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?
Homo Digitalis interview to France 24 on the MEP Asimakopoulou emails case
Our co-founder, Eleftherios Chelioudakis, represented Homo Digitalis in an interview with France 24 (the French News Agency) about the illegal transfer of personal data of a large number of Greeks living abroad in the hands of the MEP Anna Michelle Asimakopoulou and the relevant political communication she made to them via email in the context of the upcoming European elections.
We are very grateful to France 24 for its interest in our actions. You can read the interview here.
The Hellenic Data Protection Authority fines the Ministry of Migration and Asylum for the "Centaurus" and "Hyperion" systems with the largest penalty ever imposed to a Greek public body
Two years ago, in February 2022, Homo Digitalis had filed a complaint against the Ministry of Immigration and Asylum for the “Centaurus” and “Hyperion” systems deployed in the reception and accommodation facilities for asylum seekers, in cooperation with the civil society organizations Hellenic League for Human Rights and HIAS Greece, as well as the academic Niovi Vavoula.
Today, the Hellenic Data Protection Authority identified significant GDPR violations in this case by the Ministry of Immigration and Asylum and decided to impose a fine of €175.000 euro – the highest ever imposed against a public body in the country.
The detailed analysis of the GDPR highlights the significant shortcomings that the Ministry of Immigration and Asylum had fallen into in the context of preparing a comprehensive and coherent Data Protection Impact Assessment, and demonstrates the significant violations of the GDPR that have been identified and relate to a large number of subjects who have a real hardship in being able to exercise their rights.
Despite the fact that the DPA remains understaffed, with a reduced budget, facing even the the risk of eviction from its premises, it manages to fulfil its mission and maintain citizens’ trust in the Independent Authorities. It remains to be seen how long the DPA will last if the state does not stand by its side.
Of course, nothing ends here. A high fine does not in itself mean anything. The Ministry of Immigration and Asylum must comply within 3 months with its obligations. However, the decision gives us the strength to continue our actions in the field of border protection in order to protect the rights of vulnerable social groups who are targeted by highly intrusive technologies.
You can read our press release here.
You can read Decision 13/2024 on the Authority’s website here.
Homo Digitalis interview with Inside Story about the MEP Asimakopoulou emails' case
The member of Homo Digitalis, Christos Zanganas, represented Homo Digitalis in an interview with Inside.story and journalist Eleftheria Tsaliki on the illegal transfer of personal data of a large number of Greeks living abroad in the hands of the MEP Anna Michelle Asimakopoulou and the relevant political communication she made to them via email in the context of the upcoming European elections.
We are very grateful to the journalist for her interest in our actions. You can read the interview here.
Homo Digitalis interview with The Press Project about the MEP Asimakopoulou emails' case
The member of Homo Digitalis, Nikoleta Georgakopoulou, spoke to The Press Project and journalists Thanos Kamilalis and Konstantinos Poulis about the scandal with the illegal transfer of personal data of a large number of Greeks living abroad in the hands of the New Democracy MEP Anna Michelle Asimakopoulou and the relevant political communication she made to them via email in the context of the upcoming European elections.
We are very grateful to the journalists of The Press Project for their interest in our actions.
You can listen to the excerpt of the interview at 16:15 of the related video on The Press Project’s YouTube channel here.