INSIGHTS | Can Europe copy China’s health code?

Decentralized or centralized? Bluetooth or geolocation? Control quarantines or alert people to infection risk? Store data for one month or six? There are many questions that need answers to build an app-based system to manage the Covid-19 pandemic and lift lockdowns. Much like how the implementation of health code systems wildly varies between Chinese provinces and cities, European countries are coming up with wildly different solutions. 

The differences between Europe’s path to technology for epidemic control and how China did it offer a glimpse into the future. In an era where China is increasingly exporting its innovations around the world, observing how other regions are taking to them is an ever-pressing issue for China tech. A rich debate between governments, companies and private citizens is taking place in Europe, one that China didn’t get. It is a debate that is slowing down the process, but it will determine what and how gets implemented—and how China’s techniques will be judged. 

On the continent, any hint that Europe is taking up China-style surveillance comes at a political cost. Officials are claiming to be examining the South Korean and Singaporean models. But after years of bashing China’s privacy policies and the whole world looking at China during Covid-19, it is hard to dissociate China’s model of epidemic control from what European leaders are doing. So, the continent’s public health challenge has become intensely political. What began a choice between epidemic control and individual liberty is understood by many as our way versus the China way. 

We have identified 39 different epidemic control apps mentioned in news reports in several European languages, and 7 different mobile data tracking programs across European states. With many still in development and not public, it is likely that there are tens, if not hundreds. With governments, the private sector and non-profits jumping in, it is a messy process.

The Netherlands government sent seven apps to the national data protection regulator. The regulator rejected them, saying it was not able to “properly assess” (in Dutch) them. 

Mainstream approaches range from bluetooth-based contact tracing to GPS tracking. Outliers include such novelties as sharing selfies with the police and asking users to report every time they wash their hands (in German). 

Bottom line: Europe’s efforts at digital epidemic control are—characteristically—messy, diverse, and numerous. Suspicion of privacy issues, tech, and China all make it harder to roll out. It’s too soon to say what the results of this messy process will be. Europe’s health code struggle shows how China’s digital innovations travel overseas, how they are received, and changed upon landing ashore. 

A pan-European approach? In a major twist of irony, the European Union’s data privacy regulator has called for a pan-European Covid-19 tracking app. The polyphony of apps could create catastrophic splintering. The Schengen area and the EU operate on free movement of people. If your Austrian app doesn’t work in Germany, that’s no good for the epidemic or the economy. 

Answering this call, a team of 130 engineers and researchers, backed by a German company, launched the Pan-European Privacy-Preserving Proximity Tracing initiative (PEPP-PT), a Bluetooth-based protocol that participating teams can use to build apps for their own countries. The organizers claim to have the participation of Austria, Germany, France, Italy, Malta, Spain, and Switzerland, but there have been no official statements to confirm this from any of those states. Switzerland’s top research institution is the leader of the competing decentralized protocol and Austria declared it is working with it. 

The team was organized in a hurry and, in fact, doesn’t yet exist as a legal entity. Two weeks after it was launched, it faced criticism for backing off a promise to support a decentralized protocol. An EU Parliament resolution from April 15 “demands that all storage of data be decentralised.” After the letter, several researchers from high-profile universities pulled out to back a rival Decentralized Privacy-Preserving Proximity Tracing (DP-3T). Switzerland, Estonia, and Austria’s apps are developed on the DP-3T protocol. 

The players: Unlike China, Europe doesn’t have a central authority able to designate a few official solutions. Lots of actors are putting forward their own plans. Governments, the EU, nonprofits, and the private sector have all jumped into the game. 

• National governments are scrambling to protect their populations, facing a diverse set of challenges and epidemic intensities. Many have designated national universities and research institutes to build official apps.
• The EU is not only worried about protecting its people, but also European unity and the institutions that implement it. This is the first time in the EU’s history that national borders have been closed, a monumental act of nationalism that threatens to undermine the European project. 
• The PEPP-PT initiative plans to incorporate as an NGO in Switzerland. How the DP-3T will be incorporated is undetermined.
• The NGO sector is mainly taking on the role of watchdog, warning (in French) of human rights violations caused by technological methods of epidemic control. In Austria, the Red Cross developed its own app. 
• Private sector startups, tech companies, and researchers are building their own apps or working with governments. Apple and Google are collaborating on a Bluetooth handshake app that France has endorsed. 
• Surveillance companies with questionable privacy track records like US Palantir, Israeli NSO group and Italian Cy4gate are trying to convince governments that they are the ones that can solve the conundrum. 
• But the people of Europe, with their many cultures and political beliefs, are the key to successful epidemic control. 

The people decide: It may not be governments who decide which app prevails, and they certainly cannot make any effective alone. The figure making the rounds in European media is 60%: That’s how many people need to voluntarily download the app to make it useful. As EU Commission guidelines published last week say, what needs to be accomplished is a “common approach for voluntary and privacy-compliant tracing apps.” Politicians and researchers have argued that if apps overstep in data collection, people will be distrustful of the government, and app adoption will be low.  After all, the European Union’s data protection regulation requires explicit consent prior to data collection. 

The models: There are four main models touted or already in action, and plenty more in development. Governments could choose to adopt combinations of tools to manage different aspects of epidemic control. 

• For contact tracing, a popular model uses Bluetooth handshakes to determine when people are close to each other. Such apps are only alerted to the physical proximity of people, and the virus can easily spread through objects. If someone who tested positive coughed all over the supermarket aisle five minutes before you showed up, the app wouldn’t alert you to the risk of infection. The pan-European initiatives, Germany, Apple and Google and many more are using this approach. 
• Iceland, Norway, and the Czech Republic are using GPS for contact tracing. Norway’s app will combine it with Bluetooth data. 
• In France, Germany, Austria, Belgium, Italy, and the UK, telcos have or will turn over anonymized mobile phone data to authorities to help them map and predict the outbreak.  Slovakia, Bulgaria, Croatia, and Serbia are tracking mobile phone data to enforce quarantines. 
• Greece is using a text message system to monitor when people are leaving their homes whilst the lockdown is ongoing. People text a government number information about where they are going and information about their outing. 
• The EU is also touting immunity passports, so that those who have antibodies against the virus can move around freely (and go on holidays). To do this, they need to rapidly scale up the production of testing kits.  
• Poland is asking people in quarantine to send selfies to the police at irregular intervals to confirm their location. 
• The Czech Republic’s app combines location data with credit card payments. 
• Even some lone screwballs are getting traction. A German researcher built an app that asks people to record when they wash their hands. The app then builds a risk assessment of areas. 

Privacy: As much as privacy considerations are a concern for civil society, it is not the number one priority for European governments. But in order to convince people to use the apps, there need to be certain data protection guarantees. With the pandemic ravaging through the continent, and several members going their own way, privacy is a priority only so long as its needed for an efficient response.

• European Data Protection Supervisor promised that the measures will be temporary, that they will know “a way back to normalcy.” The privacy watchdog also said that the pan-European app will be strictly limited in its data collection. 
• The General Data Protection Regulation, as it is enshrined in most European countries’ laws allows for exceptions in times of emergency. Governments have jumped at this clause, despite opposition from NGOs and opposition parties. Italy passed a law to change personal data handling standards on Feb. 3. Mobile phone data was given to governments, and the EU, with little public discussion. The German and Austrian operators gifted anonymized mobile phone data to their respective governments. 
• Governments have been rushing to pass emergency laws that would allow for greater data collection powers. In Slovakia, they did it. In Germany, the government’s proposal to allow individual smartphone tracking without judicial review was blocked by the opposition. Moldova, Latvia and Romania evoked the right to derogate human rights. The Norwegian government exempted itself from parliamentary debate. 

China anxiety: Association with China’s privacy attitudes is a liability for a proposal in much of present-day Europe. Both publics and elites are suspicious. “Belgium is not China,” a privacy activist wrote on a grass-roots news site.  In one of Germany’s top newspapers, a German-Korean philosopher said that Europe’s illusion of liberalism is headed to an end: “We have been China for a long time—only we don’t want to admit it.”

• For years European politicians and press have condemned Chinese surveillance. It is hard to go back from this attitude. As governments are trying to come up with solutions that take a page from China’s book, the media are hammering on about privacy concerns in China’s apps. 
• To steer clear of the China association, many are focusing their talk on the South Korean and Singaporean models. They are no less invasive. South Korea’s app not only tracks people’s location, but publicly posts infected people’s whereabouts. 
• The EU’s top diplomat Joseph Borell wrote a blog post warning of a “struggle for influence” in a “global battle of narratives,” in which China is “aggressively pushing” the “message that it is a responsible and reliable partner.” 
• Soon after this post, Huawei, once again in the eye of the storm, decided to stop its donations to several European countries for fear of being dragged into geopolitical bickering. 
• On EU news outlets, Jack Ma’s donations are treated as suspicious “mask diplomacy.”
•  A report published on April 1 by an anti-disinformation EU-affiliate warned that Chinese state media are promoting the idea that the “Chinese model is superior in tackling COVID-19, while highlighting global expressions of gratitude for Chinese aid delivery.” 
• But China associations are a plus, or at least neutral, for some eastern European countries. The Hungarian and Serbian governments have not released any digital means of controlling the outbreak. However, they have accepted donations of personal protective equipment from the Chinese government. 

European essence, Chinese methods? A hundred years ago, Chinese reformers associated with the Self-Strengthing Movement argued about whether they could combine “Chinese essence with Western methods” (Zhongti xiyong). It’s not easy to adapt foreign tools to domestic values—as they learned, there’s a lot of values baked into technology.

Now, Westerners have to confront the same thing in reverse. Health code is a dramatic example, but as China pioneers more and more technology, Europe will often be in the copycat role. It could be a good time to brush up on your Kang Youwei.