In its submission, the global representative body for the humanist movement argued that the Commission’s current focus on reducing compliance costs for businesses ignores the significant human costs borne by individuals when protections are weakened. The organization stressed that regulatory efficiency should serve, rather than undermine, the rights of people subject to automated decisions, workers in algorithmically-managed environments, and citizens whose digital lives are increasingly monetized.
A primary concern raised in the submission is the proposed change to the definition of “personal data” in the General Data Protection Regulation. The proposal moves toward a “subjective standard,” where data might not be considered “personal” if a specific data controller claims they cannot identify the individual – even if another recipient of that same data could.
Humanists International warns that this shift conflicts with international human rights law, which requires an objective assessment of the entire processing environment. By narrowing this definition, the EU risks creating a “catch-22” where individuals lose their right to access or challenge the use of their data simply because a controller labels it as non-personal.
The organization also called for the retraction of a new provision that would grant the European Commission the power to declare certain pseudonymized data as “non-personal”. Humanists International expressed alarm that this centralizes decision-making in a political process that is vulnerable to industry lobbying, and weakens protections of human rights defenders.
The submission further highlights the danger of weakening protections against automated decision-making (ADM). The proposed changes would shift the GDPR’s stance from a “prohibition with exceptions” to a list of permitted cases, while simultaneously hollowing out the “necessity test” for contracts. Humanists International argues that ADM systems raise significant human rights concerns regarding privacy and proportionality. Weakening these tests allows companies to prioritize economic convenience over the least intrusive methods of data processing, hollowing out the substantive review process mandated by the Charter of Fundamental Rights
Rooted in the Luxembourg Declaration on Artificial Intelligence and Human Values, the submission urges the Commission to uphold its commitment to the Treaty of the European Union and the European Convention on Human Rights. Humanists International concludes that any effort to simplify the digital legislative framework must give “equal consideration to the costs for fundamental rights” rather than dismissing these amendments as merely “technical in nature”. The organization stands alongside leading digital rights groups, including noyb.eu and EDRi, in calling for the Commission to retract proposed harmful modifications.
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