What triggered the investigation into AI use by the Greek Ministry of Interior?
The investigation was triggered by the Ministry of Interior's decision to use artificial intelligence to audit nearly 40,000 civil service performance reviews. According to statements from Deputy Minister of the Interior Viví Charalampogianni, the ministry employed AI tools to review 39,394 evaluations from the 2023 assessment year. These specific evaluations had been previously categorized as 'high performance' by human supervisors.
The primary concern arises from the outcome of this automated process. The use of AI reportedly led to the rejection of a significant number of these high-performance ratings. This automated reversal of human assessments has sparked a debate over whether an algorithm should have the final authority to override professional evaluations conducted by human managers. The discrepancy between human assessment and algorithmic output suggests a potential flaw in the tool's logic or a lack of oversight in its implementation.
The impact of automated rejection on civil servants
When an AI system rejects a performance rating that a human manager has already validated, it creates a legal and professional vacuum. For the employees involved, this means their hard-earned 'high performance' status is stripped away by a process that may be opaque. This raises fundamental questions about the right to contest automated decisions and whether the ministry provided sufficient reasoning for these rejections.
Why is Homo Digitalis challenging these AI practices?
Homo Digitalis, the first Greek non-profit dedicated to defending human rights in the digital age, is leading the challenge based on potential violations of the General Data Protection Regulation (GDPR). The organization has submitted two distinct interventions to the Hellenic Data Protection Authority (HDPA) to address different aspects of the Ministry's conduct.
The first intervention is a specific complaint filed on behalf of a public employee. This complaint focuses on Article 80 of the GDPR, which concerns the right to lodge a complaint with a supervisory authority. A central point of contention is how the Ministry responded to the employee's request to access their personal data. Under GDPR, individuals have a right to know how their data is being processed, especially when automated systems are making decisions that affect their professional standing.
The second intervention is broader in scope. Homo Digitalis is requesting that the HDPA launch an ex officio investigation into the entire process involving the 39,394 employees. The organization argues that the issue is systemic rather than isolated. They contend that a massive number of public servants may have been processed by AI systems without being adequately informed, which would constitute a direct breach of transparency obligations.
What are the specific legal concerns regarding GDPR compliance?
The legal challenges center on whether the Ministry of Interior adhered to the core principles of legality, transparency, and accountability. Specifically, the HDPA must determine if the processing of employee data for AI-driven audits had a valid legal basis and whether the employees were properly notified of the processing activities.
A critical technical and legal requirement under European law is the performance of a Data Protection Impact Assessment (DPIA). The organization is questioning whether the Ministry conducted such an assessment before deploying the AI tool. A DPIA is mandatory when processing involves new technologies that are likely to result in a high risk to the rights and freedoms of natural persons.
Key principles under scrutiny
- Transparency: Did the Ministry clearly communicate to employees that AI would be used to audit their performance?
- Legality: Is there a specific legal framework that permits the use of automated tools to override human performance ratings?
- Accountability: Can the Ministry demonstrate that the AI tool is accurate, unbiased, and subject to meaningful human oversight?
The outcome of these investigations will likely set a precedent for how public administration in Greece—and potentially the wider EU—manages the intersection of automated decision-making and labor rights.
How does this incident relate to previous transparency complaints?
This current scrutiny is not an isolated event but follows a pattern of legal challenges regarding algorithmic transparency in Greece. In July 2026, a previous complaint was filed with the National Transparency Authority by the Institute for Regulatory Policy Research, Homo Digitalis, and a public employee.
That earlier complaint focused on the adherence to transparency obligations regarding AI systems, specifically mentioning the requirement for algorithmic impact assessments as outlined in Law 4961/2022. The recurring nature of these complaints suggests a growing tension between the government's push for digital transformation and the existing legal safeguards designed to protect citizens from unchecked algorithmic power.
The continuous push for accountability highlights a significant gap in the implementation of digital rights. While the legislation exists to govern these technologies, the practical application within the civil service appears to be lagging behind the technical deployment of the tools themselves.
FAQ: AI in public sector evaluations
What is the main controversy regarding the Greek Ministry of Interior?
The controversy involves the Ministry's use of AI to audit 39,394 high-performance evaluations from 2023. The AI tool reportedly rejected many of these ratings, leading to allegations that the process lacked transparency, legal basis, and proper notification to the affected employees.
Who is Homo Digitalis?
Homo Digitalis is Greece's first non-profit organization dedicated to promoting and defending human rights in the digital era. Founded in 2018, it is the only full member of the European Digital Rights (EDRi) network based in Greece.
What specific GDPR articles are being invoked?
The complaints specifically reference Article 80 of the GDPR, which relates to the right to lodge a complaint. The organization is also investigating whether the Ministry fulfilled its obligations regarding transparency and the mandatory Data Protection Impact Assessments (DPIA).
Was the AI use a new development?
While the specific audit of 39,394 employees is the current focus, the issue of AI transparency in Greece has been a subject of legal debate since at least July 2026, involving previous complaints to the National Transparency Authority.
What could be the consequences of the HDPA investigation?
The investigation could lead to a formal finding of non-compliance, forcing the Ministry to change its automated auditing processes, implement stricter transparency measures, and potentially provide reparations or corrected evaluations to the affected public employees.
Key takeaways
- Homo Digitalis challenged the Greek Ministry of Interior over AI-driven audits of 39,394 employee evaluations.
- The AI tool reportedly rejected numerous high-performance ratings previously validated by human managers.
- Legal concerns focus on GDPR compliance, specifically transparency and the lack of proper employee notification.
- The investigation seeks to determine if mandatory Data Protection Impact Assessments were conducted.
The future of algorithmic accountability in government
The confrontation between the Ministry of Interior and digital rights advocates marks a pivotal moment for the Greek public sector. As governments worldwide increasingly integrate artificial intelligence to enhance efficiency, the balance between technological progress and the protection of individual rights becomes more precarious. This case demonstrates that efficiency cannot come at the expense of legal certainty. The decisions made by the Hellenic Data Protection Authority will serve as a critical benchmark, determining whether algorithmic tools in the public service remain subjects of the law or become instruments of unchecked administrative power.
