The European Commission presented its Digital Green Certificate on 17 March 2021 in a bid to open up travel across the EU. It provides a common framework among EU countries for the issuance and verification of vaccine certificates, test certificates and recovery certificates. But digital and human rights groups are alarmed that the proposal does not prevent surveillance of certificate holders by the issuing authority and may exacerbate inequalities and social exclusion.
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In addition, the signatories fear that uncertainty around the certificate’s architecture could lead to the creation of extensive data records about the movement of people, their religious affiliation and what they do in their spare time, as some EU member states have said they could use the certificate for regulating entry to places of business and worship or sports venues.
The regulations must clarify that only an offline verification via a public key infrastructure adheres to the principles of privacy by design. That way, when a certificate is verified, the issuer should not obtain knowledge about the verification process or its circumstances. The regulation should also clarify that any further use of the certificate’s system is either prohibited or need to be approved by national legislation, accompanied by a data protection assessment.
The full list of signatories is:
Civil Liberties Union for Europe (Liberties), International
Defend Democracy, International
The Irish Council for Civil Liberties
Peace Institute, Slovenia
Human Rights Monitoring Institute, Lithuania
Rights International Spain
Solidarisches Salzburg, Austria
Verband Freier Rundfunk Österreich, Austria
Hungarian Civil Liberties Union
Aktive Arbeitslose, Austria
Legal-Informational Centre for NGOs, Slovenia
Civil Rights Defenders, Norway
Citizen D, Slovenia
Begegnungszentrum für aktive Gewaltlosigkeit, Austria
Homo Digitalis, Greece
Dutch section of the International Commission of Jurists
Verein Respekt.net, Austria
Verein Gegen Tierfabriken, Austria
Elektronisk Forpost Norge, Norway
Bulgarian Helsinki Committee
Vrijschrift, The Netherlands
Access Now, International
European Digital Rigts (EDRi)
Panoptykon Foundation, Poland
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