When cloud computing enters border control, it stops being just an IT choice and becomes a governance decision with direct consequences for privacy, accountability, and even the safety of people on the move. A recent Georgetown Journal of International Affairs article argues that the European Union’s dependence on US hyperscalers such as Microsoft, Amazon, and Google has created a structural vulnerability in a safety-critical domain, and that Brussels should respond by reducing reliance on foreign cloud providers and investing in European-owned alternatives.
The central claim is straightforward but consequential: border control is not a generic digital use case. It is a safety-critical environment in which errors, data misuse, or vendor lock-in can affect people under exceptional pressure, often at moments when they have limited control over their own data. The article frames cloud infrastructure as part of the machinery of border governance, not a neutral back-office utility.
That framing is important because the EU has increasingly relied on cloud-based tools to coordinate screening, returns, identity checks, and data processing at the external border. In that setting, the choice of provider is not merely about cost or convenience. It is also about where data resides, who can access it, how it is protected, and which legal regime ultimately applies.
That dependence matters for two reasons.
First, the market is highly concentrated. The cloud business is dominated internationally by a handful of hyperscalers, which makes it hard for public bodies to avoid vendor lock-in once they adopt proprietary ecosystems. Second, those firms are not just service providers; they are powerful private actors with their own incentives, architecture choices, and compliance obligations. In a security-sensitive setting, that gives them real influence over how systems are designed and operated.
The article also highlights a geopolitical dimension. In an era of strained transatlantic relations and rising concern about critical technology supply chains, cloud infrastructure is no longer viewed as an ordinary commodity. It is increasingly understood as part of strategic state capacity.
That enforcement action is the strongest factual anchor in the article’s case. It shows that the concern is not abstract ideology or anti-tech sentiment. It is a documented regulatory finding that Frontex did not properly assess necessity, safeguards, or the limits on collection before moving sensitive processing into commercial cloud environments. The EDPS also ordered Frontex to review its DPIA and records of processing, underscoring that cloud migration in this domain must be legally justified, not merely technically convenient.
That issue is especially sensitive in light of the CLOUD Act, which the article cites as a reminder that US providers may still be compelled to produce data under US legal process. The legal tension here is real: even if data appears physically local, control, access rights, and provider obligations can still create cross-border exposure. The EDPS and European legal discussions around cloud transfers have repeatedly emphasized that storage location alone does not settle the matter.
This is why the article treats sovereignty as more than a marketing term. A cloud service can be “European” in appearance while still embedding dependence on external corporate control, external software stacks, and external legal authority.
Border control, especially at coastal or frontline checkpoints, is a setting where failures can have immediate human consequences. Data errors, misconfigurations, access failures, or poor identity checks may affect asylum seekers, migrants, refugees, and NGO personnel. The article correctly stresses that safety-critical environments require design choices shaped by proximity, organizational structure, regulatory constraints, and ethical obligations.
This perspective aligns with broader EU cybersecurity policy. The Commission has recently moved to strengthen the Cybersecurity Act and reduce supply-chain risks from third-country vendors in critical use cases. The revised framework explicitly aims to address vulnerabilities in ICT supply chains and improve resilience for essential services.
That matters under EU law. The EDPS’s Frontex decision found failures around necessity, data minimization, and data protection by design and by default. More broadly, the EU’s data protection framework for Union bodies and the law enforcement environment places a premium on limiting processing to what is necessary and on documenting safeguards before deployment. The article’s warning is that cloud migration can make these duties easier to neglect if procurement decisions move faster than compliance review.
The piece also notes broader scrutiny of Microsoft 365 use in EU institutions. The EDPS later found the European Commission’s use of Microsoft 365 infringed several key data protection rules, reinforcing the view that cloud use by public bodies requires far more than a standard procurement checklist.
That is a valuable warning. Once a public authority builds systems around a proprietary cloud stack, switching costs can become prohibitive. Data formats, identity and access controls, integrations, training, and operational dependence all deepen the lock-in. In a security context, lock-in can weaken democratic oversight because the public body may no longer be able to change suppliers without major disruption.
The article also points to a broader convergence between defense contractors, AI companies, and cloud providers. That convergence is already visible in EU policy discussions around incident response, cybersecurity reserves, trusted service providers, and supply-chain robustness. The Commission’s current cybersecurity package and related initiatives show that Brussels is acknowledging the strategic nature of these infrastructures.
That link matters because AI systems are often only as trustworthy as the infrastructure that hosts them. If the underlying cloud environment is opaque, centralized, or difficult to audit, then the AI layer inherits those risks. In border management, that can affect identity verification, screening, and return procedures, all of which are highly sensitive operations.
The article also challenges the assumption that practices from one domain can simply be transplanted into another. Tools designed for emergency response or military contexts do not automatically fit border enforcement, because the goals, legal thresholds, rights implications, and accountability structures are different. That is a subtle but important point in the wider debate about AI-as-a-service and cloud-based automation.
First, the EU should reassess its dependencies and foster local cloud solutions for security use cases. That means measuring digital dependence more systematically, including supplier concentration and supply-chain chokepoints. The article also suggests examining encryption key management carefully, because who controls the keys can matter as much as where the servers sit.
Second, policymakers should support free and open-source software to reduce vendor lock-in. That is not a magical fix, but it can improve transparency, portability, and long-term control if procurement is designed intelligently. The article also notes that switching away from hyperscalers may be costly in the short and medium term, which is an honest acknowledgment often missing from policy debates.
Third, security professionals and researchers should adopt socio-technical design approaches. This is crucial. Border control technologies cannot be assessed purely on technical performance metrics. They also need to be judged by legal constraints, organizational workflows, ethical obligations, and the lived vulnerability of the people affected by them.
The article is also timely. The Commission has recently proposed a revised Cybersecurity Act and broader cybersecurity package aimed at supply-chain resilience and risk reduction in critical ICT dependencies, which shows that the policy environment is moving in the same direction the author recommends.
That means procurement should be tied to a rigorous assessment of necessity, proportionality, jurisdiction, data flows, and vendor dependence. It also means the EU should be skeptical of “sovereign” branding that does not eliminate structural dependency or legal exposure. And it means that border control, AI adoption, and cloud architecture need to be discussed together rather than in separate policy silos.
In the end, the article makes a persuasive case that security-critical public functions should not be outsourced casually to commercial hyperscalers. Cloud computing may offer flexibility and scale, but in border control those benefits come with legal, geopolitical, and human-rights risks that deserve far more scrutiny than they have received so far.
The EU’s challenge is not to reject cloud computing outright, but to govern it as the high-stakes infrastructure it has become. In border control, that distinction is not academic. It is the difference between technological convenience and democratic responsibility.
Source: Georgetown Journal of International Affairs A Tool for Security? Cloud Computing in Border Control - Georgetown Journal of International Affairs
Overview: why border control cloud computing matters
The central claim is straightforward but consequential: border control is not a generic digital use case. It is a safety-critical environment in which errors, data misuse, or vendor lock-in can affect people under exceptional pressure, often at moments when they have limited control over their own data. The article frames cloud infrastructure as part of the machinery of border governance, not a neutral back-office utility.That framing is important because the EU has increasingly relied on cloud-based tools to coordinate screening, returns, identity checks, and data processing at the external border. In that setting, the choice of provider is not merely about cost or convenience. It is also about where data resides, who can access it, how it is protected, and which legal regime ultimately applies.
Dependency on hyperscalers
The article’s first major argument is that Europe remains heavily dependent on a small number of non-European cloud providers. In practice, this means public administrations and security actors often build on platforms controlled by companies headquartered in the United States, with all the commercial and legal implications that follow.That dependence matters for two reasons.
First, the market is highly concentrated. The cloud business is dominated internationally by a handful of hyperscalers, which makes it hard for public bodies to avoid vendor lock-in once they adopt proprietary ecosystems. Second, those firms are not just service providers; they are powerful private actors with their own incentives, architecture choices, and compliance obligations. In a security-sensitive setting, that gives them real influence over how systems are designed and operated.
The article also highlights a geopolitical dimension. In an era of strained transatlantic relations and rising concern about critical technology supply chains, cloud infrastructure is no longer viewed as an ordinary commodity. It is increasingly understood as part of strategic state capacity.
Frontex as the key example
Frontex sits at the center of the article’s critique because it illustrates how cloud services are being embedded in border governance. The agency has used Microsoft-based systems hosted on Azure for activities tied to migrant screening and forced returns, and has also relied on a hybrid setup involving Microsoft 365, Amazon Web Services, and Microsoft Azure. The EDPS publicly confirmed that Frontex moved to the cloud without a timely and exhaustive data protection assessment and reprimanded the agency for breaching EU data protection rules applicable to Union bodies.That enforcement action is the strongest factual anchor in the article’s case. It shows that the concern is not abstract ideology or anti-tech sentiment. It is a documented regulatory finding that Frontex did not properly assess necessity, safeguards, or the limits on collection before moving sensitive processing into commercial cloud environments. The EDPS also ordered Frontex to review its DPIA and records of processing, underscoring that cloud migration in this domain must be legally justified, not merely technically convenient.
Why “sovereign cloud” is not a simple fix
One of the article’s most useful points is that so-called sovereign cloud branding should not be taken at face value. The mere fact that data is stored in EU data centers does not eliminate dependency on US cloud vendors, nor does it necessarily resolve jurisdictional exposure.That issue is especially sensitive in light of the CLOUD Act, which the article cites as a reminder that US providers may still be compelled to produce data under US legal process. The legal tension here is real: even if data appears physically local, control, access rights, and provider obligations can still create cross-border exposure. The EDPS and European legal discussions around cloud transfers have repeatedly emphasized that storage location alone does not settle the matter.
This is why the article treats sovereignty as more than a marketing term. A cloud service can be “European” in appearance while still embedding dependence on external corporate control, external software stacks, and external legal authority.
Cloud computing as a safety-critical technology
A major strength of the piece is that it refuses to treat cloud computing as a universal solution. Instead, it argues that the technology must be judged in relation to the context of use. That is a sound engineering and governance principle.Border control, especially at coastal or frontline checkpoints, is a setting where failures can have immediate human consequences. Data errors, misconfigurations, access failures, or poor identity checks may affect asylum seekers, migrants, refugees, and NGO personnel. The article correctly stresses that safety-critical environments require design choices shaped by proximity, organizational structure, regulatory constraints, and ethical obligations.
This perspective aligns with broader EU cybersecurity policy. The Commission has recently moved to strengthen the Cybersecurity Act and reduce supply-chain risks from third-country vendors in critical use cases. The revised framework explicitly aims to address vulnerabilities in ICT supply chains and improve resilience for essential services.
The data protection problem
The article’s data protection critique is particularly strong because it connects technology choice with legal duties. In the border context, people on the move often have limited bargaining power and limited practical ability to consent, refuse, or monitor downstream data use.That matters under EU law. The EDPS’s Frontex decision found failures around necessity, data minimization, and data protection by design and by default. More broadly, the EU’s data protection framework for Union bodies and the law enforcement environment places a premium on limiting processing to what is necessary and on documenting safeguards before deployment. The article’s warning is that cloud migration can make these duties easier to neglect if procurement decisions move faster than compliance review.
The piece also notes broader scrutiny of Microsoft 365 use in EU institutions. The EDPS later found the European Commission’s use of Microsoft 365 infringed several key data protection rules, reinforcing the view that cloud use by public bodies requires far more than a standard procurement checklist.
Marketization and vendor lock-in
Another important theme is the marketization of border control. The article argues that border security is increasingly treated as a market segment in which consultants and vendors shape the field of possible solutions.That is a valuable warning. Once a public authority builds systems around a proprietary cloud stack, switching costs can become prohibitive. Data formats, identity and access controls, integrations, training, and operational dependence all deepen the lock-in. In a security context, lock-in can weaken democratic oversight because the public body may no longer be able to change suppliers without major disruption.
The article also points to a broader convergence between defense contractors, AI companies, and cloud providers. That convergence is already visible in EU policy discussions around incident response, cybersecurity reserves, trusted service providers, and supply-chain robustness. The Commission’s current cybersecurity package and related initiatives show that Brussels is acknowledging the strategic nature of these infrastructures.
AI, cloud, and border automation
The article wisely links cloud infrastructure to the spread of AI in border control. Cloud platforms are increasingly presented as the technical foundation for large-scale data processing, automated decision support, fraud detection, and biometric quality checks.That link matters because AI systems are often only as trustworthy as the infrastructure that hosts them. If the underlying cloud environment is opaque, centralized, or difficult to audit, then the AI layer inherits those risks. In border management, that can affect identity verification, screening, and return procedures, all of which are highly sensitive operations.
The article also challenges the assumption that practices from one domain can simply be transplanted into another. Tools designed for emergency response or military contexts do not automatically fit border enforcement, because the goals, legal thresholds, rights implications, and accountability structures are different. That is a subtle but important point in the wider debate about AI-as-a-service and cloud-based automation.
Alternatives: local clouds and open source
The article does not stop at criticism. It proposes a three-pronged policy response, and that constructive element is one of its best features.First, the EU should reassess its dependencies and foster local cloud solutions for security use cases. That means measuring digital dependence more systematically, including supplier concentration and supply-chain chokepoints. The article also suggests examining encryption key management carefully, because who controls the keys can matter as much as where the servers sit.
Second, policymakers should support free and open-source software to reduce vendor lock-in. That is not a magical fix, but it can improve transparency, portability, and long-term control if procurement is designed intelligently. The article also notes that switching away from hyperscalers may be costly in the short and medium term, which is an honest acknowledgment often missing from policy debates.
Third, security professionals and researchers should adopt socio-technical design approaches. This is crucial. Border control technologies cannot be assessed purely on technical performance metrics. They also need to be judged by legal constraints, organizational workflows, ethical obligations, and the lived vulnerability of the people affected by them.
Where the argument is strongest
The article is strongest when it insists on three linked propositions:- Cloud is not neutral in a border-control setting.
- Security-critical systems require context-specific assessment, not generic adoption logic.
- Data sovereignty and data protection are inseparable from procurement and architecture choices.
The article is also timely. The Commission has recently proposed a revised Cybersecurity Act and broader cybersecurity package aimed at supply-chain resilience and risk reduction in critical ICT dependencies, which shows that the policy environment is moving in the same direction the author recommends.
Where the argument is less complete
Still, the article leaves some open questions.Cost and feasibility
Reducing reliance on hyperscalers sounds sensible, but the operational and fiscal burden could be significant. Public agencies often adopt commercial cloud because it offers scalability, mature tooling, and faster deployment. The article acknowledges cost pressures, but it does not fully quantify the transition costs, migration risks, or procurement delays that an EU-wide shift could create.Performance and resilience trade-offs
Local or EU-owned solutions may improve sovereignty, but they are not automatically more secure or more reliable. The article leans toward the assumption that European ownership is preferable, yet security outcomes depend on architecture, operations, staffing, maintenance, and certification—not just ownership structure. That nuance matters, particularly in critical infrastructure.Defining “EU-owned”
The policy recommendation to use EU-owned cloud solutions is compelling but somewhat underdefined. Does it mean EU-headquartered providers? EU-operated infrastructure? EU-controlled governance? EU jurisdiction over data and keys? Those distinctions are not trivial, and different answers could lead to very different procurement outcomes.The larger policy takeaway
The broader lesson of the article is that the EU should stop treating border-control cloud migration as a routine digital modernization project. In a safety-critical environment, cloud choices are governance choices.That means procurement should be tied to a rigorous assessment of necessity, proportionality, jurisdiction, data flows, and vendor dependence. It also means the EU should be skeptical of “sovereign” branding that does not eliminate structural dependency or legal exposure. And it means that border control, AI adoption, and cloud architecture need to be discussed together rather than in separate policy silos.
In the end, the article makes a persuasive case that security-critical public functions should not be outsourced casually to commercial hyperscalers. Cloud computing may offer flexibility and scale, but in border control those benefits come with legal, geopolitical, and human-rights risks that deserve far more scrutiny than they have received so far.
The EU’s challenge is not to reject cloud computing outright, but to govern it as the high-stakes infrastructure it has become. In border control, that distinction is not academic. It is the difference between technological convenience and democratic responsibility.
Source: Georgetown Journal of International Affairs A Tool for Security? Cloud Computing in Border Control - Georgetown Journal of International Affairs
