Digital Surveillance Trends and Chinese Influence in Light of the COVID-19 Pandemic

Abstract

Countries across the world expanded digital surveillance strategies in response to the COVID-19 pandemic. As the pandemic occurred contemporaneously with a global trend toward greater digital repression, commentators advanced the notion that China would use the health crisis to promote a technology-enabled form of authoritarian governance abroad. This article surveys the evidence for these claims by first examining the literature on the increase of digital surveillance associated with China and then presenting three case studies from developing countries with varying responses to the COVID-19 pandemic. The selected countries – Brazil, South Africa and Vietnam – used surveillance technology as part of their pandemic response and have either been influenced by Chinese approaches or adopted Chinese technology in recent years. Examining these case studies allows us to better understand claims regarding China's role in the general spread of digital surveillance and the interplay between Chinese state objectives and local political environments. Crucially, we illustrate how China's engagement in digital governance abroad is heavily contingent on domestic environments. Against a backdrop of China's growing influence in global digital governance, the effects observed in these case studies of Chinese surveillance models and technology proliferating through pandemic management are diffuse and contextualised by local factors.

The COVID-19 Pandemic and Chinese Influence in Global Digital Surveillance

The emergence and subsequent spread of the SARS-CoV-2 virus led countries worldwide to implement a range of measures intended to protect their populations and economies from the COVID-19 pandemic. National response strategies varied in scope and proportionality from those focused on eliminating COVID-19 to those intended to suppress viral transmission or mitigate its effects.¹ While there has been debate about the efficacy of various strategies and the specific regulations operationalising them,² it is notable that a myriad of surveillance tools and techniques were adopted on an unprecedented scale in an attempt to monitor the propagation of the virus.³ These strategies encompassed several layers of technology, including new or improved approaches such as location-tracking apps, artificial intelligence (AI) devices, large-scale closed-circuit television (CCTV) networks, biometrics wearables, drones, and big data analytics.⁴

Debate and discussion around the role of technology and data in society, both within civil society and the scholarly community, predates the pandemic.⁵ However, COVID-19 propelled the use of data-driven surveillance tools to a new level in many countries’ public health strategies. In multiple jurisdictions, the health crisis precipitated incursions into citizens’ personal data that had been unjustifiable before the pandemic. Many governments took extraordinary measures to control the spread of the virus as state officials tracked, collected, and analysed people's personal information, including data on their physical locations, beyond typical procedures of due process and state oversight.⁶ Therefore, as pandemic response strategies were implemented, concerns about government-led surveillance were raised; fingers were pointed at states ranging from single-party autocratic regimes to more liberal constitutional democracies.⁷

The pandemic also came at the tail end of a decade that saw growing Chinese involvement in global digital infrastructure⁸ – the very same digital infrastructure involved in many countries’ pandemic responses. It is unsurprising, then, that pre-pandemic discussion of China's impact on international data governance has now given rise to a debate about China's influence on pandemic management and surveillance strategies abroad. With the background of a public health crisis operating as a legitimate reason and shroud for a significant increase in state surveillance, authors argued that the pandemic rendered a proof of concept as well as a political opportunity for the deployment of illiberal technologies related to China's repression model.⁹ Others highlighted that China's pandemic response strategies could diffuse to other countries due to its major power status and global economic role.¹⁰ From this vantage point, the global adoption of surveillance technologies and practices would be a consequence of China's ambitions to promote its leadership in the digital realm, ultimately shifting how states conduct the business of governance.¹¹

Notwithstanding these claims, other scholars have challenged the idea that China is intentionally exporting some form of digital authoritarianism.¹² Gagliardone notes that China's supply factors may encourage the proliferation of technologies that have adverse consequences; however, evidence is lacking to support assertions on its intention to promote surveillance overseas.¹³ Similarly, Matthew Erie and Thomas Streinz propose conceptualising China's influence in digital infrastructure abroad through a ‘Beijing Effect’. Namely that China's impact on both governance and development is created through demand and supply-side factors.¹⁴ These interpretations challenge the notion that the international adoption of technology for illiberal purposes is influenced by the Chinese Communist Party (CCP) state security objectives and alleged desire to re-shape global governance.¹⁵

This article attempts to contribute to the ongoing debate about China's role in the global spread of digital surveillance as well as claims regarding China's role in the rise of digital repression. We do so by examining technology and data use in managing the pandemic across three jurisdictions that show growing links with Chinese information and technology (ICT) companies and that have experienced a rise in digital surveillance in recent years: Brazil, South Africa, and Vietnam. To this end, we use the COVID-19 pandemic as an analytical framework, as it has been a particular circumstance in recent global history where governments and populations favored technological surveillance as a way to manage the advance of the virus.¹⁶

Through our cases, we compare the deployment of such surveillance practices in light of the pandemic and explore whether and how China could influence the spread and governance of such strategies.¹⁷ We observe that the increase in digitally intrusive strategies during the pandemic has been primarily linked to domestic predilections in our sample, such as each countries’ institutional features, political capacity to employ large-scale surveillance systems, and their own interests in replicating Chinese surveillance models or engaging with its technology companies. Thus, we contend that simplistic claims linking the use of Chinese technology to the increase in digital surveillance generally depict a causal relation that is not necessarily confirmed in practice. Instead, we argue that the pandemic illustrates there can be little correlation between the adoption of Chinese surveillance technology and the erosion of democratic institutions or civil liberties per se – yet this relationship may still be noted to play out around factors made available in local contexts, which we explore in our three case studies. We conclude by highlighting that insofar there is growing evidence showing Chinese ambitions to influence data governance models and surveillance practices globally,¹⁸ such influence in times other than a pandemic needs to be seriously evaluated against local driving factors. These local conditionalities structure China's technological engagement abroad and play a significant role in potentially adverse outcomes such as increased digital repression and digitally empowered authoritarianism.

There are two methodological caveats to this research. First, our case studies are useful for disentangling discernible trends of international discourses about China's role in the spread of digital surveillance; nevertheless, they should be assessed together with other works that examine the topic through different angles and countries from our own.¹⁹ Our main goal herein is not to provide absolute conclusions about the role of China in the global spread of digital surveillance. Rather, we aim to illuminate and contextualise narratives around Chinese companies providing surveillance infrastructure to developing nations. Second, further research to evaluate the correlation between Chinese influence and the rise of digital surveillance may take different approaches.²⁰ Our own approach, examining closely the experiences of countries in their interaction with China and how their uptake of surveillance strategies was formed, show that countries demonstrate divergent experiences shaped by traceable developments in their own domestic trajectory and intentional choices to engage with China. These accounts highlight nuanced aspects of relevance to studies on Chinese surveillance technology and models proliferating abroad.

The article is divided into three sections in addition to this introduction and its conclusion. First, we examine the aforementioned discussions regarding China's influence on digital repression and governance abroad. Then, we present the case studies on Brazil, South Africa, and Vietnam, comparing how each of these countries applied distinct pandemic responses and to what extent they used Chinese technology or were influenced by Chinese approaches to pandemic management surveillance. Finally, we analyse whether and how China's digital surveillance model is spreading to other countries. We also put forward some considerations and further research questions on how China could effectively exert influence on data management abroad.

Interpreting China's Role in the Global Spread of Digital Surveillance

Over the past few decades, the densification of digital infrastructure and the exponential increase in internet bandwidth has enabled an ever-growing amount of data to be collected, processed, and stored around the world.²¹ Through these technological foundations, the world has witnessed an emerging raft of surveillance practices surrounding new digital tools and techniques, which have significantly transformed how governments and private enterprises wield data for enhanced state control and economic data-driven applications.²²

While not the first protagonist of these surveillance trends,²³ China has come to attract global attention for its companies’ growing prominence in producing such digital technologies. In the last decade, firms such as China Mobile, China Unicom, China Telecom, Huawei, ZTE, Hikvision and Dahua have become global leaders in the ICT market, offering diverse solutions to national and international consumers.²⁴ Concurrent with the advance of Chinese companies, the world has also experienced a rise in digital repression as global internet freedom has been continuously declining and several countries have adopted censorship mechanisms and automated surveillance systems.²⁵ Based on these observations, commentators began to highlight China's role in this process as the ultimate model of political repression and the go-to supplier for authoritarian regimes seeking to shore up domestic control.²⁶ Thus, when the first human infection of COVID-19 was confirmed in Wuhan, China was already in the spotlight for its growing role in deploying surveillance mechanisms at home and abroad.

Although some of the concerns about the Chinese government and companies providing surveillance tools to other countries seem well-founded, the real picture of whether and how China has been pushing its governance model to other countries is not as clear as critics usually suggest. In this section, we juxtapose two of the primary academic interpretations of how China could be exerting international influence to reshape global norms and standards in ways that enable authoritarian behaviour in the digital realm. First, we present the claims on how China is strengthening digital surveillance abroad in advancing its ‘techno-authoritarian’ political model by transplanting technology-based enablers of repressive rule. Then, we look at the literature that examines China's influence through a more complex framework of interactions between local and international factors.

China Exporting Digital Authoritarianism

‘Digital authoritarianism’ is broadly defined as the use of digital information technology by authoritarian regimes to surveil, repress, and manipulate domestic and foreign populations.²⁷ The conceptual narrative highlights how illiberal governments have been increasingly using technology-driven playbooks for authoritarian rule – the most notorious contemporary example being China itself.²⁸ While the dangers to civil liberties to those living in China seem evident, the claim of its role in transplanting digital authoritarianism to other jurisdictions is less clear.

The claim first relates to the economic activities of different Chinese companies providing digital tools with advanced surveillance capabilities to governments with poor human rights records. Among the most ubiquitous technologies are advanced facial-recognition software, safe city projects, and data-analytic tools. Some actors argue, inter alia, that Chinese technology is embedded with a malign governance model that allows substantial information collection and tracking, strengthening government overreach while reducing domestic freedom.²⁹ Crucially, these positions generally suppose a Chinese strategy to promote its normative values through a coordinated effort between the CCP and corporate actors, whether state-owned or (formally) private;³⁰ an example being the recent accusations that Huawei, as an agent tied extensively with the Chinese state, has pitched products and services for its surveillance solutions, acting in coordination with the CCP's agenda.³¹ Additionally, commentators highlight how China's technology exports have been fuelling illiberal regimes through the support of its financial institutions – which are touted to be less intrusive than Western organisations.³² Thus, as Chinese companies peddle its products with little or no conditionalities on domestic policies, they become particularly attractive for authoritarian regimes barred from global financial markets.³³

Second, authors argue that China's major power status and its leadership in international organisations could help diffuse its ‘model’ to other countries, as China's example creates permissive conditions for authoritarian regimes to enhance their repressive capacity.³⁴ Under this logic, other governments would be encouraged to replicate China's apparatus of repression, whether due to Chinese financial support or indirect political allowances. This process would also entail a cross-border regulatory effect. As China accesses new markets, ones with allegedly weak regulatory frameworks, it helps push forward new rules in domestic jurisdictions on digital rights, privacy, and data collection, through emulation and modelling.³⁵ To this end, critics underscore how Chinese companies have been hosting officials from a number of countries for periodic training on its sprawling system of censorship and surveillance,³⁶ and how Chinese companies also face pressure from the Chinese government to spy, sabotage, or take other actions on its behalf, making global data more accessible to Chinese intelligence agencies through both legal and extra-legal methods.³⁷

Although other authoritarian governments, such as Russia and Saudi Arabia, have also been exploiting the surveillance toolkit for their own purposes,³⁸ China, according to some, arguably plays a greater role in this trend as its companies have been a major driver for the expansion of surveillance tools worldwide. Since 2008, at least 80 countries have adopted public security technologies and surveillance platforms from Chinese companies.³⁹ The customer profile is varied, including emerging as well as developed nations.⁴⁰ The fact that other European, North American, and Asian companies provide the same technology is overshadowed by the fact that their market share in surveillance solutions is much smaller than that of Chinese companies.⁴¹

While it seems clear that digital authoritarianism as a narrative accurately describes several worrying trends in the employment of digital technologies, the approach seems to exaggerate the degree to which China has been actively transplanting governance approaches on surveillance tools and techniques to other jurisdictions. In particular, many scholars appear to agree that the argument of China pushing digital authoritarianism in other countries is oversimplified.⁴² Instead, a model acknowledging demand-side drivers in addition to supply-side factors might better explain China's influence on other countries concerning the adoption of digital technologies and the conditions of their use.

China's Influence in Global Digital Surveillance: A Two-Fold Narrative

Current media, state, and academic discourses speculate about coordinated efforts between the Chinese state and private actors to promote digital surveillance practices abroad. Even though this remains a valid hypothesis, the speculation emphasises the fact that Chinese supply factors prompt the proliferation of governance and surveillance technology. In this light, the CCP would be willing to assert a Chinese-based vision of digital governance in other jurisdictions. Some scholars, however, raise critical questions about how we should interpret China's adaptive posture and its willingness to meet foreign actors in their often-unique circumstances.

Gagliardone, for instance, provides a measured account of Beijing's growing geopolitical footprint. He argues that as Beijing expands access to digital infrastructure in Africa, the means of its ICT system also imply political processes available in local contexts. The proclivity to technically and financially support state actors regardless of their legal environments and political regime type raises questions about how China negotiates differences. More to the point, this conception of a locally responsive China does not necessarily negate complicity in adverse outcomes on the ground – like unwarranted surveillance. Rather, it points to how we should examine local and global features as interconnected vectors.

This reading is strengthened by Erie and Streinz. While not the first commentators to describe China's influence through a push/pull framework,⁴³ these authors employ this interpretation in articulating the theory of what they term the ‘Beijing Effect.’⁴⁴ This term appears deliberately chosen to contrast with the ‘Brussels Effect’, a term describing instead how Europe influences governance and corporate behaviour abroad through European Union (EU) regulation and standardisation.⁴⁵ Speaking specifically with respect to technology governance, the ‘Beijing Effect’ argues that China develops and exercises influence through a combination of demand-side and supply-side factors, an approach less overtly legalistic compared to the EU and United States’ (US) propensity for exercising influence through extraterritorial application of regulation or formal legal instruments.⁴⁶ Pull, or demand-side, factors include emerging countries’ desire for affordable digital development as well as a desire to retain control over domestic and cross-border data flows.⁴⁷ On the other hand, push, or supply-side, factors include China's activities to promote its technology and, to some extent, its approach to governance in international fora or through global development initiatives such as the Digital Silk Road.⁴⁸

The ‘Beijing Effect’ theory refines more general theories regarding China's influence on technology governance abroad, but it does so primarily for a narrower set of technology use cases than are frequently discussed in the digital repression literature. In this regard, other scholars expand the forms digital authoritarianism may take. For example, Steven Feldstein provides a relatively comprehensive treatment of what he refers to as ‘digital repression’,⁴⁹ creating a taxonomy of the forms in which such repression appears. Feldstein divides digital repression into five practices, namely, surveillance, censorship, social manipulation and disinformation, internet shutdowns, and persecution of individuals for online activity. Feldstein argues, however, that there is not much evidence that other countries are adopting repressive digital tools and techniques because China is allegedly pushing them.⁵⁰ Rather, other factors better explain which governments engage in digital repression and which methods they use to do so. Feldstein specifically mentions the role of political environments, intelligence and security capacity, and levels of social media penetration in host nations.⁵¹

Answering whether China is exporting not only technology but also its values and governance approach requires further consideration of what ‘export’ entails. Scholars like Alden and Alves contend that China's technology and technical support does not mean categorical exportation of its normative values.⁵² Instead, they contend that Beijing helps amplify domestic-led processes already present in local environments. Likewise, Gagliardone, Erie and Streinz, and Feldstein all argue convincingly that the notion of the exportation of values does not hold up under an interpretation of intentional pressure by China for other countries to adopt its approach to technology and data governance. This view, however, is contrasted by other authors, such as Emily de La Bruyère, Samantha Hoffman and Nigel Cory, who see in the Chinese government's policies and statements ambitions to promote a model of state controlled and delimited cyberspace.⁵³ According to their reading, the CCP is strategically and deliberately rewriting the international digital architecture to shape the emerging global governance regime to closer align with Beijing's social and political values. This is precisely happening as the party-state increasingly controls cross-border data flows and influences the adoption of international norms, standards, and new digital infrastructure in other parts of the world.

In light of this debate, case studies on the use of Chinese technology in managing the pandemic in various jurisdictions can shed light on patterns in such technology and data use and, therefore, provide material for conclusions regarding China's influence on the adoption and governance of digital surveillance in other countries.

Digital Surveillance During the COVID-19 Pandemic: Case Studies on Brazil, South Africa, and Vietnam

As COVID-19 spread around the world, many countries were driven to systematically roll out or extend an array of digital measures of unprecedented scale and intrusiveness. Between February 2020 and March 2021, at least 80 countries in the world had employed some sort of surveillance strategy in their quests to track COVID-19 infections.⁵⁴ Such surveillance took a myriad of forms, from governments using digital applications to chart the virus’ trajectory from broad swaths of personal data to physical infrastructure monitoring quarantine compliance.⁵⁵ In times of a pandemic, the use of digital tools with surveillance capabilities was greatly excused by public opinion, pushing government practice beyond legal and ethical boundaries.⁵⁶ Thus, the rapid embracing of such technologies and their opaque operational mechanisms promptly sparked debates about the impact on privacy and the need for proper oversight.⁵⁷ If technology was already being used with growing implications to human rights, the pandemic catalysed this process, raising concerns about the extent and limits of public and private overreach.

This was the case of China's own pandemic response, the first country to detect COVID-19 and to implement a large-scale panoptic strategy to prevent contagion.⁵⁸ The health strategy adopted by China is a paradigmatic case that illustrates the potential and challenges arising from the use of digital infrastructure in the face of a public crisis of the magnitude of COVID-19. China's case is also relevant for our analysis as it shows how the country pursued a strategy made available by a particular entanglement between the Chinese party-state, Chinese technology companies, and Chinese society – a distinct relationship that constrained partner countries attempting to replicate China's surveillance approach to COVID-19.⁵⁹

Although the success of China's pandemic response has been associated with strict lockdowns, mass testing, and isolation protocols based on its previous responses to the 2002 severe acute respiratory syndrome (SARS) outbreak, digital surveillance tools were extensively used to complement these measures.⁶⁰ Prominent strategies included the processing of telecommunications networks data through smartphone apps – specifically the Alipay Health Code⁶¹ – as well as new layers of technologies such as the use of drones, biometric wearables, and big data analytics.⁶² After the first cases were registered in the country, China was able to build new data surveillance tools at a quick pace by leveraging existing e-technology and data surveillance infrastructure while tapping into its close relations between the state and private sectors.⁶³ China's response system was rather unique in this aspect as it collected new data by adding new health surveillance infrastructure to existing networks, rather than creating novel systems or using established data streams.⁶⁴ While some tools resembled examples seen internationally, others have gone a step further, expanding, for instance, the national authorities’ reach over citizens’ private messages.⁶⁵

Examining China's particular pandemic response reveals characteristics which suggest less coherent intentionality or transferability to different regimes given that China's health digital surveillance model developed within its own system with certain Chinese characteristics. In particular, the development of its strategy came up through endorsed competitive evolution from local governments and relied heavily on existing public-private collaboration between the state and technology companies such as Alibaba and Tencent, which had already built out an existing digital application infrastructure. Therefore, China's response was characterised by a local government-focused ground-up approach rather than a coordinated central approach strategised from Beijing,⁶⁶ which seems to reduce the opportunity for intentional transplantation to partner countries.

While China's context shows limited evidence of intent to correspondingly influence other countries’ pandemic response, its technology exports prior to the pandemic led commentators to argue that not only the crisis would accelerate the spread of digital repression, but it would also fuel China's drive to export surveillance practices to other jurisdictions.⁶⁷ In this section we analyse these claims in the face of three case studies that highlight how different governments with growing links to the Chinese government and companies coped with the COVID-19 health crisis. To this end, we examine publicly available documents on how digital surveillance strategies were modelled in Brazil, South Africa, and Vietnam – three counties that have used Chinese technology as part of their pandemic response or have been influenced by Chinese surveillance approaches in recent years.

The case studies offered here represent complementary but distinct political contexts. Brazil and South Africa are regarded as flawed democracies, while Vietnam has an authoritarian government.⁶⁸ In recent years, all three countries have witnessed the growing involvement of Chinese ICT companies in their markets as they provide telecommunications hardware and software to governments agencies and private actors, often outcompeting technology companies from the US and Europe. Paralleled to this emergence, the three countries have also watched a decline in the quality of democracy⁶⁹ and internet freedom,⁷⁰ and, in the case of Brazil and Vietnam, a rise in digital repression indicators.⁷¹ Thus, the three case studies together present a diverse analytical scenario where Chinese digital surveillance technology and techniques are being deployed against a scenario of diminishing democratic standards.

Brazil

The use of digital strategies has been a remarkable element in Brazil's pandemic response. Since the outbreak of COVID-19, public authorities have implemented a variety of technologies to coordinate health actions and enforce quarantine mandates.⁷² The most relevant technologies employed at the national level included developing a contact-tracing application, collecting data from telecommunications networks, installing AI-empowered facial recognition cameras (FRC) in public and private venues, and using drones. Chinese companies were not directly involved in these efforts; however, a large part of Brazil's pandemic strategy relied on technology deployed by them in the country before and during the pandemic.

The first guidelines for the Brazilian pandemic response were framed in Law No 13,979, a legislation that was approved in early February 2020.⁷³ Through this enactment, the Brazilian government granted its Ministry of Health broad powers to deal with the public health emergency with the aim of preventing the spread of COVID-19. For this purpose, the law mandated the recording of data of confirmed and suspected individuals, and the sharing of essential personal data to government agencies for their respective identification. All data collected has been stored in the National Network of Health Data (Rede Nacional de Dados em Saúde or RNDS), a database created in May 2020 and controlled by the federal government.⁷⁴

After Brazil's parliament approved the law, discussions in the Brazilian national government emerged around creating a large-scale surveillance platform to trace infections. Jair Bolsonaro's administration then formulated two main strategies: (i) ordering private telecommunications companies to share user data with government entities and (ii) developing a national contact-tracing application. However, during the course of the pandemic, the Brazilian government faced several obstacles to successfully implementing its strategies due to institutional and political challenges.

The first measure was initially set by the Bolsonaro administration in April 2020 in an announced partnership with the five largest telecommunications operators in the country.⁷⁵ Through this strategy, the government would have had access to data collected from the cell phones of almost all Brazil's population, which would have then been anonymised and used to identify risky areas through geolocation. Nonetheless, public rebuke and concerns around privacy risks caused President Bolsonaro to retreat from his initial plan and suspend the negotiations with telephone operators.⁷⁶ Shortly after the political defeat, the government pushed forward a provisional measure that would have given the country's statistics office access to personal data held by telecommunications companies.⁷⁷ However, Bolsonaro's order was met with several challenges in Brazil's Federal Supreme Court, which struck down the measure under the premise that it did not sufficiently explain how the telecommunications databases would be used against COVID-19 nor how the data collected would be protected.⁷⁸ The court's concerns with governmental databases were highlighted by the information leakage affecting more than 16 million Brazilian COVID-19 patients in November 2020 and a successful cyberattack against the RNDS in December 2021,which brought the platform offline for a month and caused patients’ logs to disappear.⁷⁹

The restrictions on the use of non-consensual data from telecommunications companies constrained other actions by the federal government, but allowed subnational entities (ie, states and municipalities) to develop their own partnerships with private companies, as long as they abided by Brazil's General Personal Data Protection Law (Lei Geral de Proteção de Dados or LGPD), which sets high standards for data collection and processing – closely resembling the EU's General Data Protection Regulation (GDPR).⁸⁰ As of December 2021, at least 47 subnational entities in Brazil have done so, and have been using geolocation data collected through public-private partnerships to define their local health policies.⁸¹ One active company in the country has been Google, which partnered with multiple local governments to provide Community Mobility Reports.⁸² Another relevant company has been Brazilian In Loco, a local branch of the US-based company Incognia, which provides geolocalisation services to companies and governments.⁸³

In addition to the use of geolocation data, the Brazilian government launched a contact-tracing application called Coronavírus-SUS, developed by DATASUS, the Informatics Department of Brazil's public-funded healthcare system, the Sistema Único de Saúde (SUS).⁸⁴ The app's first version was launched in February 2020 with basic features. The second version released in September, however, implemented the Google/Apple Exposure Notification (GAEN) API,⁸⁵ which allowed patients who tested positive to share their results with health authorities and warn other individuals of possible exposures through anonymous, temporary Bluetooth tokens that utilised users’ devices for data processing and storage.⁸⁶ Nevertheless, the app registered a very low penetration with around 10 million downloads as of November 2020 – less than 5 per cent of Brazil's population.⁸⁷

Besides these two large strategies, local governments also approved pilot projects for the monitoring of citizens via Remotely Piloted Aircraft (or drones)⁸⁸ and demand for FRC systems significantly increased in public and private venues, such as airports and schools.⁸⁹ The use of these new technologies highlights a growing trend in Brazil as both strategies are being increasingly supported by state agencies and promoted as effective mechanisms to combat crime – a strong argument in a country still faced by high criminality.⁹⁰

While Chinese companies were not behind any of Brazil's pandemic strategies, their technology supported them extensively. Since the late 1990s, Chinese telecommunications companies have gradually gained a greater role in the country, providing hardware and software solutions to local and non-Chinese companies operating in the country. Huawei is a notorious example as the company currently accounts for two local data centres and about 40 percent of wireless communications networks in operation in Brazil.⁹¹ Currently, all national and multinational companies in the sector use its equipment and maintenance services.⁹²

Furthermore, Huawei has launched a series of pilot initiatives with local governments promoting the use of smart city projects and FRCs systems in recent years⁹³ and has also strategically partnered with Brazilian telecommunications giant Oi to commercialise facial recognition technology in the country.⁹⁴ Besides Huawei, other companies such as ZTE, Dahua and Hikvision have also become increasingly relevant in the local market.⁹⁵ The latter two have been particularly active in providing facial recognition hardware and software to government agencies before and during the pandemic.⁹⁶ In 2020, at least 13 new projects were mapped between these companies and public authorities aimed at pandemic control.⁹⁷ Their projects included, eg, AI-enabled camera solutions for identifying individuals, measuring temperature and detecting mask use. Although they are not the only ones operating in Brazil's market, their range is impressive and it is estimated that they have already developed about 266,000 camera systems in the country.⁹⁸

Therefore, the role of Chinese companies and their equipment in current discussions on technology regulation in the country is somewhat disputed. On the one hand, there are no obvious causal links that the Chinese government or its companies have influenced, or sought to influence, Brazil's take on data governance or pandemic management. On the other hand, the digital infrastructure deployed by Chinese companies has supplied Brazilian and non-Chinese actors with new digital tools that have strengthened their capacity to collect data on Brazil's population. Moreover, although the adherence to the surveillance solutions of Chinese companies did not attract particular attention from Brazil's public opinion throughout the pandemic, the growing collecting of data from such technologies has propelled discussions about data governance currently taking place in the country, especially regarding the implementation of 5 G networks and the widespread use of FRCs.

In the first case, Huawei has been in the spotlight around the discussions about its participation in Brazil's much anticipated 5 G spectrum auction. Although public officials initially rejected its participation due to concerns on data security – following the US ‘Clean Network’ proposal⁹⁹ –the government backed off and allowed the use of Chinese technology, restricting it from the government's stand-alone private network.¹⁰⁰ Now, the company is expected to be the likely supplier of all major telecommunications operators in the 5 G local market.¹⁰¹ The change in position was the last chapter of a long struggle between the Bolsonaro's administration and the Chinese government, and had as background the supply of Chinese vaccines to the country.¹⁰² China's biopharmaceutical Sinovac increased its shipments of Active Pharmaceutical Ingredients for the local production of CoronaVac vaccines after Brazil signalled it would not ban Huawei from the 2021 auctions as the country faced vaccine shortages.¹⁰³

In the second case, as the use of FRCs quickly advanced in the country pushed, to some extent, by Chinese companies’ supply and support, legislative and judicial debates have arisen about whether the surveillance technology complies with Brazil's data protection framework. For instance, in April 2022, São Paulo's Justice Court suspended a public announcement for the installation of FRCs in the city's metro due to concerns on its non-compliance with the LGPD – a dispute Chinese companies were expected to take part in.¹⁰⁴ The issue is now waiting for national legislation on the topic or a decision by the country's independent data authority. São Paulo's example is just one in a series of other embroiled discussions happening in the country as local governments and private companies that have adopted the technology now face legal challenges.¹⁰⁵ In this regulatory vacuum, it has been easy for surveillance companies, including Chinese, to move into Brazil.

It is important to highlight that Chinese companies are not the only suppliers of these technologies;¹⁰⁶ nevertheless, their pilot projects and public-private partnerships have played a remarkable role in promoting their products locally. Brazil's case illustrates how the presence of Chinese companies can supply surveillance tools when local demand calls for it, but their implementation is ultimately constrained by local conditionalities.

South Africa

The widespread use of digital technologies was also a critical feature in addressing the COVID-19 crisis in South Africa. Most prominent digital strategies included applications dedicated to contact tracing via Bluetooth technologies and CCTV networks. Accordingly, discussions about the potential abuse of digital technology have also been particularly salient given the personalised nature of data being processed and captured. Furthermore, South Africa has received telecommunications financing and infrastructure from China in recent years and is one of the top destinations for Chinese ICT companies in Africa.¹⁰⁷ Huawei and ZTE have established their regional head-quarters and logistics centre in the country,¹⁰⁸ and Huawei has partnered with local companies such as South Africa's MTN, Africa's largest mobile operator, to expand the country's network infrastructure in the face of growing local demand.¹⁰⁹ Thus, the digital infrastructure provided by Chinese companies was part of South Africa's pandemic response; however, as in the case of Brazil, it was not directly run by Chinese operators.

When the first cases of COVID-19 were registered in South Africa, President Cyril Ramaphosa swiftly declared a national state of disaster on March 2020, invoking section 27(1)(b) of the Disaster Management Act 57 of 2002 (DMA) and declaring contact tracing as a necessary strategy to combat the pandemic.¹¹⁰ The government then passed a series of regulations in the Government Gazette that allowed the identification of infection hotspots using collected data and epidemiological maps,¹¹¹ wherein the use of smartphone apps for automated contact tracing was considered one of the most promising advances in the fight against COVID-19, as smartphones are ubiquitous in South Africa.¹¹² To this end, the South African government introduced two mobile voluntary applications and one WhatsApp-based symptom reporting process designed to assist health officials in tracking down exposures after infected individuals have been identified.¹¹³ These strategies were developed by government agencies in partnership with the local private sector; nevertheless, they used digital infrastructure deployed by Chinese companies in the country, especially mobile networks.

The first application (COVID Alert SA) was launched in September 2020 and uses a phone's Bluetooth signal to share a unique code, which is sent to other users of the application within a two-meter radius.¹¹⁴ The app was developed by the local company Discovery Limited in partnership with South Africa's National Department of Health. People who have tested positive for COVID-19 within two weeks can anonymously alert others by clicking the notification button on the application. However, the person with COVID-19 has the decision on whether to voluntarily share their status. The purpose of the application is to notify users who have been in contact with someone who has tested positive for COVID-19. Accordingly, it encourages people to isolate and test for COVID-19 as a measure to further prevent infections. The COVID Alert SA application is predicated on smartphone technology which was developed by Apple and Google, specifically the GAEN API.¹¹⁵

To deal with privacy risks, including the potential for temporary rights-infringing measures to become permanent features, the COVID Alert application does not record any personal or health information. More exactly, individual phones exchange anonymised digital identities to mark such interactions.¹¹⁶ Data is stored on individual devices and users can opt out anytime. The unique codes cannot be used to identify a phone number or identity; therefore, data cannot be traced back by technical means to persons, locations or devices. The unique Bluetooth identifier codes change every ten to twenty minutes, to help prevent tracking. This mechanism provides the user with full authority and control over who gets access to the data, which has been coined as ‘Self-Sovereign Identity’.¹¹⁷

The second application (Covi-ID) was developed in a partnership between government agencies and the University of Cape Town.¹¹⁸ The application uses a similar technology of COVID Alerta SA, collecting an infected subject's geolocation and sharing it through Bluetooth anonymised tokens when authorised.¹¹⁹ Similarly, the personal information is saved on the data subject's personal device and not on a centralised government database.¹²⁰ The application also allows users to present QR codes and for verifiers to scan these QR codes to retrieve the user's COVID-19 health status – a tool closely resembling China's Alipay Health Code. The Covi-ID app makes use of a GDPR based privacy policy and is said to comply with the Protection of Personal Information Act 4 of 2013 (POPIA), South Africa's benchmark for data protection, which came into force in July 2020.¹²¹ Nevertheless, the app registered a remarkably small number of downloads as it was not rolled out extensively by the government.¹²²

Finally, the WhatsApp symptom tracker (COVIDConnect) was developed by diverse South African public and private actors, including Telkom, Praekelt, GovChat, and the Council for Scientific and Industrial Research. It was launched nationwide in May 2020 by South Africa's Department of Health.¹²³ The platform uses machine learning technology to deliver automated responses with information on COVID-19 including symptoms recommendations, travel advice, and the latest country data. The platform was hailed as an effective strategy to diffuse reliable information on the pandemic; however, it is unclear who has been processing the information submitted and where else it may be disclosed since there are no terms and conditions available regarding the use of this functionality. After having been successful in South Africa reaching over 2.6 million users, a similar platform was adopted by the World Health Organisation (WHO) inspired by the South African strategy.¹²⁴

Before the introduction of these three tools, the South African government utilised a tracing database, which collected both aggregated and individualised mobility and locational data on COVID-19 cases and their contacts from telecommunications service providers.¹²⁵ The database was licensed under the Electronic Communications Act 36 of 2005 and recorded, under the written request of the Director-General of Health, the names, identities, and cellphone numbers of people who tested for COVID-19.¹²⁶ Although there were compelling public health reasons for this development, it allegedly infringed on constitutional privacy rights and the POPIA as South Africans were vulnerable to non-consensual processing of their personal information.¹²⁷ Against this background, the South African Government implemented a set of track-and-trace regulations, in terms of section 27(2) of the DMA.¹²⁸ The regulations set out the standards for processing personal information used in the management and containment of the spread of COVID-19. They allow the obtaining of information by the government in relation to location data of any person from electronic communications service providers while establishing legal constraints. In doing so, the government gave effect to the constitutional right to privacy and to prevention mechanisms of the POPIA that had yet to come into effect.¹²⁹

Even with the privacy-preserving protocols taken by the government, data collection processes and security were seen to lack transparency. The South African government contended that to protect data against unauthorised access and usage, its tools make use of a variety of technical security measures, which includes encryption, pseudonymisation, logging access controls and restrictions.¹³⁰ For instance, the South African National Department of Health and its partners such as Discovery Limited and Telkom supposedly employ confidentiality agreements to combat data leakages. However, how exactly this data is being transmitted and managed by contractors remains unclear. Moreover, despite these procedures, there was a spike in cyberattacks during the COVID-19 pandemic against government agencies, which increased the public's awareness of data breaches.¹³¹

Finally, South Africa's response to COVID also included the use of digital CCTV networks. These closed-circuit surveillance tools were periodically utilised by the police during countrywide lockdowns that included bans on gatherings, a curfew from 9pm to 4am and prohibition on the sale of alcohol.¹³² This was a containment strategy that aimed at limiting social interaction while supposedly preserving the economy. Technology procured from Chinese companies provided the infrastructure that underpins this digital surveillance practice, which is, in part, linked with Huawei's Safe Cities projects in the country.¹³³ These initiatives utilise a plethora of interconnected systems like video cameras, tracking devices, software, and cloud storage systems to tap public and private platforms in a more cohesive manner to advance service delivery and policing.¹³⁴ Besides Huawei, Vumacam, a local company, is also a leading provider of networked surveillance cameras.¹³⁵ For example, Johannesburg's central business district is contingent on digital CCTV cameras procured from Huawei and Vumacam, but also from Axiom, a South African digital surveillance camera provider, Iveda, an American supplier, and Hikvision, a Chinese state-owned supplier.¹³⁶ The City's extensive camera surveillance system is located within the Integrated Intelligence Operations Center and these various cameras are owned by the police, local municipalities, and private security companies.¹³⁷ By purchasing governance and monitoring tools through various commercial channels, South African state and private actors are able to establish a hybridised surveillance system that is part of a broader digital infrastructure initiative.¹³⁸

South Africa illustrates, like Brazil, that Chinese companies have been key in providing the digital infrastructure needed for the contact tracing strategies implemented throughout the pandemic, even though they were operated and designed by partnerships between local public and private actors. Moreover, South Africa's smart cities show how often these infrastructure networks, which rely on Western and Chinese corporations, highlight host nations’ aptitude to patch together diversely sourced technology.

Vietnam

Vietnam has been commended for having a successful response to the COVID-19 pandemic, particularly prior to the arrival of the Delta variant.¹³⁹ Building on institutional capacity and prior experiences with SARS, the government prioritised contact tracing and targeted quarantines while using data surveillance and mobile application infrastructure to manage the pandemic. Similar to China's response, Vietnam's response also relied on local government coordination and surveillance technology building on infrastructure developed with domestic Vietnamese technology companies. However, Vietnam's experience is noteworthy for its distinction from the other two case studies: that despite Vietnam officially rejecting economic entanglement with Chinese technology firms, it has also increased its domestic digital surveillance both before and during the COVID-19 pandemic through active exposure to Chinese models of surveillance, including technical training from Chinese authorities and companies.¹⁴⁰ Thus, Vietnam's experience illustrates that the practices of the Chinese government, even if not directly adopted into a country through partnerships with Chinese technology companies, may cause a diffuse effect in providing replicable strategies favourable to authoritarian governments. It can offer, for instance, a cover that normalises the adoption of more authoritarian surveillance practices, such as those that Vietnam seeks to pursue with its own companies as a model of both economic development and political control.¹⁴¹

Building on its prior experience with other contagious diseases, such as the SARS pandemic, Vietnam has over time prepared and invested in a series of measures for public health emergencies, including its national public health surveillance system.¹⁴² In 2009, Vietnam first employed a nearly real-time and web-based system to collect and aggregate public data and, since 2016, hospitals have been required to report notifiable diseases within 24 hours to a centralised database.¹⁴³ Vietnam has also looked to Western support to develop pandemic responsiveness and even surveillance strategies, in particular for illnesses that may spread across its borders. In 2018, in collaboration with the US Centers for Disease Control and Prevention (CDC), Vietnam implemented an ‘event-based’ surveillance program.¹⁴⁴ The program is designed to enable members of the public, including teachers, pharmacists, religious leaders, and even traditional medicine healers, to report public health events. All these strategies were part of the country's COVID-19 pandemic response and are part of the country's national strategy to implement a smart healthcare industry that encompasses disease prevention, medical examinations, and health management through a digital health ecosystem.¹⁴⁵

When COVID-19 arrived in Vietnam, surveillance and contact tracing were central to the country's strategy. After the first cases were registered, Prime Minister Nguyễn Xuân Phúc established a ministerial task force to design and implement a national response that was set to include the use of digital infrastructure.¹⁴⁶ The head of Vietnam's official Steering Committee for COVID-19 Prevention and Control tasked the Ministry of Health (MOH) and the Ministry of Information and Communications to create surveillance, contact tracing and information dissemination applications within a week of the first COVID-19 cases in Vietnam.¹⁴⁷ To monitor citizens’ movement, Vietnam then mobilised digital health applications, building on its robust information and technology sector and high mobile penetration.¹⁴⁸

Vietnam's contact tracing was comprehensive, as three degrees of contacts were traced for each positive case. To effectively track each case, local public health officials, with support from the military and civil servants, worked with patients to identify who they might have been in contact with in the past 14 days. If any individual tested positive, they were placed in government-run quarantine centres put in place to reduce household and community transmission. Similar to China, Vietnam was noted to have benefitted from its centralised authoritarian political structure, although many levels of government support and buy-in were necessary to facilitate the response, including at the local level.¹⁴⁹

Vietnam's surveillance efforts also relied on three smartphone apps, which have been voluntary to download: (i) NCOVI, an official state platform for state agencies to distribute rapid updates and public health recommendations; (ii) SmartCity, an application that infected and quarantined people must also download and which notifies the heads of households if a person travels 30 metres from their quarantine area; and (iii) Bluezone, another application launched by the MOH which leverages Bluetooth Low Energy to alert users if they were in close contact with someone who tested positive for COVID-19.¹⁵⁰ The Vietnam government also developed a community monitoring system using GPS technology in Hanoi through the city's Smart City project.¹⁵¹ Later, the government launched a unified mobile app for COVID-19 prevention, the PC-Covid Vietnam app, which combined existing features of the applications into one travel and social pass – a similar strategy to China's pandemic management.¹⁵² Developed by Viettel Group, Vietnam's COVID-19 immunisation management platform was launched in October 2021 to aid the government's mass vaccination drive and comprised four systems including an e-health record app, a COVID-19 vaccination information portal, a national vaccination support system and a response centre, while also handling registrations for COVID-19 immunisation and tracking vaccination records.

Although Vietnam initially may seem a natural match for Chinese companies given existing close economic ties with China as well as ideological and political sympathies, it is notable that the country has sought to distance its pandemic response from Chinese digital infrastructure due to Vietnam's scepticism of Chinese technology dominance. In recent years, Vietnam has shied away from embracing Chinese companies due to geopolitical concerns,¹⁵³ including intentionally rejecting Chinese 5 G technology – a distinct move compared to other countries in Southeast Asia that are openly deploying such technology through Huawei.¹⁵⁴ The country has instead mimicked China and South Korea's development approach by endorsing home-grown companies for economic development. Viettel Group, Vietnam's largest mobile carrier state-owned by the Defense Ministry, announced their own successful 5 G development while already using Ericsson's and Nokia's technology for its 4 G network.¹⁵⁵ Other smaller carriers, such as MobiFone Corp and Vinaphone, have followed the same path rejecting Chinese companies’ hardware as well.¹⁵⁶

Shying away from Chinese companies, Vietnam has also invested in artificial intelligence and facial recognition applications developed by its domestic industry.¹⁵⁷ Nevertheless, it is important to note that its general surveillance system has increased over the years, with similarities and training received from the Chinese regime, as well as some technological infrastructure to support this expansion.¹⁵⁸ For instance, companies such as Hikvision and Dahua still have a strong foothold in Vietnam as the country registers more than 822,000 camera networks from these companies combined – both companies’ largest market in the world.¹⁵⁹

Against this background, Vietnam's surveillance and quarantine approaches both in handling the COVID-19 pandemic and in creating state surveillance outside of the pandemic have been similar to China's, involving the mobilisation of mobile technology penetration, surveillance applications, local actors’ coordination, and targeted quarantines. However, Vietnam serves as an interesting case study in which Chinese influence may have informed its general surveillance approach, while the specific use of Chinese technology has been rejected. Simultaneously, Vietnam adapted its own surveillance program, which was strongly aided by the centralisation of its authoritarian government structure and built on its prior experiences with the SARS and Middle East respiratory syndrome pandemics, in collaboration with foreign actors such as the US CDC. Therefore, Vietnam is notable as an authoritarian regime that has successfully embraced digital surveillance as a pandemic response, despite simultaneously rejecting the direct use of Chinese technology and companies.

Reflections on Chinese Influence in Pandemic-Related Digital Surveillance Trends

While a sample of three countries is a small one, it is nevertheless representative of certain trends on how Chinese digital infrastructure has been deployed and adapted in foreign jurisdictions during the pandemic. The use of digital surveillance technology in managing the pandemic also provides insight as to how scholars and observers might reconceptualise issues related to the global spread of surveillance practices and, more specifically, to China's influence in domestic technology governance abroad. Our focus on Chinese technology does not suggest China's exceptional nature in the distribution of surveillance goods or seeks to obscure the broader transnational market of digital surveillance tools, which includes several other international actors. However, our narrow approach may be warranted if it elucidates China's opaque role in the development of global ICT markets and in the general spread of digital surveillance practices.

In this regard, data from our case studies show no evidence to support the claims that the Chinese government and its companies have exploited the pandemic to export digital repression to other jurisdictions, at least when export suggests a deliberate aim to promote surveillance practices. Evidence like this seems unlikely to arise, as proof of such claims would appear to rely on internal accounts whistle-blowing the situation or policy statements focused on such goals, which have not surfaced in relation to China's digital strategy during the pandemic.¹⁶⁰ This conclusion also seems to overshadow the fact that China's own pandemic-related surveillance resulted from a particular environment that is not easily replicated by partner countries.

There may be a better argument, nevertheless, under a weaker interpretation of export, wherein the claim is that Chinese surveillance technology alone is leading to different governance outcomes than those originating from liberal democracies. As seen in our study, the pandemic highlighted that surveillance models are spreading across the world, made possible, to some extent, by the technical support offered by Chinese companies or the influence of the Chinese government as a role model. However, the meeting point between Chinese surveillance technology and host nations’ demand has not had the same characteristics as what it looks like in China, as local stakeholders also dictate outcomes of the development of ICT infrastructure and surveillance practices.

Thus, having in mind that Chinese technology and governance models have either supported or influenced our country sample's pandemic management strategies, our examination of the evidence shows different fashions in which host countries are adapting Chinese technology for their own needs. Precisely, we observe three general trends of Chinese influence proliferating diffusely in our sample of countries: (i) Chinese technology supported or influenced the management of the pandemic; however, each country designed and operationalised its response framed on its own technical and institutional capacities; (ii) the use of Chinese technology or governance models within each country's pandemic response blended with those from domestic or non-Chinese foreign companies; and (iii) countries acquired implementation capacity to develop surveillance strategies through technical exchanges with Chinese actors (ie, companies and government agencies) without necessarily adhering to Chinese technology.

First, we observe that the export of Chinese technology is increasingly providing governments with digital infrastructure that may be used for surveillance purposes, even though countries have not necessarily emulated China's surveillance approach. For instance, our Brazil and South Africa case studies show countries where massive data collection has happened through varied data streams, such as telecommunications networks, which despite being extensively deployed by Chinese companies in both countries, are not usually associated with China's surveillance toolkit. Additionally, the extent to which governments employed such digital infrastructure for surveillance goals seems to have been ostensibly constrained by local contingencies such as legal safeguards and technical capacity. This is particularly the case of Brazil, which experienced a demand increase for facial recognition software throughout the pandemic – enabled in part by Chinese offer and promotion of its surveillance solutions. However, the deployment of such technology has been limited by discussions of its legality under the country's data privacy regime, which is heavily inspired by the EU's GDPR. Thus, we observe that China's supply-side might have influenced data governance abroad during the pandemic by making new digital infrastructure available to a part of our case studies.¹⁶¹ Yet any supply-side influence seems to have been eventually modulated by demand-side constraints. In other words, Chinese companies have engaged on the terms available in local contexts, which have resulted in contextually contingent outcomes.

Second, we must pay attention to the fact that China has not been the only country contributing to the expansion of global digital surveillance during the pandemic. All three case studies presented herein highlight how local and non-Chinese foreign companies also played a role developing and deploying digital surveillance strategies. The widespread use of digital surveillance does not provide a basis on which China's influence during the pandemic can be meaningfully disentangled from that of other countries.¹⁶² Even though Chinese companies have a comparatively larger share of the surveillance technology global market,¹⁶³ the pandemic shows that companies from elsewhere in the world seem inclined to step in to offer similar solutions to domestic challenges. In addition, the origin of surveillance technology employed by the observed countries does not seem to have led to a specific approach linked to China's digital governance models. This observation does not neglect Chinese influence via other avenues, such as previously mentioned global internet governance and technical standardisation activities,¹⁶⁴ but it can add to the debate on whether the source of surveillance technology is a determinant factor in data governance design.

Third, our case studies also suggest that inversely, countries might opt to reject Chinese technology while copying China's surveillance approach and acquiring implementation capacity through the provision of technical assistance and capacity building by Chinese actors. Vietnam, which has officially rejected Chinese technology, seems to have been influenced by Chinese approaches of social control, and may also be copying Chinese models of surveillance to both preserve its political power and facilitate economic development through the endorsement of home-grown technology companies. This contradictory finding underscores how the interests of the host country clearly direct the relationship with China and suggests that local factors affect the uptake of Chinese influence. Therefore, the surveillance practices of the Chinese government and companies, even if not directly adopted into a country through economic importation of Chinese technology, may generate a diffuse effect in providing replicable strategies favourable to authoritarian governments and a precedent that normalises the adoption of surveillance practices – especially if seen as a successful model for both economic development and political control.

The fact that Vietnam is deploying its own surveillance strategy also confirms how the picture of why digital repression is advancing globally is more complex than is often portrayed. In this sense, we observe that surveillance can build on more hostile local environments not necessarily linked to China's influence; a notable example being Brazil. In recent years, the country has experienced an alarming rise in digital repression indicators¹⁶⁵ against the backdrop of rising political persecution by the Bolsonaro government and its supporters. This is highlighted as the government itself has pushed forward surveillance programs to monitor the activities of opposing public servants and journalists.¹⁶⁶ The troubled scenario is markedly a consequence of domestically contingent vectors, even though Brazil has been associated with narratives that link growing digital repression to Chinese companies’ local surveillance footprint.¹⁶⁷

As stated before, this paper aims to add a level of complexity to the narrative of China's ambition to export a normative model of digital surveillance and governance. Ultimately, we do not argue that Chinese surveillance technology exports are exempt from having adverse influence on other countries as certain kinds of technologies can encourage the adoption of authoritarian practices. As argued by Duncan, digital surveillance tools, like facial recognition technologies, are not simply neutral instruments of governance.¹⁶⁸ Rather, they are political tools that are embedded in a given society and may have negative consequences for the public. These technologies have the capacity to exacerbate established problems at the intersections of inequality, race, gender, and policing. Nevertheless, it is clear that their supply factors must be evaluated alongside demand side conditionalities, in particular legal and political structures. In our case studies, Chinese technology and capital have not been the fundamental drivers of growing digital surveillance during the pandemic, but they can be seen as another factor that supports and exacerbates existing trends such as rising authoritarianism.

In this regard, while host nations’ legislation may offer a set of broad principles and commitments, there are still significant gaps in how emerging technologies are regulated in the world. It is this gap between Chinese technology supply and regulatory vacuums that seems to augur the atrophy of democratic norms and civil liberties. In South Africa, for instance, there is no mention of a CCTV code of practice in any legislation, including the POPI Act. Accordingly, there are no robust checks and balances as to how facial recognition software or biometric databases should be managed in Brazil or Vietnam. Thus, regulation of digital surveillance technologies is missing potentially as a mediating factor in Brazil, South Africa, Vietnam and beyond.¹⁶⁹

Finally, we should also be attentive to how other international actors will react to the growing involvement of Chinese surveillance companies in foreign markets. Most recently, the Biden administration launched an initiative at the Summit for Democracy to curb the exports of technology with surveillance capabilities to countries with poor human rights records.¹⁷⁰ The ‘Export Controls and Human Rights Initiative’ was signed by the US, Canada, France, the Netherlands, and the United Kingdom, and is set to stem the tide of authoritarian government misuse of technology by establishing a nonbinding written code of conduct on the use of surveillance technology. It is still unclear what role and impact this initiative will have on the exports of these countries and China's companies, especially to developing nations. Companies like Huawei have already stated that they would take effective measures to prevent abuse from using their technology – although their claims remain unclear in practice.¹⁷¹

Conclusion

While the expansion of digital surveillance and discussion about its implications pre-dates the pandemic, COVID-19 exacerbated a global trend towards spreading digital surveillance practices. Commentators who saw China as an exporter not just of surveillance technology, but also of the governance of that technology, advanced a theory that China would use the pandemic to spread its technology governance model. To test these claims, this paper has sought to shed light on how national governments deployed digital technologies to curb the COVID-19 virus and whether, if at all, Chinese technologies and companies played a role in domestic management policies and governance.

Through our case studies, we have observed that selected countries were able to implement large-scale surveillance systems due to Chinese and non-Chinese technology already deployed in each country – and did so on their own terms and contingencies. Thus, expansive use of digital surveillance in managing the pandemic appears to have neither been a direct consequence of Chinese technology exports nor its surveillance approaches. Rather, factors such as state capacity to conduct digital surveillance, itself dependent on the existence of digital networks and technical knowledge, as well as political will to use data and make governance changes better explain how countries ultimately used digital surveillance as part of their pandemic response. Similarly, the existence of safeguards intended to balance the need to manage the pandemic and the use of digital surveillance against privacy rights of a state's population appear primarily to have been dependent on the pre-pandemic state of digital governance rather than susceptibility to Chinese influence. Accordingly, a deeper look at the use of digital surveillance in managing the pandemic suggests that the theory of China exporting digital repression, even in some indirect sense, likely oversimplifies reality.

China's intentional desire to export its normative values abroad and its engagement in foreign infrastructure certainly points to supply factors, which foster conditions for the misuse of devices, particularly in political and legal environments that have weak checks and balances. Although individual countries procuring Chinese technology have their own interests, China's active push to support the distribution of surveillance tools also shapes outcomes. Drawing attention to how the party-state leverages demand factors for its own state interests does not necessarily imply downplaying host nations’ volition and their ability to detect outcomes; rather, it points to how studies must establish more proportional accounts that are able to examine both the local and global features that determine outcomes.

Most studies highlight the supply factors that motivate the proliferation of Chinese digital surveillance technologies, paying meagre attention to the local factors that determine its use. This paper focuses our attention on the often-neglected minutiae of Chinese operations in local contexts so as to expand our understanding of how China's growing geopolitical footprint is mediated by domestic conditions and actors. This dialectic posture shows how local and global factors are interconnected, deriving illumination and clarity from one another. Crucially, this layered approach hopes to forestall the potential long-term impact of Beijing's growing cyber power on the global stage.