We submitted our views to the European Commission’s public consultation on Article 30(5) GDPR
Yesterday, Homo Digitalis submitted its views as part of the European Commission’s public consultation on Article 30(5) of the GDPR.
In our submission, we call on the Commission to withdraw the proposed amendment and stress the need to ensure that the GDPR is not reopened or modified through broader deregulatory initiatives. The priority must remain on the effective application and enforcement of the existing framework, rather than on reducing the safeguards that are essential for protecting fundamental rights in the digital age.
You can read our full position here.
Homo Digitalis spoke on smart farming and the AI Act
In the beginning of july, the AgriDataValue project hosted an in-depth online workshop dedicated to data privacy, legal, and ethical dimensions within the context of smart farming. Organized by Netcompany, the event brought together AgriDataValue partners, Advisory Board members, legal experts, as well as representatives from related EU-funded projects.
Homo Digitalis participated in the workshop, giving a legal presentation on the topic “Smart Agriculture from a GDPR and AI Act Perspective”. Many thanks to Ioannis Chrysakis for the kind invitation! Our Executive Director, Eleftherios Chelioudakis, represented us.
The objective of the workshop was to identify and validate key ethical, legal, social, and privacy-related topics linked to the AgriDataValue platform. It also served as an opportunity to review data flow mappings between the project’s technologies, user types, and integrated services, a vital exercise for ensuring compliance, transparency, and responsible data governance.
We filed a complaint against Alphabet before the European Commission under the provisions of the DMA, together with five organizations.
European Digital Rights, ARTICLE 19, Free Software Foundation Europe (FSFE), Gesellschaft für Freiheitsrechte e.V., Vrijschrift.org, and Homo Digitalis filed a formal complaint against Alphabet Inc. under the Digital Markets Act (DMA) before the European Commission.
Despite the DMA’s clear gatekeeper rules:
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On Android, users still cannot truly uninstall Google’s pre-installed apps; they can only disable them, which leaves them on the device. Yet Alphabet misleads users by claiming this is the same as removing an app. It is not.
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The disable option is buried deep in the settings and, when users do find it, Android displays vague and intimidating warnings that discourage them from switching to alternative apps, making it harder to move away from Google’s ecosystem.
We are facing a textbook case of deceptive design, which restricts user choice and reinforces Alphabet’s gatekeeper position.
With our complaint, we call on the European Commission to investigate Alphabet’s practices and order the company to fully respect end-user rights under the DMA.
You can read our complaint on EDRi’s website here.
Homo Digitalis contributes to two EU consultations on the Data Strategy and high-risk AI systems
Last Friday, July 18th, Homo Digitalis submitted detailed input to two public consultations launched by the European Commission.
The first consultation focused on collecting targeted input from stakeholders regarding the implementation of the AI Act (2024/1689) rules for high-risk AI systems. According to Article 6(5) of the AI Act, the Commission must publish guidelines on the practical implementation of the high-risk classification rules by February 2, 2026, accompanied by a list of practical examples of both high-risk and non-high-risk AI systems. Additionally, Article 96(1)(a) requires the Commission to provide guidelines on the application of obligations and responsibilities for high-risk AI systems, including those across the AI value chain, as defined in Article 25. In its submission, Homo Digitalis provided practical examples of AI systems from Greece and other countries, and highlighted key issues that should be clarified in both the classification and compliance guidelines.
The second consultation addressed the EU Data Strategy. Its three goals are to: 1) boost investment in data technologies and promote data sharing through voluntary or funded initiatives; 2) streamline existing rules and develop data tools to reduce administrative burdens; and 3) shape an international data strategy that ensures safeguards for data transfers outside the EU and encourages data inflows into the EU.
In its response, Homo Digitalis raised strong concerns about potential undermining of personal data protection under the pretext of simplification, flexibility, and competitiveness. The organisation reaffirmed its position that fundamental rights must be strengthened through the use of new technologies and rejected the framing of existing legal frameworks as a barrier to innovation. According to Homo Digitalis, the challenges lie primarily in the lack of enforcement and resources, not the laws themselves.
You can read our full submission for the first consultation here.
We thank the drafting team, Stavrina Chousou, Niki Georgakopoulou, Sofia Antonopoulou, and Eleftherios Chelioudakis, for their valuable contributions.
You can read our full submission for the second consultation here, edited by our Executive Director, Eleftherios Chelioudakis.
We sent an open letter to the EU calling for a reassessment of Israel’s adequacy decision under the GDPR
Together with European Digital Rights, Access Now, and 16 other civil society organizations, we submitted a second open letter to the European Commission, urging it to urgently reassess Israel’s adequacy status under the GDPR.
Since the Commission reconfirmed Israel’s status in January 2024, the situation has only deteriorated:
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Escalating human rights violations in Gaza and the West Bank
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Expansion of surveillance systems and biometric repression
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Legal reforms undermining oversight of personal data processing
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Ongoing data flows to Israeli companies with ties to security services
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Use of AI-driven targeting systems in a context where the International Court of Justice has found plausible genocide
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Application of Israeli law to occupied territories, in breach of the EU’s own policy
This is not just about technical compliance. It is about whether the EU’s data protection framework can credibly uphold fundamental rights, and whether data originating in the EU is being used to facilitate unlawful practices.
Read the letter here.
We submitted our views to the European Commission’s public consultation on Article 28 of the DSA
On June 13, Homo Digitalis submitted its responses to the European Commission’s Public Consultation regarding the guidelines for the protection of minors online, within the framework of Article 28 of the Digital Services Act.
The responses to the questionnaire were accompanied by a study, which provided a more detailed explanation of the relevant proposals and concerns.
The editorial team for this action consisted of Stavrina Chousou, Anastasios Arampatzis, Alkmιnι Gianni, Kalliroi Grammenou, and Lamprini Gyftokosta.
You can read the responses to the questionnaire here.
You can read the study here.
We have prepared an easy-to-read infographic on developments at the AI Act trilateral conferences
How are the tripartite conferences progressing in the context of the adoption of the proposed EU AI legislation?
Together with European Digital Rights and other key civil society organisations we have been working closely with over the last few years on this legislative dossier, we have prepared a graphic to highlight where we are with meeting our demands for the protection of Human Rights.
We have achieved significant improvements, but unfortunately there are still many provisions that do not meet our requests. You can read more on the relevant here.
Request for a meeting at the Ministry of Digital Governance for AI ACT
On Friday 29/9, Homo Digitalis requested a meeting before the Minister of Digital Governance, Mr. Dimitris Papastergiou, in the context of the trilateral negotiations taking place at EU level for the adoption of the proposed AI Act. In addition to our request for a meeting with the Minister, we attach a one-page statement, in which we briefly set out the specific issues we wish to discuss in more detail with him.
Our aim is to present to the Minister and to the Greek Government’s representation at EU Council level our views on the proposed provisions in more detail and to learn more about Greece’s positions in the trilateral consultations already taking place.
FRONTEX responds to Homo Digitalis' Request for Access to Information on EUROSUR and the deadly shipwreck in Pylos
In June 2023, Homo Digitalis had filed a request for access to documents before FRONTEX in order to explore whether the EUROSUR system, which is composed of drones and satellites, among other technologies, was in operation during the fatal ship’s voyage from 9 to 13 June in the Mediterranean Sea and the reasons why it did not prevent this fatal shipwreck.
Today, FRONTEX replies that the EUROSUR system, despite being fully operational, has not been able to do what it promises, namely to detect large vessels that may be used by criminal organisations to transport people in the Mediterranean, putting the lives of the latter at high risk. This is a major revelation by Homo Digitalis, demonstrating that the very expensive – tens of millions of euros – solutions promised by technology companies to complex issues such as border management and the protection of people who put their lives at risk have failed. EUROSUR failed to locate the large floating vessel, despite the fact that it had been right in its field of control for more than 3 full 24 hours.
You can see the text of the reply we received here.