Homo Digitalis has asked Greece’s data protection authority to examine the use of an AI tool to review 39,394 civil servants’ 2023 performance evaluations.
Many evaluations previously classified as high-performing were reportedly rejected.
The interventions seek a systemic examination of transparency and legality, alongside a complaint under Article 80 of the GDPR.
On 4 November 2026, the organization filed two interventions with the Authority for the Protection of Personal Data. The first concerns a complaint on behalf of a public servant, which focuses on the way in which her request for access to her personal data was handled by the ministry. The second intervention requests the Authority to proceed with an ex officio review at a systemic level, in order to determine whether the principles of transparency, accountability and the required impact assessment on the protection of personal data were observed.
Homo Digitalis, as a member of the European Digital Rights Organisation (EDRi), questions the legality of automated data processing on this scale. The issue of the use of artificial intelligence in public administration has also concerned the authorities in the past. In July 2026, Homo Digitalis, in collaboration with the Regulatory Policy Research Institute and a public servant, had filed a complaint with the National Transparency Authority, highlighting the need to comply with transparency obligations and Law 4961/2022 on algorithmic impact assessment. The National Transparency Authority is now called upon to clarify whether the ministry's practice offered the necessary protection guarantees for the thousands of employees affected.
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