In an open letter addressed to the European Parliament Civil Liberties, Justice and Home Affairs

Committee, 31 31 organisations protecting the rights of people on the move, children and digital

rights including European Digital Rights (EDRi) urge policymakers to radically change the direction

of the EURODAC reform – the European Union (EU) database storing asylum seekers’ and migrants’

personal data – in order to respect fundamental rights and international law.

If adopted, the legislative proposal would vastly expand the database, extending far beyond its original

purpose and leading to unaccountable and exponential surveillance at the EU’s borders. EURODAC

would cover a greater number of persons, data categories, and store data for a longer period of

time. People on the move, including children from the age of 6 , would have their fingerprints and facial

images captured, stored and cross-checked with several police and migration control databases.

This process would effectively label people as criminals by default, undermining rights to dignity,

privacy and data protection, the rights of the child, and the principles of necessity and propor –


In terms of the policy process, the signatories express their deep regret that no impact assessment

has been carried out. This gravely undermines transparency and due process and is completely incompatible

with democratic processes. In addition, little was done to involve and consult relevant

stakeholders and notably civil society organisations. Lastly, the automatic linkage of EURODAC to

the interoperability framework of EU information systems limits the possibility to hold an open debate

on the appropriate purpose of the database and on its interconnections with the other legislative

files of the Migration Package.

This is why the undersigned organisations call for:

• a temporary delay to the legislative process to give due time for significant consideration of

the fundamental rights implications of the EURODAC reform;

• the completion and publication of an impact assessment;

• meaningful consultation with civil society working on the fundamental rights of migrants,

children, data protection and digital rights;

People on the move deserve the same level of protection as anyone else and the EU should not take

advantage of their vulnerable situation to subject them to mass surveillance and undignified treatment.


Read the full Open Letter



Access Now, International

Amnesty International, International

Aspiration, USA

AsyLex, Switzerland

Border Violence Monitoring Network, International

Digitalcourage, Germany

Državljan D, Slovenia

Child Rights International Network (CRIN), International

Electronic Information Privacy Center (EPIC), USA – for digital rights, Austria

European Center for Not-For-Profit Law Stichting, International

European Council on Refugees and Exiles (ECRE), International

European Digital Rights (EDRi), International

European Network Against Racism (ENAR), International

European Network on Statelessness, International

Greek Forum of Migrants, Greece

Hellenic League for Human Rights, Greece

Hermes Center, Italy

Homo Digitalis, Greece

IT-Pol Denmark, Denmark

JustPeace Labs, International

Ligue des droits humains, Belgium

Maisha e.V.-African Women, Germany

Missing Children Europe, International

Network for Children’s Rights, Greece

Open Society European Policy Institute (OSEPI), International

PICUM – the Platform for International Cooperation on Undocumented Migrants, International

Red Acoge, Spain

Refugee Legal Support, Greece

Statewatch, United Kingdom

Terre des Hommes International Federation, International