Accompanied by thunderous applause and cheering crowds, an incredible one is announced digital innovation offered from Municipality of Bologna which is immediately blessed by the technophelics of our day. I obviously do not dispute the importance of digitization and the sharing of data in the Public Administration (PA) to favor online services in favor of citizens and businesses, as has been foreseen for some time in Italy by the Code of digital administration. But – as announced with great fanfare in a video interview by the councilor for the digital agenda Massimo Bugani – the Bolognese municipal administration has a digital innovation plan in the works which promises to be between now and 2024 change radically the relationship between citizens and the municipal machine, suggesting Orwellian scenarios that bring us not a little closer to what has already been happening for some time and carefree in China (and unfortunately also in some European countries).
In particular, this is the experimental development project of the so-called “Digital twin” of citizens, that is, of a real one avatar generated by the shared management of huge databases (a “flood of data”, as Bugani proudly defines them) which certainly has the benefit of accelerating certain administrative processes, but – like all simplifications – this innovation process can involve serious risks for the rights and freedoms – not only digital – of citizens under this lens of public control.
All the more so if you intend to favor the most virtuous by setting up a real “Smart Citizen Wallet”, that is a social credit – attributed according to reward mechanisms typical of social scoring – for virtuous behaviors that allow citizens access to dedicated benefits. In short, a nice prize competition for citizens is happily proposed transparent in the eyes of a voracious PA (by the way, but was it rather the PA that had to be transparent?). In a nutshell, the PA will say to this “decent citizen” – who does not take sanctions, is culturally active and behaves flawlessly: “we see you and recognize you with a score and this will enter a circular reward for which the citizen it will have actual economic benefits ”, as the commissioner calmly declares.
Can we like all of this? Not so much. Moreover, a few weeks ago, regarding the risks of the green pass, I argued that the vaccination tool is not in dispute, but the method used by our government to impose it. Perhaps in the future, in the wake of other emergencies, perhaps of an economic nature, we will begin to legitimize instruments similar to the green pass compression of fundamental rights for those who have not paid their bills regularly? Or for those who have not paid their taxes regularly and have not paid them in installments? Or – why not? – for those who don’t have a solid bank account?
Unfortunately, even if these comparisons have seemed to some a fanciful hyperbole, it cannot be denied that there is a worrying escalation that is opening – day after day – a serious chasm in the regulatory guarantees for the protection of our fundamental rights and freedoms, which could end. to pave the way for scenarios of simplistic solutionism even more disturbing.
However, I could not have imagined having to read – after a short time – that in our country some worrying tools would be adopted by public administrations. social scoring, blessed as technological miracles by a municipality like that of Bologna. On the subject, I would like to remind you that, moreover, if it should come into force – and I hope it will happen soon – the proposal for an EU regulation onArtificial intelligencethe use of social scoring systems (therefore of tools similar to what the Municipality of Bologna proposes today) by public authorities would be among the AI systems at risk unacceptabletherefore it would be considered prohibited.
Furthermore, the lightness with which we would like to overcome the “privacy problem” by ensuring that the system would work only with the consent of the citizen, who could freely download the relative app made available by the Municipality, leaves nothing short of perplexed. I would like to remind you that recital 43 of the Gdpr (i.e. EU regulation on the protection of personal data) expressly advises against adopting consent as a legal basis by public bodies.
In short, I have the unfortunate feeling that such is the poor culture of personal data protection that – I remember – protects our fundamental rights and freedoms (and such is the technological stupidity that characterizes the particular period we are experiencing), that we both the real risk and the case of the Municipality of Bologna do not remain isolated at all in our country, but rather be an example for other zealous PAs ready to make forward-looking leaps towards digital innovation, approaching with incredible unawareness the dynamics of the societies of some regimes characterized by a questionable level of democracy, like China. The risk, therefore, is that of importing and disseminating a made in Italy copy of the social scoring systems made in China in our free and democratic society.
I hope at least that the preliminary consultation process of the Guarantor for the protection of personal dataafter evaluation of a Robusta data protection impact assessment, as would be foreseen by the GDPR for large-scale treatments of this nature. And maybe the Guarantor can thus place such a project on other, more serious and less irresponsible, digital tracks.