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Submission to the European Commission Consultation: Security-Related Information Sharing

Date 30 March, 2023
Category Policy Brief

The Commission’s initiative for a ‘Security-related information sharing system between frontline officers in the EU and key partner countries’ is a further development along the path of problematic border externalisation, and a trend of increasing use of large-scale processing of the personal data of non-EU citizens for combined criminal law and immigration control purposes, that civil society has been speaking out against for years. The proposal cites strengthened security measures within EU borders in the form of new interoperable IT architecture, and puts forward its plans to expand this to non-EU Member States (MS). There have already been a number of initiatives at the EU level to increase the availability of personal and biometric data to border guards and law enforcement officers, which brings into question the necessity and proportionality of yet another interoperability initiative. Further to this, the aim of the initiative, to facilitate increased police identity checks and to repurpose the data collected for other means such as readmissions and deportations, is not met with sufficient safeguards for people on the move. The initiative will expand the already problematic Safe Third Country (STC) “system” that has seen people on the move expelled, pushed and/or pulled back to countries like Turkey and Libya where their fundamental rights are at substantial risk of being further violated. In light of this, and based on the information expanded upon below, we (the undersigned organisations) believe that this initiative should not proceed and that there is no legal basis under which the sharing of sensitive personal information between EU and non-EU authorities should be pursued.


As the report outlines extensively, there are already a number of initiatives by the Commission seeking to facilitate the sharing of information between EU and non-EU states. A number of these have been extensively criticised by civil society for posing threats to asylum procedures and the safety of third-country nationals who have sought protection from corrupt regimes in EU Member States. This raises doubts as to the necessity of this new initiative as well as the sufficiency of the safeguards proposed with it. Case studies from the MENA and Western Balkan regions clearly elucidate how such interoperability mechanisms are playing out on the ground and have devastating effects on the fundamental rights of people on the move. In light of the analysis presented above we, the undersigned organisations, call for the Commission’s initiative not to proceed and for attention to be focussed on sufficient safeguards around the current mechanisms that have already been unsatisfactorily implemented.

Signed by:
Border Violence Monitoring Network (BVMN)
Euromed Rights
European Digital Rights (EDRi)
Access Now
Privacy International (PI)
Refugee Law Lab, York University
Homo Digitalis
Platform for Undocumented Migrants (PICUM)
European Network Against Racism (ENAR)
Dr Niovi Vavoula, Queen Mary University of London
Dr Derya Özkul, University of Oxford