SHARE Foundation #hiljadekamera campaign against Belgrade Safe City biometric surveillance (2019–ongoing)

In early 2019, Serbia's Minister of Interior publicly announced that Belgrade would receive one thousand smart surveillance cameras with facial recognition and licence plate recognition capabilities supplied by Huawei — the public face of a Safe City strategic partnership the Ministry of Interior and Huawei had formalised in a Strategic Cooperation Agreement in 2017, itself emerging from a broader 2009 Serbia-China bilateral framework. The SHARE Foundation — Belgrade's principal digital rights organisation, a 2017 member of European Digital Rights (EDRi), and the institutional anchor for Southeast European digital rights advocacy — initiated and sustained the civil society campaign against the deployment from March 2019 onward, working through a combination of investigative disclosure, freedom of information requests, a three-organisation legal analysis of the Ministry's Data Protection Impact Assessment, a crowdsourced civic camera-mapping initiative, and a documentary film to produce the first independent public record of the surveillance infrastructure's actual footprint and to establish the deployment's legal non-compliance as a matter of formal regulatory record.

The Belgrade Safe City project

The Huawei Safe City framework reached Belgrade through a path that began with the 2009 Serbia-China bilateral agreement and accelerated through the 2017 Strategic Cooperation Agreement between Huawei and Serbia's Ministry of Interior. The system as publicly announced contemplated one thousand smart cameras with object and facial recognition features and AI-powered analytics capabilities at eight hundred locations across the capital, to be rolled out in phases. A Huawei-published case study that SHARE Foundation retrieved and analysed in March 2019 revealed the Phase 1 implementation in detail: one hundred high-definition cameras across more than sixty key locations, with a command and data centre established in Belgrade; the documented capability set included facial recognition, behaviour analysis, automatic licence plate recognition, 4K video with H.265 encoding, cloud networking infrastructure, and an OceanStore data storage system with a one-year retention period. The case study disclosed no legal basis for any of these processing operations.

The Huawei case study investigation and FOI findings

SHARE Foundation's March 29, 2019 investigation — which retrieved, translated, and published an analysis of a Huawei promotional case study detailing the Belgrade Safe City deployment — constituted the campaign's opening act and its first transparency win. Huawei had published the case study as a commercial account of the project; SHARE Foundation's disclosure of the investigation prompted Huawei to remove the case study from its website, a documented instance of the system's operator scrubbing its public record under civil society scrutiny. Simultaneously, SHARE Foundation submitted freedom of information requests to the Ministry of Interior seeking the camera location data and the human rights impact analysis for the surveillance system. The Ministry refused disclosure, classifying procurement documents as confidential and — in a direct contradiction of the Minister's own public announcement about one thousand cameras — claiming to hold no location analysis data in any document or medium. The contradiction between the Minister's public statement and the Ministry's FOI response became anchoring evidence in the campaign's subsequent legal analysis.

The December 2019 DPIA policy brief

When Serbia's new Personal Data Protection Law — closely modelled on the EU's General Data Protection Regulation — entered into force in August 2019, it imposed on the Ministry of Interior an obligation to conduct a Data Protection Impact Assessment (DPIA) before deploying a large-scale biometric surveillance system of the Safe City type. The Ministry completed and delivered a DPIA in September 2019. SHARE Foundation, together with Partners for Democratic Change Serbia and the Belgrade Centre for Security Policy (BCSP), published a joint policy brief on 3 December 2019 analysing the Ministry's DPIA against the Personal Data Protection Law's requirements. The brief concluded that the document failed to meet both formal and material legal conditions: it contained no comprehensive description of the smart video surveillance data processing operations; it lacked the risk assessment for the rights and freedoms of data subjects that the Law requires; it omitted adequate data protection measures; and it failed to establish a lawful basis for mass biometric processing. The brief's conclusions were independently endorsed by Serbia's Commissioner for Personal Data Protection, who publicly confirmed that the DPIA "was not conducted in line with the requirements of the Personal Data Protection Law" and that it lacked "risk assessment regarding the rights and freedoms of data subjects". This regulatory confirmation placed the deployment's legal standing in formal dispute and established a documented record of non-compliance directly with the body responsible for enforcing Serbia's data protection framework.

#hiljadekamera: the civic initiative and documentary

In November 2019 SHARE Foundation launched the #hiljadekamera ("Thousands of Cameras") civic initiative — a grassroots campaign built around the dual tasks of mapping the surveillance infrastructure's actual footprint and building public awareness of biometric surveillance's incompatibility with fundamental rights. The initiative's crowdmapping platform, hiljade.kamera.rs, went live in mid-May 2020 alongside dedicated social media accounts; citizens contributed camera locations via tweet and direct platform submission using the #hiljadekamera hashtag. Within the first two months, the crowdsourcing effort identified 689 cameras with facial recognition capabilities across Belgrade — twice the count on the official police list — revealing the deployment's actual footprint to be substantially larger than state authorities had acknowledged and that the Belgrade surveillance infrastructure had expanded significantly beyond the government's public disclosures. The campaign also extended to an educational portal informing citizens of their legal rights and explaining how facial recognition technology works.

In July 2020, SHARE Foundation released a ten-minute documentary film — also titled #hiljadekamera — addressing the key legal, technical, and rights questions raised by the surveillance deployment. The documentary featured interviews with digital experts, initiative representatives, Serbia's Commissioner for Personal Data Protection, and Ella Jakubowska, Policy and Campaigns Officer at EDRi, whose contribution framed biometric systems as creating "a threat to your identity" and challenging the fundamental right to dignity in public space. The film's release, amplified through EDRi's European civil society network, carried the Serbian campaign into European policy conversations at a moment when the European Commission was drafting what would become the EU AI Act — an alignment that SHARE Foundation lead lawyer Ana Martinović has described as strategically significant.

Legislative advocacy and ongoing pressure

Ana Martinović, SHARE Foundation's human rights litigation lawyer with European Court of Human Rights experience, led the campaign's advocacy over the five years from its 2019 launch, submitting written comments on draft amendments to Serbia's Law on Internal Affairs that would have provided a legislative basis for biometric surveillance in public spaces — comments submitted twice on successive draft iterations. Each legislative attempt was subsequently withdrawn under civil society pressure; as of 2026 no mass biometric surveillance law had been enacted in Serbia. The campaign has also engaged the EU AI Act process as an external accountability lever — a channel made substantively relevant by Serbia's EU candidate status, since accession negotiations carry expectations of alignment with EU fundamental rights norms in which the AI Act's biometric surveillance restrictions now sit. SHARE Foundation has hosted AI governance summer schools for European activists and experts on these questions, functioning as a knowledge-building and network node for the European civil society community working the biometric surveillance issue.

Significance for the broader AI-good movement

The #hiljadekamera campaign is the corpus's first campaign entry from Southeast Europe and the first entry in the corpus's surveillance-accountability register from the Western Balkans. Its structural position matters on three counts. First, it is the first campaign in the corpus to document grassroots civil society response to the deployment of Chinese-manufactured biometric surveillance infrastructure in a European country — the Huawei Safe City framework's first appearance in the corpus — making the Belgrade case a reference point for how organising can respond to Chinese technology transfer as a vehicle for state biometric surveillance capacity in states outside Chinese domestic regulation. Second, the campaign's multi-channel architecture — investigative disclosure, FOI litigation, DPIA legal analysis, crowdmapping civic initiative, documentary, and sustained legislative commentary — represents one of the most fully articulated multi-phase campaign forms in the corpus, operating over a sustained multi-year arc with a continuous feedback loop between the public record the crowdmapping produced and the legislative arguments the campaign pressed. Third, the campaign's use of EU accession obligations and the EU AI Act as an external accountability lever is the corpus's first entry where a candidate country's accession process is structurally central to the campaign's theory of change — a route potentially replicable across the other Western Balkan candidate states (Albania, Bosnia and Herzegovina, Montenegro, North Macedonia) that share Serbia's context but have fewer comparable civil society institutions. The campaign connects the corpus's European biometric surveillance thread — anchored by the EDRi-coordinated Reclaim Your Face European Citizens' Initiative and the EDRi-coordinated EU AI Act fundamental rights coalition — to the Balkan region's grassroots AI-good layer, and extends the corpus's Eastern European coverage beyond its previously Poland-only anchor in the Panoptykon Foundation's algorithmic profiling campaign.