Identifier
Created
Classification
Origin
07ATHENS2219
2007-11-15 06:59:00
SECRET
Embassy Athens
Cable title:  

GREECE: RESPONSE TO S/CT REQUEST FOR INFORMATION

Tags:  KVPR PTER PREL PGOV PINR CVIS ASEC KHLS GR 
pdf how-to read a cable
VZCZCXRO6689
OO RUEHAG RUEHROV
DE RUEHTH #2219/01 3190659
ZNY SSSSS ZZH
O 150659Z NOV 07
FM AMEMBASSY ATHENS
TO RUEHCSECSTATE WASHDC IMMEDIATE 0732
INFO RUCNMEM/EU MEMBER STATES COLLECTIVE PRIORITY
RUEHTH/AMCONSUL THESSALONIKI PRIORITY 1692
RHMFISS/FBI WASHINGTON DC PRIORITY
RHMFISS/HOMELAND SECURITY CENTER WASHINGTON DC PRIORITY
RUEAIIA/CIA WASHINGTON DC PRIORITY
S E C R E T SECTION 01 OF 09 ATHENS 002219 

SIPDIS

SIPDIS

S/CT FOR KEN MCKUNE, NCTC, AND DHS

E.O. 12958: DECL: 11/15/2017
TAGS: KVPR PTER PREL PGOV PINR CVIS ASEC KHLS GR
SUBJECT: GREECE: RESPONSE TO S/CT REQUEST FOR INFORMATION
ON HOST GOVERNMENT PRACTICES: INFORMATION COLLECTION,
SCREENING, AND SHARING

REF: SECSTATE 133921

Classified By: Charge D'Affaire Thomas Countryman for 1.4 (b) and (d).
S E C R E T SECTION 01 OF 09 ATHENS 002219

SIPDIS

SIPDIS

S/CT FOR KEN MCKUNE, NCTC, AND DHS

E.O. 12958: DECL: 11/15/2017
TAGS: KVPR PTER PREL PGOV PINR CVIS ASEC KHLS GR
SUBJECT: GREECE: RESPONSE TO S/CT REQUEST FOR INFORMATION
ON HOST GOVERNMENT PRACTICES: INFORMATION COLLECTION,
SCREENING, AND SHARING

REF: SECSTATE 133921

Classified By: Charge D'Affaire Thomas Countryman for 1.4 (b) and (d).

1.(SBU) Embassy Country Team has assembled the following
responses to REFTEL request for information on the government
of Greece's (GOG) practices on information collection,
screening, and sharing. Narrative responses below are keyed
to specific subject questions in reftel. Please note the
secret classification for portions of this cable.

SIPDIS

Watchlisting
--------------

2.(S) A. Watchlisting: If host government maintains a
"watchlist," how many records does the watchlist contain, and
how many are terrorist-related? Which ministry or office
maintains the watchlist?

-- As a member of the Schengen Information System (SIS),the
GOG reports that it has access to EU watchlists, in addition
to Interpol, and its own national criminal database. These
databases are maintained by the Hellenic National Police
(HNP). The GOG has not disclosed to Post how many of those
records are terrorist-related. The U.S. Terrorist Screening
Center's (TSC) watchlist is updated daily, but it is not
disseminated to the GOG; however, the HNP cooperate
extensively with Post on any Post-identified terrorist leads.
Per the Greek National Intelligence Service (EYP),the
Aliens Bureau of the HNP is the primary Greek government
entity designated to receive information pertaining to
watchlisting, although other HNP divisions have shared the
responsibility depending on the case.

-- EYP often receives watchlisting requests from foreign
government services, but it lacks the law enforcement
authority to take action. As a result, these requests are
forwarded to the HNP by the EYP or directly by the requesting
foreign government. EYP provides information to the HNP in

the course of its own investigations and those of select
liaison operations.

-- EYP claims that the GOG does not draw a distinction
between EU and non-EU watchlisting standards. EYP emphasizes
that privacy and data security laws in Greece are strict.
EYP cannot order the arrest or detention of any suspects
crossing the border; it can only provide supporting
information. EYP maintains regional representatives at key
points of entry who act only as intermediaries to borders and
customs authorities. EYP can request collection of
information about inbound and outbound individuals singled
out for watchlisting and retains this information in its
archives.

-- In most cases, EYP needs to provide a timeframe of the
person,s travel in order for the airport to search an
airline,s manifest to flag a specific traveler. EYP noted
that monitoring cruises and ferries is more difficult than
airports or land crossings.

Traveler Information Collection
--------------

3.(SBU) B. Traveler Information Collection: What are the
country's policies (legislation, mandates, etc.) on
collecting information from travelers arriving in the
country? Are there different policies for air, sea, and land
entry and for domestic flights? Who collects traveler
information? What are the policies of the collecting agency
to share that information with foreign governments? Does the
host government collect Passenger Name Record (PNR) data on
incoming commercial flights or vessels? Is this data used
for intelligence or law enforcement purposes to screen
travelers? Does host government have any existing treaties
to share PNR data? If applicable, have advance passenger
information systems (APIS),interactive advanced passenger
information systems (IAPIS),or electronic travel authority
systems been effective at detecting other national security
threats, such as wanted criminals?

-- As Greece is a participant in the SIS, it conforms to EU
legislation and mandates on collecting information from
travelers arriving in Greece. For example, when incoming
travelers, whether by air, sea, or land, apply for a Schengen
visa, their information is collected by the Schengen country

ATHENS 00002219 002 OF 009


where they apply and is centralized in the SQrQl countries, Third-Countrybases, SIS and the national database. The national
database examines Interpol, Greek alerts, and local criminal
records.

-- Traveler information is collected and accessed using SIS
by the HNP. The HNP report that it shares collected traveler
information on an ad-hoc basis with foreign governments.
When the Greek authorities find a hit on a SIS record, they
send the information to the SIRENE (Supplementary Information
Request at the National Authority) office located at the
Hellenic Police Headquarters in Athens. SIRENE responds by
sending notification forms of the discovery to the Greek
authorities at the port of entry, while the person is
detained and placed in secondary for further questioning.
The borders and customs authorities immediately alert the
Greek Anti-Terrorism Unit (ATU) as appropriate. The ATU,
reporting directly to the Ministry of Interior, arrives on
the scene to detain and question the suspects.

-- According to the HNP, the integration of a European
directive now mandates the use of Passenger Name Records
(PNR) on incoming flights. (Note: The EU signed a July 23
agreement on the processing and transfer of Passenger Name
Record (PNR) data by air carriers pre-flight to the
Department of Homeland Security (HS). End Note.) The HNP
reported that the reek authorities were only beginning to
phase in the use of PNR data to examine traveler information
prior to the landing of commercial aircrafts.

-- The HNP said they use this data for both intelligence and
law enforcement purposes to screen travelers when they
receive any derogatory information pertaining to the
travelers. Post is not aware of any other existing treaties
to share PNR data beyond the agreement between the EU and the
U.S. The HNP said it is having ongoing conversations with
commercial carries to access their PNR data.

-- Athens Embassy RSO reports that the Hellenic police have
been very helpful in locating criminals and suspected
terrorists wanted by the U.S. and INTERPOL. When a criminal
is identified while applying for a U.S. visa at the Embassy
and there is an INTERPOL Red Top, the Hellenic police have
sent officers to make the arrest within minutes.

-- Advance passenger information systems (APIS),interactive
advanced passenger information systems (IAPIS),or electronic
travel authority systems are not used by the GOG.

Border Control and Screening
--------------

4.(S) C. Border Control and Screening: Does the host
government employ software to screen travelers of security
interest? Are all travelers tracked electronically, or only
non-host-country nationals? What is the frequency of
travelers being "waived through" because they hold up what
appears to be an appropriate document, but whose information
is not actually recorded electronically? What is the
estimated percentage of non-recorded crossings, entries and
exits? Do host government border control officials have the
authority to use other criminal data when making decisions on
who can enter the country? If so, please describe this
authority (legislation, mandates, etc. What are the host
government's policies on questioning, detaining and denying
entry to individuals presenting themselves at a point of
entry into the country? Which agency would question, detain,
or deny entry? How well does information sharing function
within the host government, e.g., if there is a determination
that someone with a valid host-government visa is later
identified with terrorism, how is this communicated and
resolved internally?

-- Although it is a participant in the SIS, the GOG does not
employ software to screen travelers of security interest.
Documents are visually checked and random checks are
conducted on certain flights. No travelers are tracked once
they are in the Schengen zone. For non-Schengen flights, all
third-country nationals (TCNs) have their documents checked

ATHENS 00002219 003 OF 009


at passport control and are recorded electronically. The HNP
report that, although they do not use a formal screening
technique, they receive derogatory information on passengers
prior to their landing in Greece. Thereupon, the HNP is able
to detain and question the suspected terrorist or criminal.


-- The GOG does not have a percentage estimate of
non-recorded crossings, entries and exits, but it has the
following estimates on illegal immigrants. Based on
unpublished GOG statistics, the number of illegal immigrants
in Greece is estimated at 77,647 year-to-date, 73,438 (2006),
and 59,170 (2005). (Note: On November 5, Athens News media
reported that Greece's Merchant Ministry estimated that an
average 50,000 illegal immigrants try to cross into Greece
every year with a record-breaking 13,151 illegal immigrants
caught in September. Reports also claim that Greece will
soon receive a 13.7 million euro boostfrom the EU to
reinforce its land and sea borders from illegal immigration.
End Note.)

-- Border control officials have the authority to use other
criminal data available to them when they make decisions on
who can enter the country. In these cases, the border
security authorities can apprehend passengers once they cross
into Greek territory. Based on the Schengen convention,
police co-operation includes the right of information
exchange between cross-border police services, as well as the
right of cross-border surveillance and pursuit.

-- The HNP is the agency that would question, detain, or deny
entry to any individual at the POEs who are associated with
derogatory information. The GOG bases its policies on
whether the individual is a legal or illegal immigrant to
Greece. If the traveler is an illegal
Third-Country-National, Post has received reports that the
GOG can detain the individual for ninety days in a detention
facility. If the individual is a legal TCN, the GOG must
work with the host-government of the TCN to resolve the
issue.

-- The border control authorities do not have the final
authority on allowing travelers to enter Greece. This
authorization must come from the Ministry of Interior. The
border authorities send the file to the Ministry of Interior
who makes the final decision on the traveler's case.

-- Although Greek ministries share information amongst
themselves, bureaucratic hurdles remain. If there is a
determination that someone with a valid Greek visa is later
identified with terrorism, this issue is communicated and
resolved on an ad-hoc basis by telephone between the Ministry
of Interior and the HNP. Per para 12, information sharing
among different Greek security services can be challenging
due to territoriality and competition between them. However,
the HNP and the Hellenic Coast Guard are proactive and
cooperative in investigating terrorist threats.

-- The HNP noted that the GOG has formed an inter-ministerommittee on securing
bord%0 media
report, GOG minibe would continue to sric Collection
--------------

5.(SBU) D. Biometric Collection: Are biometric systems
integrated for all active POEs? What are the systems and
models used? Are all passengers screened for the biometric
or does the host government target a specific population for
collection (i.e. host country nationals)? Do the biometric
collection systems look for a one to one comparison (ensure
the biometric presented matches the one stored on the
e-Passport) or one to many comparison (checking the biometric
presented against a database of known biometrics)? If
biometric systems are in place, does the host government know
of any countermeasures that have been used or attempted to
defeat biometric checkpoints? What are the host government's
policies on collecting the fingerprints of travelers coming
into the country? Which agency is responsible for the host
government's fingerprint system? Are the fingerprint
programs in place NIST, INT-I, EFTS, UK1 or RTID compliant?
Are the fingerprints collected as flats or rolled? Which

ATHENS 00002219 004 OF 009


agency collects the fingerprints?

-- The GOG has not yet integrated biometric collection
systems for all active POEs. The GOG has plans to conform to
the European Visa Information System (VIS),which will be a
database of fingerprints and facial scans consisting of all
applicants for an entry visa into the Schengen group
countries. The system was established in June 2004 by the
European Council decision 2004/512/EC. Not all passengers
are screened for biometrics, except for the scanning of
passport data for those travelers from countries that do
provide biometric data on the passport chip. The biometric
collection systems look for a one-to-many comparison. Border
authorities have told us that illegal immigrants sometimes
use "crazy glue" to alter their fingerprints.

-- According to the Hellenic National Passport Center (NPC),
the HNP has started capturing fingerprints using EuroDac for
asylum seekers and irregular border-crossers. (Note:
EuroDac is the European finger database that is sent in
digitally to a central unit at the European Commission and
automatically checked against other prints in the database.
The purpose is to determine whether asylum seekers have
applied for asylum in another EU Member state or have
illegally transited through another EU Member State. End
Note.)

-- The HNP are responsible for collecting hard-copy
fingerprints from illegal immigrants at land POEs for entry
into a national database. The Hellenic Coast Guard is the
responsible entity for fingerprint collection at sea POEs.
Fingerprints are taken for illegal immigrants or other
persons of concern who are apprehended or taken into
secondary. Fingerprints are EFTS compliant and collected as
flats and rolled, without consistency. Greek authorities
also routinely collect palm prints, (but not the side of
hand) in addition to fingerprints.

Passports
--------------

6.(SBU) E. If the host government issues a machine-readable
passport containing biometric information, does the host
government share the public key required to read the
biometric information with any other governments? If so,
which governments? Does the host government issue
replacement passports for full or limited validity (e.g. the
time remaining on the original passports, fixed validity for
a replacement, etc.)? Does the host governmenthave special
regulations/procedures for dealing with "habitual" losers of
passports or bearers who have reported their passports stolen
multiple times? Are replacement passports of the same or
different appearance and page length as regular passprts (do
they have something along the lines of our emergency partial
duration passports)? Do emergency replacement passports
contain the same or fewer biometric fields as regular-ssue
passports? Where applicable, has Post noticed any increase
in the number of replacement or "clean" (i.e. no evidence of
prior travel) passports used to apply for U.S. visas? Are
replacement passports assigned a characteristic number series
or otherwise identified?

-- According to the Greek passport agency, Greek authorities
utilize a Public Key Infrastructure (PKI),which is changed
every three months. This public key is shared with the U.S.,
Schengen-participating countries, the E.U., and Australia.

-- The Greek government does not issue special replacement
passports, but will replace a lost or stolen passport with a
full-validity passport with the appropriate documentation
provided to the Greek police authorities. The replacement of
a new passport takes two months after the HNP conducts a
security clearance of the applicant. Each new passport is
assigned a unique passport number and is the same appearance
and page length as regular passports. As biometrics are not
used, the passports do not contain biometric fields. The GOG
does not issue passports to people who have already lost
passports twice in the year. The Fraud Unit is housed in the
HNP and has reported that it has taken 5,000 passports and
fraudulent documents out of circulation year-to-date.

-- Emergency passports are not issued. If a Greek citizen
has lost his or her passport, he or she can make an
application at an overseas Greek consulate for a travel
document that is valid to return to Greece. If a Greek

ATHENS 00002219 005 OF 009


citizen petitions an overseas consulate for an emergency
passport to travel to another country, he or she is told to
return to Greece with this travel document and make an
application for a new passport. This can take as long as two
months.

-- The passport agency is working towards electronic
personalization by including facial biometrics as well as
fingerprints, which will be compared manually and
electronically. By 2009, the GOG plans to have its
fingerprinting conform to the EU standards and plans to have
these biometrics auto-interface with systems, such as
Advanced Passenger Information Systems (APIS).

-- As of January 1, 2006, all Greek passports are issued
centrally and only by the National Passport Center which is
managed and staffed by the Hellenic Police. As a result, all
passports are "clean" when they are used to apply for U.S.
visas. All new passports have a machine-readable zone (MRZ)
and a unique passport number, but do not yet contain
biometric information. Emergency replacement passports do
not contain biometric fields.

Fraud Detection
--------------


7. (SBU) F. Fraud Detection: How robust is fraud detection
and how actively are instances of fraud involving documents
followed up? How are potentially fraudulently issued
documents taken out of circulation, or made harder to use?

-- Post believes that the GOG has an internal as well as
external problem with fraudulent documents but is attempting
to address the issue. In 2006, the Hellenic Bureau of
Internal Affairs dismissed and suspended officers involved in
corruption, primarily for forging documents and taking
bribes. Most charges against police involved violation of
duty, false certificates, abuse of power, corruption, and
violations related to alien registration. Documents such as
Hellenic national identity cards and passports are kept under
strict control by the Passport Authority and the Hellenic
Police.

-- The HNP does not place a high priority on punishment for
fraud cases. The penalties for committing fraud are not
stringent. In many cases, the offender can avoid prison by
paying bail.

-- The GOG has a special fraud unit housed in the HNP that is
dedicated to investigating cases of fraudulent documents.
The HNP reports that it has taken 5,000 passports and
fraudulent documents out of circulation year-to-date. Post
will provide additional information on GOG's anti-fraud
efforts after it meets with the GOG's fraud unit (septel).

Privacy and Data Security
--------------

8.(SBU) G. What are the country's policies on records related
to the questioning, detention, or removal of individuals
encountered at points of entry into the country? How are
those records stored, and for how long? What are the
country's restrictions on the collection or use of sensitive
data? What are the requirements to provide notice to the
public on the implementation of new databases of records?
Are there any laws relatially identifyi
to acceQase files (fo example, records about
enforcement actions)? Does a non-citizen/resident have the
right to sue the government to obtain these types of data?

-- Due to the restrictive laws on privacy and data, the GOG
said that it collects information but does not disclose
records related to the questioning, detention or removal of
individuals encountered at points of entry. The GOG
maintains data records in storage indefinitely. If these
records belong to an illegal immigrant, these records are
kept by the Aliens Bureau, again for an indefinite period of
time.

-- Although the GOG has privacy laws similar to the U.S.,
these laws are considered more restrictive than the U.S. in

ATHENS 00002219 006 OF 009


certain circumstances. The GOG collects sensitive
information when someone applies for a passport, ID card, or
other form of national ID. The information collected as a
result of a police arrest is not normally disseminated by the
HNP, particularly if this information relates to a Greek
citizen. A legal framework exists to obtain &sensitive8 or
&classified8 data based on the parameters established by
the Mutual Legal Assistance Treaty per Para 9.

-- Although the European Union Data Protection Directive
(EUDPD) requires that all EU members must adopt national
regulations to standardize the protection of data privacy for
citizens throughout the EU, the GOG is not yet fully
compliant, and continues to work on these issues. The GOG
has legislation requiring the issuance of a court order or
warrant in order to collect information on a terrorist or
criminal act.

-- A Greek citizen can access data held by homeland security
agencies by petitioning a specific ministry or agency. In
turn, the ministry or agency verifies the applicant and
provides him or her with the requested information. Post is
unaware of differences between an application to access raw
data versus case files.

-- Prior to implementing a new database of record-keeping,
the initiative must be examined in a public legislative
process. As the legislative process is normally conducted as
an open hearing/debate; therefore, a certain level of notice
is provided to the public. Additionally, the GOG engages in
a public affairs campaign to educate and notify citizens of
this new data-collection initiative. For example, when the
GOG increased penalties associated with vehicular traffic
violations, it was required to advertise this change to the
public. The notice of a new database must also appear in the
daily gazette.

-- A non-citizen/resident has the right to sue the government
to obtain personal data.

Immigration Data Base
--------------

9.(S) H. What computerized immigration databases are used to
track entries and exits? Is the immigration database
available at all ports of entry (POEs)? If immigration
databases are available at some POEs, but not all, how does
the host government decide which POEs will receive the tool?
What problems, if any, limit the effectiveness of the
systems? For example, limited training, power brownouts,
budgetary restraints, corruption, etc.? How often are
national immigration databases updated?

-- Per para 5, Greece participates in SIS to track entries
and exits. It is updated on a regular basis. This database
is available at all ports of entry. There are several
allegations that corrupt guards allow people to pass through
the borders without proper documentation.

-- A British Embassy source reported that the effectiveness
of monitoring and screening capabilities is limited due to a
lack of adequate training for police personnel. He also
stated that the British Government was working on training
several members of the Airport HNP on how to properly use the
systems in place. Conversely, the HNP said that the
borders/customs control authorities do receive regular and
comprehensive training on the systems.

Watchlist and Information Sharing
--------------

10.(S) I. Watchlist and Information Sharing: Is there a
name-based watchlist system used to screen travelers at POEs?
What domestic sources of information populate the name-based
watchlist, i.e. names of deported persons, terrorist
lookouts, criminal wants/warrants? What international
watchlists do the host government use for screening
individuals, e.g. Interpol or TSA No Fly lists, UN, etc.?
What bilateral/multilateral watchlist agreements exist
between host government and its neighbors?

-- The GOG is part of the SIS and has access to EU lists and
Interpol lists as stated in para 2. The GOG places alerts on
names on an ad-hoc basis when it receives information from
foreign governments.

ATHENS 00002219 007 OF 009



-- The GOG uses the SIS and the Greek national watchlists
(NSIS). Greek authorities put local criminals on the NSIS
watchlist and suspected terrorists into the SIS system.
Greek authorities claim that they always search all
watchlists, including the Interpol list.

-- The TSA no-fly list is only provided to air carriers
departing to the U.S. and not to agencies of other
governments. The names on that list are shared with Interpol
and provided by the Department of Homeland Security -
National Terrorist Security Center.

-- Under the 1932 Extradition Treaty, the U.S. and the GOG
exchange information on criminals through a formal process.
In some instances, criminals may be able to circumvent this
process if they claim Greek citizenship. However, U.S.
representatives reported that the police continue to provide
significant assistance even in these cases.

-- Based on the 1999 Mutual Legal Assistance Treaty, there is
robust cooperation between the U.S. security/intelligence
agencies and the HNP, as well as with the Greek National
Intelligence Services in tracking and investigating terrorist
leads. Post believes that it is possible to develop
Memorandums of Understanding between the U.S. and the GOG to
encourage further data sharing on terrorists and terrorist
activity. Besides the E.U. and the U.S., Post does not know
of any other bilateral/multilateral watchlist agreements that
exist between the GOG and its neighbors.

Biometrics
--------------

11.(SBU) J. Are biometric systems in place at ports of entry
(air, land, sea)? If no, does host government have plans to
install such a system? If biometric systems are available at
some POEs, but not all, how does the host government decide
which POEs will receive the tool? What biometric
technologies, if any, does the host government use, i.e.
fingerprint identification, facial recognition, iris
recognition, hand geometry, retinal identification, DNA-based
identification, keystroke dynamics, gait analysis? Are the
systems ICAO compliant? Does the host government issue a
machine-readable passport containing biometric information?
If e-Passports are issued, what biometric information is
included on the document, i.e. fingerprint, iris, facial
recognition, etc. If not, does host government plan to issue
a biometric document in the future? When?

-- Biometric systems are not yet in place at Greece's ports
of entry (POEs) (air, land, sea),but the GOG indicated a
desire to implement these systems in 2009. The GOG places a
high priority on placing biometric systems at its two main
airports in Athens and in Thessaloniki. The GOG will
implement biometric systems in accordance with SIS and in
compliance with EU legislation. We note that any traveler
information collected and stored must be compliant with EU
regulations.

-- The Greek law enforcement agencies have begun to capture
fingerprints, photos, and biodata for illegal Third-Country
Nationals (TCNs). This information is kept in storage
indefinitely at the local Aliens Bureau. For TCNs that enter
legally, their passports with the MRZ are swiped at the POEs
and their biodata is scanned.

-- Although the GOG uses fingerprint identification and
facial recognition using the photo on the travel document, it
does not utilize iris recognition, hand geometry, retinal
identification, DNA-based identification, keystroke dynamics,
nor gait analysis. Systems are ICAO-compliant, meaning that
countries participating in ICAO have the systems in place to
potentially read each other's software in the future.

-- At present, the GOG issues a machine-readable passport,
which has a Radio Frequency Identification (RFID) chip.
Border control authorities swipe only the MRZ of the
passports. e-Passports are issued, but contain only biodata
and a photo as data fields. Moreover, e-Passports do not
incorporate fingerprint and iris identification. Facial
recognition is only utilized to the extent that a photograph
is used. GOG has stated that it plans to incorporate
biometrics, but they have not provided Post with a definite
timetable.

ATHENS 00002219 008 OF 009



Identifying Appropriate Partners
--------------

12.(S) K. Department would appreciate post's assessment of
whether host government would be an appropriate partner in
data sharing. Considerations include whether host government
watchlists may include political dissidents (as opposed or in
addition to terrorists),and whether host governments would
share or use U.S. watchlist data inappropriately, etc. -- Are
there political realities which would preclude a country from
entering into a formal data-sharing agreement with the U.S?
-- Is the host country's legal system sufficiently developed
to adequately provide safeguards for the protection and
nondisclosure of information? -- How much information sharing
does the host country do internally? Is there a single
consolidated database, for example? If not, do different
ministries share information amongst themselves? -- How does
the country define terrorism? Are there legal statutes that
do so?

-- Post considers the GOG an appropriate partner in data
sharing based on a high level of cooperation and coordination
between Post and the GOG. Although challenges exist to
implementing a data sharing agreement, Post believes that GOG
is committed to securing its borders and is open to receiving
assistance and/or support to strengthen its screening and
monitoring capabilities in the area of counterterrorism.

-- Although GOG maintains watchlists, it allows individuals
it considers to be fleeing persecution access to its
refugee-admission process, including refugees from Turkey who
sympathize with the Kurdistan Workers' Party (PKK) ) a State
Department recognized Foreign Terror Organization (FTO).
Nonetheless, Greece maintains one of the lowest asylum-seeker
approval ratings in Europe at one percent per a 2006 United
Nations Refugee Agency report. Post also believes that the
GOG would not share or use the U.S. watchlist data
inappropriately.

-- The GOG faces political hurdles in solidifying a formal
data-sharing agreement with the U.S. The GOG is presently
examining its data privacy and security laws. This issue
remains controversial among the Greek populace as the GOG
used to maintain records on the political affiliation of its
citizens during the Junta era (1967-1974). At the same time,
Post believes that most Greek government entities engaged in
border security now consider illegal immigration to be their
number-one security issue. They are looking for ways to
identify and process the hundreds of refugees or immigrants
arriving daily. Thus, the time appears ripe to approach GOG
for closer cooperation.

-- Post believes Greece's legal system is sufficiently
developed to adequately provide safeguards for the protection
and nondisclosure of information on its citizens. There does
not exist a single consolidated database for sharing data.
Different ministries in the GOG share information among
themselves on an ad-hoc basis.

-- Information sharing among different Greek security
services can be challenging due to territoriality and
competition between them. However, the HNP and the Hellenic
Coast Guard are proactive and cooperative in investigating
terrorist threats.

-- The GOG is seeking to improve its internal data sharing
capabilities and has appointed an inter-ministerial committee
dedicated to addressing immigration issues and improving
border control. The Ministry of Interior, overseeing the
HNP, and the Ministry of Mercantile Marine, overseeing the
Hellenic Coast gh the EU utilizes a standard definition for
terrorism, which deems that terrorism is illegal, Greece has
a statutory defense for acts aimed at establishing or
restoring democratic regimes, or in the exercise of
fundamental civil or political rights. Moreover, the Greek
constitution provides for the right of access to
government-held information. Per the 2006 Human Rights

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Report, the GOG granted its citizens access to the data that
it had collected upon their request.

-- Additionally, Post would like to highlight that it works
closely with the GOG on database sharing, training of Greek
security and customs officials, training of judicial
personnel and the improvement of Greek border and
cargo-container security through programs such as the
Container Security Initiative (CSI). Post believes that the
GOG is diligent in its apprehension and disruption efforts of
alien smuggling routes and organization.

-- All U.S. agencies concerned with alien smuggling of all
nationalities have received excellent cooperation from the
Greek authorities. In July 2007, Immigration and Customs
Enforcement (ICE) and the HNP conducted a joint investigation
into one of the most prolific Iraqi alien smuggling
organizations operating in Greece.

-- In addition, Athens Embassy LEGAT enjoys a good working
relationship with various sections of the HNP. In 2006,
LEGAT coordinated three separate training seminars in Crisis
Negotiation, Interviews and Interrogation, and
Counterterrorism. Over 170 police officers of all ranks
participated.
COUNTRYMAN