We express our concern about the introduction of a mechanism providing for direct payments from content providers and technology companies to major European telecom companies.
In February 2023, the European Commission presented a series of actions to transform the EU’s connectivity sector, including an exploratory consultation on the future of the connectivity sector and related infrastructure.
Today, 48 organisations, including Homo Digitalis, published a joint statement expressing our collective concern about calls at EU level for a mechanism to provide for significant direct payments (“network contribution”, “network fee”, “fair share”) from content providers and technology companies to large European telecoms companies.
We call on EU policy makers and Member States to resist the imposition of direct payment obligations in favour of the largest telecom operators! Six MEPs support our stand!
You can read our joint statement in English and the MEPs’ joint support here.
You can read the relevant EU Press Release here.
Our participation in the study "DMA & DSA: A comprehensive inventory of the EU's effort to regulate digital platforms & the digital economy"
Yesterday, the ENA Institute for Alternative Policies published the study “DMA & DSA: An analytical inventory of the EU’s effort to regulate digital platforms & the digital economy”, in which Christos Zanganas, Lawyer representing Homo Digitalis and Antonis Bogris, Information & Communications Engineer and Professor at the University of West Attica, participated.
You can read the study here. Thank you very much for your cooperation!
Joint Letter to the European Parliament on the AI Act
The European Parliament is preparing to vote on the proposed legislation on artificial intelligence #AIAct.
In a joint letter today, European Digital Rights and 75 other organisations, including Homo Digitalis, are sending a clear message to protect Human Rights and call on MEPs to pay due attention to the problematic provisions of the proposed text!
In order to do so, MEPs will have to vote:
-to strengthen the framework for the protection of Human Rights,
-on specific accountability and transparency obligations regarding the use of artificial intelligence systems,
-for a ban on the use of AI systems that pose unacceptable risks to the protection of everyone’s rights!
You can read the joint letter here.
We participate in the Media Pluralism Monitor study of the European University Institute (EUI)
Elpida Vamvaka, president of Homo Digitalis, participated for the second year as an expert in the Media Pluralism Monitor 2022 survey!
The study highlights the risks to media pluralism and freedom in four areas: Fundamental Protection, Market Pluralism, Political Independence and Social Inclusion.
The Media Pluralism Monitor 2022 is implemented by the Centre for Media Pluralism and Media Freedom and is a scientific attempt to map the threats to pluralism and media freedom in the Member States of the European Union and in some candidate countries, taking into account legal, political and economic variables.
We send a letter to the Government asking for the immediate drafting and proposal of a draft law of popular legislative initiative
Three years after the 2019 revision of the Constitution, when the institution of the popular legislative initiative was introduced for the first time in Greece, i.e. the possibility for citizens to submit legislative proposals to the Parliament, it remains inactive.
Unfortunately, there is no apparent legislative intention from the Greek government as an implementing law is required. This is a disheartening contempt for the Constitution, citizens and democratic institutions.
Homo Digitalis, Vouliwatch and 44 other Civil Society Organisations (CSOs) have sent an open letter to the Government asking for the immediate drafting and proposal of this draft law. We also asked whether members of the CSOs would be included in the legislative process.
You can read the letter and more information here.
Homo Digitalis participates in important research on sexual abuse through images
Our member Anastasios Arampatzis participated in a Share Foundation survey on the legal framework in Greece regarding sexual abuse through images.
The Greek legal order, like many neighbouring countries, does not include a comprehensive and clear provision practically protecting survivors of image-based sexual abuse (#imagebasedsexualabuse).
The lack of a directly regulated framework defining and prosecuting the crime as a stand-alone crime as well as #advocacy methods are explored in the comparative study in South Eastern Europe recently published by the SHARE Foundation. The latest development in the Greek reality (Article 346 CC), despite its positive aspect, again includes the crime in a series of offences such as forgery, intensifying the need for an autonomous regulation.
You can read the relevant report and find out about the two countries that recognise sexual abuse through images as a separate criminal offence here.
Homo Digitalis participates in the development of a cybersecurity guide
The SHARE Foundation, in collaboration with Homo Digitalis, SCiDEV, Hivos and the Digital Defenders Partnership, has developed the Cybersecurity Toolkit – a single website where you will find answers to all the privacy and security issues you may face on the Internet.
Whether used as an incident response resource or as a learning platform, this useful and inclusive Cybersecurity Toolkit provides up-to-date and easy-to-understand information in just a few clicks!
Thanks to our member Tasos Arampatzis who represented Homo Digitalis in the related work for the development of the toolkit and its promotional campaign.
Visit the full Guide for free here.
Homo Digitalis participates in MIIR research on new technologies at the borders
Homo Digitalis participated in a research report by the Mediterranean Institute of Investigative Journalism (MIIR) on the use of new technologies in the field of border management.
Our organisation provided interviews to MIIR researchers in order to explain the important challenges that arise in terms of the protection of Human Rights, and to highlight the ways in which new technologies are used in the field of border management.
The research has been published in three parts, namely 1: The ecosystem of European biometric surveillance and monitoring data, 2: Trapped in digital surveillance systems, and 3: Automation and Surveillance in Fortress Europe.
You can read the survey here.
Homo Digitalis thanks MIIR for the recognition shown to our organisation’s expertise and knowledge in the field of rights protection in the area of border management.
The Hellenic DPA is requested to take action again the deployment of ICT systems IPERION & KENTAUROS in facilities hosting asylum seekers in Greece
Homo Digitalis together with The Hellenic League for Human Rights, HIAS Greece and Dr. Niovi Vavoula, Lecturer at Queen Mary University of London submitted before the President of the Hellenic Data Protection Authority (HDPA) on 18.2.2022, a request for the exercise of its investigative powers regarding the deployment of the ICT systems IPERION and KENTAUROS in facilities hosting asylum seekers in Greece (protocol number 2515/18.02.2022).
In particular, as described in the relevant website of the Ministry of Digital Governance for the area of migration and asylum, as well as in the annual action plan of the Ministry of Immigration and Asylum:
-The ΙPERION system will be the asylum seekers’ management system with regard to all the needs of the Reception and Identification Services. It will include a detailed record of the data of asylum seekers and it will be interconnected with the ALKYONI II system with regard to the asylum application. In addition, it will be the main tool for the operation of all related facilities as it will be responsible for access control (entry – exit through security turnstiles, with the presentation of an individual card of a migrant, NGO member, worker and simultaneous use of fingerprints), the monitoring of benefits per asylum seeker using an individual card (food, clothing supplies, etc.) and movements between the different facilities. At the same time, the project includes the creation of a mobile phone application that will provide personalized information to the user, will be his/her electronic mailbox regarding his/her asylum application process and will enable the Service to provide personalized information. It is important to note that the IPERION system is presented by the Ministry of Digital Governance as a system that will be completed in the medium term and its construction – installation is already underway. Furthermore, explicit reference is made to this system in Article 7(2) of the General Regulation on the Operation of Closed Controlled Island Facilities. Therefore, it is understood that the IPERION system will process biometric and biographical data of asylum seekers, as well as of NGO members visiting the relevant structures and of people working in them.
-The KENTAUROS system will be a digital system for managing electronic and physical security around and inside the facilities, using cameras and Artificial Intelligence Behavioral Analytics algorithms. It includes centralised management from the headquarters of the Ministry of Digital Governance and the following services: Signaling perimeter breach alarms using cameras and motion analysis algorithms; signaling of illegal behavior alarms of individuals or groups of individuals in assembly areas inside the facility; and use of unmanned aircraft systems to assess incidents inside the facility without human intervention, among other functions. It is noted that the KENTAUROS system is presented by the Ministry of Digital Governance as a system that will be completed in the medium term and its construction – installation is planned. Therefore, it is understood that the KENTAUROS system is incorporating highly intrusive technologies, such as behaviour analysis algorithms, drones and closed circuit surveillance cameras, which create important for challenges for the protection of privacy, personal data and other rights
It is worth noting that Homo Digitalis submitted on 13 October 2021 a request for information re IPERION and KENTAUROS systems before the Secretary General for Asylum Seekers of the Ministry of Immigration and Asylum, Mr Logothetis. Nevertheless, Homo Digitalis did not receive a response from the competent bodies, even though the relevant deadline for reply has already expired.
Based on all of the above, it is understood that there is a serious risk that the installation of these systems could violate the European Union legislation on the processing of personal data and the provisions of Law 4624/2019, while there is also a significant risk that the installation of these systems without the preparation of the necessary Data Protection Impact Assessment may cause a serious violation of the rights and freedoms of data subjects who are hosted in this facilities, visit the facilities, or are employed in them. Finally, the possible creation of databases (including biometric data and other special categories of data) to assist the operation of these systems is not foreseen by any national legal rule providing the necessary safeguards for the rights of data subjects, thus raising significant challenges.