Digital rights group Homo Digitalis has asked privacy regulators to investigate the Greek Interior Ministry over its use of artificial intelligence in worker evaluations.
The organisation submitted two legal interventions to the Hellenic Data Protection Authority on Wednesday, November 4. The filings demand an inquiry into automated systems used to review the performance files of roughly 40,000 public sector employees.
Citing statements by Deputy Interior Minister Vivi Charalambogianni, Homo Digitalis said the ministry deployed an artificial intelligence tool to examine 39,394 evaluations from the 2023 evaluation cycle. Every one of those files had originally received a high performance rating.
The algorithmic screening reportedly led to the rejection of a large number of employee ratings. The group said the move raised serious concerns over the legal basis of the processing, institutional transparency, employee notification, and safeguards protecting personal information.
Interventions filed with privacy regulator
The first intervention submitted to the Hellenic Data Protection Authority is a formal complaint lodged on behalf of a female civil servant. The action relies on Article 80 of the General Data Protection Regulation, which permits designated nonprofit organisations to represent individuals in data disputes.
That filing centres in part on how the Interior Ministry handled a subject access request submitted by the employee, who sought copies of her personal records and information on how the automated system processed her evaluation.
Alongside the individual case, the complaint asks the regulator to evaluate whether the ministry fulfilled its wider legal obligations under the European Union privacy framework.
In its second intervention, Homo Digitalis urged the authority to open an ex officio, own initiative investigation into the wider practice affecting all 39,394 evaluated civil servants.
The group stated that a systemic review is essential because the deployment touched tens of thousands of state employees. It warned that staff members may never have been properly informed that automated algorithms were being used to process their performance data.
Homo Digitalis asked regulators to establish whether the ministry respected core principles of lawfulness, transparency, and accountability. The group also called on the authority to examine whether officials conducted a formal Data Protection Impact Assessment before using the software.
Digital rights and European standards
Homo Digitalis is the first Greek nonprofit civil partnership formed specifically to defend and promote human rights in the digital age. Founded in 2018, the Athens based group is the sole full Greek member of European Digital Rights, an international network of nongovernmental organisations advocating for civil liberties and digital privacy across Europe.
Under the General Data Protection Regulation, public authorities across the European Union must maintain clear lawful grounds for handling employee information. When automated systems or new technologies present potential risks to workers, data controllers must complete a comprehensive Data Protection Impact Assessment to evaluate risks to personal privacy before the software enters operation.
The Hellenic Data Protection Authority serves as Greece's independent constitutional watchdog tasked with enforcing data protection legislation. The regulator holds statutory powers to investigate government agencies, conduct audits, order changes to data processing operations, and impose sanctions where public institutions breach privacy standards.
Prior complaint to transparency watchdog
The legal action before the data authority follows an earlier complaint submitted in July 2026 to Greece's National Transparency Authority. That earlier petition was filed jointly by the Institute for Regulatory Policy Research, Homo Digitalis, and the civil servant.
The July filing urged officials to determine whether the Interior Ministry followed transparency standards that were in place at the time. Those obligations included conducting an algorithmic impact assessment under Greek Law 4961/2022, a statutory framework that governs emerging technologies and automated decision making systems in the public sector.
The National Transparency Authority operates as an independent body responsible for monitoring accountability, combating corruption, and ensuring public sector institutions comply with administrative integrity standards across Greece.
The deployment of artificial intelligence in public administration has intensified scrutiny over legal guarantees for workers. The Hellenic Data Protection Authority must now rule on whether the Interior Ministry implemented sufficient transparency, gave workers adequate notice, and maintained proper data protection safeguards throughout the evaluation process.
