Data privacy in China and Europe: individual, collective, subjective, and objective perspectives

This article presents a comparative analysis of personal data governance in the EU and China, using the ‘four quadrants’ framework of Weber’s Integral Theory. Both jurisdictions seek to protect the individual’s right to control personal information. When it comes to the collective aspects of personal information, however, China’s Social Credit System gives the pursual of social objectives a degree of priority over individual rights unacceptable within EU contexts. The value of large-scale, pseudonymized data sets for research and policy-making is recognized in both the EU and China. Facilitating access to valuable data sets while also protecting individual privacy rights remains a key challenge. Similarities can also be found in each jurisdiction’s desire to maintain system integrity and secure digital ecosystems, albeit with different levels of sensitivity surrounding sovereignty and security concerns. The article concludes by proposing a system of international data trusts as a useful tool for facilitating collaborative data sharing and mutual confidence.