Datafication of the hotspots in the blind spot of supervisory authorities

The hotspot approach used to contain asylum seekers at the borders of Europe has been heavily criticized for deplorable conditions and multiple fundamental rights violations. This article dives into an underexplored issue in the hotspots, namely its datafication. It explores the question of the protection of personal data, and analyses whether the supervisory arrangements in place are sufficient to ensure the protection of personal data of individuals at the borders, or whether, as the current European Data Protection Supervisor states it, data protection is too often suspended at European Union borders. While supervision is in place to monitor the hotspots, this contribution shows that it remains limited and that many blind spots exist that fully escape any supervision. These emerge, for example by reasons of the complex legal framework of the hotspots, or of the informal nature of the exchanges of data.