The Chinese government’s ambition to use technology for social control and governance has been increasingly clear. As these technologies have matured, and as the Chinese government’s abuses have deepened under President Xi Jinping, the United States has vowed to counter this rise of “techno-authoritarianism.” The United States has portrayed its own technologies—and those of its allies—as a democratic alternative. But is this really the case? 

Online, the Chinese government’s Great Firewall, which blocks people in the country from accessing hundreds of thousands of websites outside China, is well known. Using a mix of coercion and incentives, the authorities compel major Chinese internet companies to censor online speech in an ever more efficient manner using a mix of human and artificial intelligence. Netizens’ efforts to “scale” the Firewall, or to post sensitive information using creative means such as using homonyms or graphics, are no match in this lopsided arms race.

Offline and in physical spaces, the Chinese Ministry of Public Security (MPS) has built an overlapping, multilayered, nationwide mass surveillance architecture over the past two decades, weaving an ever-tightening net around people. The government issues every citizen a national identification card and requires people to use the number to access many public and private services. This “real name registration” requirement enables the police to collect and compile vast databases of personal profiles linked to an individual’s ID. At the same time, the government has been blanketing the country with closed-circuit surveillance cameras (CCTV).  The authorities have bought artificial intelligence technologies from private companies—some with links to the state and the military—to help them automatically parse useful information from public surveillance footage streams. 

Chinese authorities’ mass surveillance systems do not only try to pick out specific individuals from the crowd. They aim to transform “unstructured information” into “structured information,” turning a chaotic visual field into something akin to a text file that can be easily, automatically analyzed, and searched. In the visual field, artificial intelligence extracts information such as the size and direction of crowds, the color and type of objects present, even whether the person has pimples or arched eyebrows, from live or archival video footage. As a result, a search based on these attributes (“where is that red umbrella”) can be easily performed, even in real time. 

While the Chinese police certainly depend heavily on visual surveillance in the form of CCTV networks, their surveillance systems encompass other technologies. Those include IMSI catchers, which locate and track all mobile phones that are switched on and connected to a network in a given area, thereby automatically detecting unique identifiers on people’s phones and other connected devices such as IMEI numbers and MAC addresses. Surveillance also includes the mass collection of people’s voice samples, DNA, iris scans, and even their gait, to form a multimodal portrait.

One might be able to get away with a 3-D printed mask to avoid facial recognition, for example, but multi-modal mass surveillance is aimed to be pervasive, all-encompassing, comprehensive—and nearly inescapable. The police additionally use analytics systems to uncover relationships and detect irregularities. In Xinjiang, where the government has cracked down on the Uyghurs, for example, the big data system known as the Integrated Joint Operations Platform identifies behaviors that the authorities consider suspicious—such as when phones suddenly go offline—and flags those individuals to officers for interrogation, arbitrary detention, and prosecution. 

Many of these surveillance technologies are not unique to China. But the depth, breadth, and intrusiveness of the Chinese government’s mass surveillance on its own citizens may be unprecedented in modern history. This mass surveillance remains unchallenged in China because there are few meaningful checks on government powers and the MPS is especially unaccountable.

Other state-owned tools, such as the central bank’s digital currency—which allows the authorities to surveil and control people’s financial transactions, among other capabilities—are not part of the MPS policing surveillance architecture. But they bear the imprint of the Chinese government’s technological authoritarianism: a top-down form of governance that monitors people and heavily influences their behavior by setting boundaries for what is acceptable and what is not. 

The emerging and expanding Chinese “technosphere” also includes other technologies that are functional and affordable. Huawei’s 5G equipment has reportedly been adopted by dozens of countries. Beijing’s Beidou navigation system now prevails over the U.S. version, GPS, in more than 160 countries. TikTok, owned by Chinese firm ByteDance, has gone global. Alibaba is making headway in Southeast Asia, and Tencent’s WeChat undergirds Chinese diaspora life. 

While most of these are private companies based in China, all are susceptible—to varying degrees—to the Chinese government’s pressure, censorship, and surveillance. Technological systems and their impact on society are notoriously difficult to study everywhere, given that many of these systems are black boxes whose trade secrets are guarded closely by the companies. Given the lack of rule of law and a free press in China, however, it is exceptionally difficult to obtain information from these companies or hold them accountable for abuses. 

The Chinese technosphere underpins a chillingly innovative model of governance: a technocratic country led by strongmen who efficiently deliver the people a mirage of modernity and progress. In contrast, democracies, with their competitive elections, free media, and an independent judiciary, appear to be slow, chaotic, captured by special interests, and unable to meet the challenges of our times. The technological bells and whistles of this governance model enhance the Chinese Communist Party’s overall efforts to make democracies appear obsolete.   

It is important not to overstate the Chinese technosphere’s prowess, though. The Chinese police’s mass surveillance ambitions are often stumped by difficulties, such as in integrating data across information silos. But if the general outline of China’s techno-authoritarianism is increasingly clear, how have democracies, particularly the United States, responded to it? 

The U.S. government considers the Chinese government its key competitor and has portrayed such competition, including over technology, as being about values. Former President Donald Trump’s Clean Network effort, for instance, sought to encourage other governments and network operators to work with companies that meet a set of standards—primarily that they are based in countries with democracy and the rule of law, but also because they have transparent ownership structures—while excluding Chinese companies from U.S. telecoms networks. It has also restricted Chinese tech companies’ access to U.S. technology, funding, and markets, citing human-rights concerns. For its part, the Biden Administration established the U.S.-EU Trade and Technology Council to deploy “new technologies based on shared democratic values, including respect for human rights.” 

While these initiatives stem from different sides of the growing political divide, they do have something in common—namely, their emphasis on values, as the words “democracy” and “human rights” are peppered throughout these policy documents.

This U.S. government narrative has at least three flaws, though. First, the stated motivation of promoting certain values obscures the realpolitik and protectionism that lie behind at least some actions on Chinese technologies. While it is true that TikTok poses a threat to privacy, for instance, sensitive data on virtually everyone in the United States are also available on the commercial data broker market. That is because Congress has never set an overarching national standard that meaningfully limits how most companies gather, use, buy, and sell personal data. Had the Trump Administration truly cared about privacy, it would have prioritized passing a federal privacy regulation, for which there appeared to have been bipartisan support in 2019. 

Second, the narrative implies that technology built and designed in the United States or other democracies is inherently and automatically more rights-respecting. Nothing could be further from the truth.

Companies based in democracies were intimately involved in the construction of the Chinese government’s surveillance state since its very inception. North American companies have reportedly helped lay Beijing’s architecture of surveillance, including the Great Firewall. U.S. companies have continued to provide “components, financing, and know-how” to power China’s surveillance infrastructure. Some of these very companies are nevertheless listed as “clean” under Trump’s clean network program because they “have rejected doing business with tools of the CCP’s surveillance state.” 

At the same time, U.S. mass surveillance—the scope and invasiveness of which was exposed by the former National Security Agency contractor Edward Snowden—has inspired counterparts in the Chinese military-policing surveillance complex. American surveillance of allies and partners, such as the European Commission or the former German Chancellor Angela Merkel’s phone, has left a lasting transatlantic scar. The idea that technology that is developed or produced by democracies (or even close allies) is inevitably or inherently secure or rights-respecting has not always resonated in Europe. 

Domestically, U.S. mass surveillance and bulk data collection have undermined media freedom, the public’s right to know, the right to legal counsel, and the ability of Americans to hold the government to account, as Human Rights Watch has documented. Also in U.S. cities, and particularly in overpoliced communities of color, the increasing use of facial recognition threatens people’s right to freely walk down the street without being watched by the government. 

In addition, the business model upon which some dominant U.S. tech companies rely is fundamentally incompatible with human rights. This model depends on an online advertising ecosystem, which captures everything people say or do online and profiles and mines that data to maximize attention and engagement on platforms while selling targeted advertisements. The economics of these platforms rely on pervasive tracking and profiling of users, which intrude on people’s privacy and feed algorithms that promote and amplify divisive and sensationalist content.

Finally, the very idea that embedding “democratic values, including respect for human rights” can replace the safeguards and oversight needed for a functioning democracy reeks of techno-solutionism and grossly oversimplifies the ways in which technological systems work. 

The good vs. evil narrative the U.S. government uses obscures its own role and that of Western companies in undermining human rights and democracy, including their impact globally. The privacy of people and civil society organizations in other countries is not just being threatened by mass surveillance systems sold by Chinese companies, but by a plethora of tech companies, many of which are based in democracies, as well as the rights-abusing business models and practices that they have exported. 

The United States could present a genuine alternative to China’s digital authoritarianism, if it was willing to rethink and prioritize rights at home and abroad. 

First, Congress should adopt a strong federal data protection law that regulates the collection, analysis, and sharing of personal data by companies, including with security and intelligence agencies. It should protect sensitive personal data, including biometric data, more strictly, and consider banning law enforcement from using facial recognition. It should also regulate data use by advertisers and data brokers. Additionally, the law should require human rights impact assessments for U.S. tech companies’ operations globally. Congress should also reform its national security surveillance laws, such as by repealing Section 702 of the Foreign Intelligence Surveillance Act to end bulk data collection.  

The United States should work with like-minded governments to strengthen export control regimes both at home and around the world to ensure that they do not facilitate transnational repression. This work should include a special focus on research into Chinese businesses involved in developing and supporting abusive systems. The Chinese surveillance technosphere is a big business, and more research is needed to investigate just how many players there are, how they relate to one another, and crucially, how much companies outside China are intertwined with these abusive systems, especially in the form of dual-use technologies, and how to tease them apart.

And more research is needed to establish whether American restrictions on Chinese tech companies have the intended impact, or whether these companies have managed to avoid and circumvent them. The United States should also prioritize and ramp up its work with like-minded governments in various technical standard-setting bodies such as the International Telecommunication Union, to incorporate the human-rights framework into technical standards, particularly internet governance standards. 

But reining in the worst tendencies with regulations is itself inadequate. The U.S. government should devote resources to experiment with bolder proposals, such as technological systems that can have a positive impact for democracy. The American nonprofit New Public has urged governments to develop “digital public spaces”—publicly owned online spaces designed to maximize public goods, for people to “talk, share, and relate without those relationships being distorted and shaped by profit-seeking incentive structures.” The government of Taiwan has engaged with a civic hacker collective known as g0v—collective member Audrey Tang later became the country’s digital minister—to incorporate participatory decision-making processes in its governance. Barcelona’s Decidim is another experiment involving a participatory democracy platform. 

The United States can become an actual leader by curtailing its worst technological impulses at home, preventing its technologies going into the wrong hands, and supporting the development of technologies that contribute to democratic participation. That would provide a genuine alternative to the Chinese government’s digital authoritarianism.