Eπιστολή στην ομάδα εργασίας Άρθρου 29 για τα προσωπικά δεδομένα

Η Ένωση Άθεων έστειλε στην Ομάδα Εργασίας του Άρθρου 29 της Οδηγίας 95/46/ΕΚ για τα προσωπικά δεδομένα το ακόλουθο ηλεκτρονικό μήνυμα, που αφορά τα προβλήματα στην προστασία των ευαίσθητων προσωπικών δεδομένων και ιδιαίτερα του θρησκεύματος στην Ελλάδα.

To the Secretariat of the Article 29 Working Party

Dear Madams/Sirs,

Following our message of March 22, and in view of the fact that the time limit for the answer of the HDPA has expired, we hereby communicate to you the correspondence between us and the HDPA concerning the failure of various Greek Ministries to comply with the legislation for private data record keeping.

Specifically, many public services keep records of private data, including sensitive private data such as religion, without having notified the HDPA of this, and without informing the citizens whose data are collected of the collection and processing purpose, of the data controller identity or of their rights to access and objection, even though there is no ground for restriction of these rights according to Article 13 of Directive 95/46, namely these records in general and the sensitive data in particular are not a matter of national or public security, national defense etc.

Such records to our knowledge are the following (not excluding the possibility of the existence of other records):
Ministry of Interior: Citizen’s Registry (Ληξιαρχείο), Municipal Roll (Δημοτολόγιο), Male’s Registry (Μητρώο Αρρένων),
Ministry of Education: Pupil’s Registry and Progress Book (Βιβλίο Μητρώου και Προόδου μαθητών),
Ministry of Defense: Enlistment Enumeration Sheet (Δελτίο Απογραφής Στρατευσίμων).

On 24-12-2010 we asked the Ministries for information concerning their personal data (data controller identity, purpose of collection etc.) but received no response.
On 28-12-2010 we requested the HDPA to inform us of the records notified to it by these Ministries and also received no response.
On 8-2-2011 we denounced the omission of the Ministries to the HDPA but have received no response up to now.

Sensitive private data such as religion are also recorded on various state documents, in violation of citizen’s rights.
An example of this is the recording of religion on Secondary Education Graduation certificates.
On 16-7-2010 we reported this practice to the Ombudsman and denounced it to the HDPA.
The Ombudsman has taken no action to our knowledge, and the HDPA responded solely with a reference to its past relevant Decision 77A/2002, which was already known to us and has never been implemented in practice, nor has the HDPA taken any action to ensure its implementation.

Hoping this information will be useful,


For the Atheist Union Secretariat


1. Our letters to the Ombudsman and to the HDPA about religion on school graduation certificates


2. The response of the HDPA to the above letter


3. Our participation in the consultation on the revision of Directive 95-46-EC



4. Our letter to the three Ministries and to the HDPA on sensitive data recording


5. Our second letter to the HDPA on sensitive data recording