Facebook, Google, Instagram, and other social media giants are based in the United States, where they have faced relatively little Government oversight. But their reach extends around the world, influencing a wide spectrum of audiences in a variety of ways.
A Northeastern University survey of four diverse democracies found that people in other countries differ from Americans when it comes to opinions as to how social media companies should be regulated.
Respondents in the United Kingdom, South Korea, and Mexico favoured stricter content moderation than people in the US—especially in cases that cause harm or distress. All four democracies are suffering from political divisions that have been fed by social media misinformation.
Though the US lags far behind the European Union in terms of regulating Facebook and other tech behemoths, the need for social media governance has emerged as a rare issue of agreement for both Republicans and Democrats.
The European Union paper on “Illegal and harmful content on the Internet” probably best sums up the fears of governments about the Internet:
- national security (instructions on bomb-making, illegal drug production, terrorist activities);
- Protection of minors (abusive forms of marketing, violence, pornography);
- Protection of human dignity (incitement to racial hatred or racial discrimination);
- Economic security (fraud, instructions on pirating credit cards);
- information security (malicious hacking);
- Protection of privacy (unauthorised communication of personal data, electronic harassment);
- protection of reputation (libel, unlawful comparative advertising); intellectual property (unauthorised distribution of copyrighted works, software or music)
South Korea is probably the first country to have any Internet-specific censorship law. In 1995, it passed the Electronic Communication Business Law, which established the Information & Communication Ethics Office. The Office has broad powers to censor: its scope of coverage encompasses material on bulletinboard services, chat rooms, and other “public domain services” that “encroaches on public morals,” “may cause a loss of national sovereignty,” and “information that may harm youths’ character, emotions and the sense of value.
France has attempted to regulate the Internet through mechanism established for policing the Minitel. It has proposed using inspectors of its famous Minitel to prowl the Minitel system inspecting content to ensure that information providers comply with the terms of their contract with France Télécom.
Germany’s NetzDG law came into effect at the beginning of 2018, applying to companies with more than two million registered users in the country. They were forced to set up procedures to review complaints about content they were hosting, remove anything that was clearly illegal within 24 hours and publish updates every six months about how they were doing.
Australia passed the Sharing of Abhorrent Violent Material Act in 2019, introducing criminal penalties for social media companies, possible jail sentences for tech executives for up to three years and financial penalties worth up to 10 per cent of the company’s global turnover.
Canada’s federal regulator says it may regulate content on the Internet to provide for more Canadian content. This is similar to the French idea of having more Franco space.
Singapore, which has a reputation for censorship, has made headlines for its recent attempt to regulate the Internet. Like most countries, Singapore had to amend its laws to capture the Internet.
In the United States, social media platforms have largely been left to make and enforce their own policies, though Washington is weighing new laws and regulations.
Other countries have implemented or proposed legislation to force social media companies to do more to police online discourse. Authoritarian governments generally have more restrictive censorship regimes, but even some Western democracies, such as Australia and Germany, have taken tougher approaches to online speech.
