We submitted important questions to the Minister of Interior, Ms Kerameos, on the project "Development and operation of a tool for the strategic planning of public sector staffing in terms of artificial intelligence" and its pilot application in 9 institutions
On April 15, Homo Digitalis submitted an electronic letter to the Minister of Interior, Ms Kerameos, regarding the Ministry’s project entitled “Development and operation of a tool for strategic planning of public sector staffing in terms of artificial intelligence”.
Our letter was communicated to the President of the Personal Data Protection Authority, Mr. Menoudakos, and to the Data Protection Officer of the Ministry of Interior, Mr. Theocharis.
More specifically, this project relates to the development and operation of a tool for the strategic planning of human resources in the public sector in terms of artificial intelligence and concerns the following axes:
– Creation of an integrated framework for strategic staffing planning (optimal allocation of existing and new staff) in the public sector (including technical specifications for the implementation and revision of existing frameworks)
– Pilot implementation in 9 Public Sector Entities and more specifically in MOD SA, AADE, OAED, Athens General Hospital “G. Municipality of Thessaloniki, Region of Attica, Ministry of Education and Religious Affairs, Ministry of Environment and Energy and Ministry of Culture and Sports,
– Design of training programmes for (a) users and (b) upgrading the skills of civil servants, and
– Development of the knowledge repository of civil servants.
According to relevant information posted on the website of the Ministry of Interior and articles in various media, the Ministry of Interior is the project manager and has already contracted with Deloitte for its preparation. In fact, according to the timetable, the work has made significant progress.
In its letter, Homo Digitalis requests information from the Minister on a number of questions regarding both the legal framework for the protection of personal data (Law 4624/2019 – GDPR), and the legal framework for the use of artificial intelligence systems by the public sector (Law 4961/2022), as the pilot implementation of the project is expected to take place immediately in the 9 institutions mentioned above.
Specifically, we put the following questions to the Minister in our letter:
-Has the Ministry of Interior carried out a data protection impact assessment before the project was announced, in accordance with the principles of data protection “already by design” and “by default”?
-Has a relevant Data Protection Impact Assessment been carried out specifically in relation to the pilot implementation of the platform in the 9 public bodies?
-If the relevant Assessments have been prepared, has the Ministry considered it necessary to consult the Data Protection Authority in this respect?
-Does the Ministry consider the 9 public bodies as joint controllers and if so, has the Ministry proceeded with the relevant obligations as set out in Article 26 GDPR?
-Can the Ministry inform us of the relevant categories of personal data, the purposes of the processing for which such data are intended, and the legal basis for the processing you intend to use?
-Can the Ministry point us to the exact website where the Ministry of Interior’s contract with Deloitte is posted so that we can study the relevant provisions contained therein, especially with regard to the processing of personal data?
-Finally, has the Ministry of Interior proceeded to comply with the obligations arising from the provisions of Law 4961/2022, and in particular has an algorithmic impact assessment been carried out (Article 5), has it taken the necessary transparency measures (Article 6), has the project contractor fulfilled their obligations in this respect (Article 7), and has the Ministry kept a register (Article 8) in view of the forthcoming pilot use of the system?
Protect Not Surveil Campaign's Joint Statement: AI Act provisions are dangerous for vulnerable groups in the migration field
On 13 March 2024, the European Parliament adopted the EU Act on Artificial Intelligence (AI ACT).
Although the legislation is widely presented as a global first, the EU AI Act falls short in the important area of migration, as it does not prevent the high risks that exist and does not provide the necessary level of protection to vulnerable groups in society who are targeted by intrusive technologies in this area.
In its final version, the EU AI act sets a dangerous precedent. The legislation develops a separate legal framework for the use of AI by law enforcement, immigration control and national security authorities, providing unjustified ‘loopholes’ in the obligations set out in its text, and even encouraging the use of dangerous systems for surveillance of the most marginalised members of society.
Homo Digitalis, having in the last 4 years made significant legal complaints in this regard before the DPAA, as well as a series of educational, awareness-raising and co-determination actions at EU level in this regard, is following with particular concern the relevant developments.
As part of our active participation in the Protect Not Surveil campaign, together with all its members, we have published a joint statement outlining the main gaps in the protection of vulnerable groups in the field of migration identified in the text of the AI Act.
You can read the text of our joint statement here.
Our joint action on the Digital Euro & Right to Cash legislative initiatives
At the end of February, together with epicenter.works, European Digital Rights and other important civil society organisations, we sent a letter to the MEPs who are the rapporteurs and shadow rapporteurs of the DigitalEuro and Right To Cash packages.
Despite the fact that both proposed pieces of legislation are part of the same legislative package, we see that the relevant negotiations are moving at two different speeds!
With the European elections approaching and uncertainty prevailing regarding the proposed legislation on the Digital Euro and the challenges that arise with its technical features, we call on MEPs to separate these two legislative proposals in order to spend the necessary time to solve the problems that have been identified and highlighted by academics, and other experts in the field.
You can view our joint letter here.
Our joint research on children's safety and privacy online just published
YouGov, Humankind Research and Homo Digitalis conducted a survey on online safety and privacy for children in Greece, which shows high levels of concern among adults and young people.
-What percentage of Greeks are concerned about children’s online privacy?
-Do they believe that children have little control over how their data is collected and used?
-Who do Greeks believe is primarily responsible for protecting children online?
The survey also highlights the critical need to invest in raising awareness among Greek citizens, both adults and non-adults, on issues of privacy, protection and safety online.
You can find the survey and learn more about its results:
We submitted a joint letter with noyb.eu to the European Data Protection Board for its opinion in the Meta case
The European Data Protection Board (EDPB) will soon issue its most important opinion to date: it will determine whether we still have a realistic option to protect our right to privacy online!
In November 2023, Meta adopted the “Pay or Okay” approach. Since then, users are forced to either pay a “privacy fee” of €251.88 per year or agree to be monitored. The supervisory authorities of the Netherlands, Norway and Hamburg have therefore requested a binding opinion from the EDPB on this issue.
If “Pay or Okay” is legalised, companies in all industry sectors could follow Meta’s lead – which could mean the end of real consent in the use of our data.
Homo Digitalis has now joined forces with 27 other civil society organisations including noyb.eu, Wikimedia Europe, Bits of Freedom and Forbrukerrådet/Norwegian Consumer Council to urge the EDPB to issue an opinion that protects our fundamental right to data protection!
You can read our joint letter here.
We declare our full support for Freedom of the Press in Greece against SLAPP
On 25 January, C. Demetriades’ case against Reporters United & The Newspaper and journalists Nikolas Leontopoulos, Thodoris Chondrogiannos and Thanassis Koukakis for their revelations regarding the use of the PREDATOR spy software.
-We declare our full support for Freedom of the Press.
– We stand by journalists and their investigative work.
– We stand with the international, European and domestic journalists’ and human rights organisations calling for the immediate withdrawal of this abusive SLAPP lawsuit!
We published a joint study with EDRi on age verification online
Age verification is the process of predicting or confirming a person’s age online. Increasingly we hear from governments and technology companies that age verification is a tool we should use to ensure the safety of children online.
For example, in the EU, the draft regulation establishing rules to prevent and combat child sexual abuse (CSAR) proposes to enforce age verification forms for private messaging services (e.g. WhatsApp, Signal) and app stores operating in the EU, as well as to provide strong incentives to use this tool on all other digital platforms and services, such as social media.
The European Digital Rights network, including Homo Digitalis, has prepared a relevant study with a rich analysis of more than 30 pages, freely available here.
It is important to ensure that our children have access to age-appropriate online content. However, quick technological ‘fixes’ such as age verification online will not make a difference or really solve the complex problems we face. On the contrary, the adoption of age verification systems can have serious human rights implications, especially for the children they are intended to protect.
We call on European legislators to ensure full consistency with the principles of the rule of law in the AI ACT
We continue the actions of co-shaping political decisions at European level for the proposed European regulation on Artificial Intelligence (AIAct)!
Together with the Civil Liberties Union for Europe, European Center for Not-for-Profit Law Stichting, European Civic Forum and 60 other CSOs, we call on EU-level legislators to ensure that the proposed provisions are fully consistent with the principles of the rule of law, including transparency, accountability and access to justice. You can read our joint letter here.
Action is also coming at national level!
We demand an end to the use of mass biometric surveillance technologies by law enforcement authorities in public places
Today, 120 civil society organisations and 60 academics, scientists and other experts on new technologies are joining forces to stop the use of mass biometric surveillance technologies by law enforcement authorities in public places.
It is a great honour for Homo Digitalis to be part of this initiative. Already since 2020 with European Digital Rights we have been involved in the #ReclaimYourFace campaign, in which more than 250,000 people across the EU signed our petition to ban these practices.
You can read the joint statement here.