Can an algorithm reject your application for social benefits without telling you why? Can a child's image be used for commercial purposes? Can your voice be turned into a convincing fake video? And what happens when a public service requires an online application from someone who cannot use a computer?
These are among the questions addressed by the proposed Cypriot Declaration on Human Digital Rights, currently under discussion by the House Human Rights Committee.
The draft contains 45 articles and 33 categories of digital rights. It is not legislation but rather a policy framework intended to guide future laws and government action.
At its heart is a simple principle: the rights people enjoy offline should also be protected online.
Decisions should not belong to machines alone
Under the draft, if an automated system affects someone's employment, access to social benefits, education or healthcare, citizens should have the right to know what data and criteria were used.
More importantly, they should be able to request a genuine review by a human decision-maker with the authority to overturn the outcome.
The same principle applies to the assessment of pupils and university students, as well as to important medical and administrative decisions.
The Office of the Commissioner for Administration argued that the wording should go further, stressing that human oversight must be meaningful rather than a formal rubber-stamp of an algorithmic decision.
Responsibility, it said, must remain with the competent authority.
Children are more than just users
A dedicated section of the draft focuses on children.
It proposes stronger privacy protections and safeguards against:
- Online bullying
- Online grooming
- Blackmail involving personal material
- Abuse content generated using artificial intelligence
The framework also envisages child-friendly reporting mechanisms, victim support services and restrictions on the commercial exploitation of children's data.
It seeks to address digital practices designed to keep users continuously engaged online.
During the committee discussion, TEPAK assistant professor Gianna Danidou highlighted another concern: child influencers and the online publication of children's images by adults.
As she noted, many children acquire a digital footprint before they are even able to speak.
She called for safeguards against commercial exploitation and mechanisms allowing the deletion of material posted during childhood.
At the same time, the draft stresses that protection should not mean exclusion. Children retain rights to learning, creativity, information, play and participation in decisions affecting them, according to their level of maturity.
Protecting image, voice and privacy
The declaration also addresses the growing risks posed by synthetic media and artificial intelligence.
Photographs, voice recordings and videos can now be used to generate misleading content. The draft proposes measures for identifying and tackling such material, while strengthening rights to access, correct and, where legislation permits, delete personal data.
It also includes protections against arbitrary digital surveillance.
Representing SPAVO, Andri Andronikou argued that the text should explicitly address technology-facilitated domestic abuse.
She noted that surveillance and control of victims can continue through digital means even after a relationship ends, and called for such risks to be incorporated into threat-assessment protocols.
Public services without digital exclusion
A recurring theme of the draft is that digital transformation should not leave citizens behind.
The proposal states that people without internet access, mobile devices or digital skills should not be denied public services.
It therefore foresees practical assistance and, where necessary, equivalent non-digital alternatives that do not impose disproportionate costs or delays.
The provision is particularly relevant for:
- Older people
- Persons with disabilities
- Citizens who struggle with digital procedures
University of Cyprus associate professor Aristotelis Konstantinidis identified the "human alternative" to digital-only services as one of the most important provisions in the Cypriot text.
Rights at work and online shopping
The proposed framework extends to the workplace, providing protection against excessive digital monitoring and recognising a right to disconnect outside agreed working hours.
It also covers online shopping, with an emphasis on:
- Transparent pricing
- Easy cancellation of subscriptions
- Protection from misleading commercial practices
These issues, the draft notes, directly affect everyday transactions and the degree of control citizens retain over the digital services they use.
From principles to policy
Education Minister Athina Michaelidou said the ministry supports the philosophy behind the declaration and views both the draft text and its explanatory guide positively.
She said targeted suggestions would be submitted regarding:
- Child protection
- Meaningful participation of children in decisions affecting them
- Human oversight of automated systems
Discussion of the proposal will continue on 16 November, with the committee aiming to bring a resolution before the House plenary by the end of the year.
