detrimental consequences for European consumers, businesses and the open internet.
You can read our joint statement here.