Experts say it’s unlikely, but not impossible, that America could replicate the tech-driven approach taken by China, which has taken full advantage of its vast surveillance apparatus and the murky integration of “big data” to monitor, diagnose and limit the movement of its citizens.

It’s not that America doesn’t have its own surveillance tools to play with, but more to do with basic differences between the two countries, experts said. As one digital human rights researcher told Newsweek: “China isn’t just a surveillance state—it’s a model for digital authoritarianism.”

Around the world, many efforts to utilize technology to identify or contain COVID-19 have proven innovative, such as the drive-thru test stations in South Korea and the robotic healthcare assistant in Washington state. Others, including by China, have been a little more dystopian.

The most recent example that turned heads was Alipay Health Code—an app built by a sister company of tech giant Alibaba that assigns citizens a color code to automatically decide if they are free to move around a city, or face quarantine. It was analyzed by The New York Times, which reported it appeared to share user information with the police.

In another recent case, a mobile application was being pushed out to citizens that reportedly contained a “close contact detector” showing a map of COVID-19 infections.

The Global Times reported this week that authorities in Chengdu city, Sichuan Province, had started wearing “smart helmets” which had the ability to measure the temperatures of passengers-by when they enter a five-meter range. An alarm would ring out if a fever was detected.

In each case, it was not immediately clear what data was being used to fuel the app software and devices, but it appeared to at least include social media, transport and health records.

Freedom House, a non-profit research organization in Washington, D.C., conducts research into democracy, political and civil liberty issues. In its latest report, it noted how the Chinese government’s monitoring of citizens had “increased dramatically” in recent years.

It explained how surveillance cameras now come bundled with facial recognition software and a pilot program known as the Social Credit System is expected to expand further this year.

That system can rate citizens’ trustworthiness based on financial spending, debts, video game habits, friends and “adherence to rules in public spaces,” Freedom House noted.

Experts told Newsweek that China’s tech and social media firms have been ingesting personal data for years, seemingly then sharing some of it with the government.

“It’s hard to imagine that being rolled out in the U.S.,” Adrian Shahbaz, research director of technology and democracy at Freedom House, told Newsweek when asked if mobile software like the Alipay Health Code could ever become normalized throughout America and used to enforce quarantines.

“It comes down to key differences between democratic and authoritarian regimes. In places like China, the state places less emphasis on individual rights.

“Authorities have far greater leeway for instituting harsh and intrusive restrictions. In the eyes of the Chinese Communist Party, the ends often justify the means.

“China isn’t just a surveillance state—it’s a model for digital authoritarianism. That is, the government channels technology like biometrics, surveillance, and big data for controlling citizens’ behavior.

“The app should be viewed in the context of other alarming initiatives taking hold in China, such as the social credit system, Safe City or Smart City projects, and the vast monitoring of online speech for what they have called ‘positive energy public-opinion guidance.’”

Of course, efforts to contain COVID-19 using technology has not been limited to China. South Korea is also using a GPS-enabled app to monitor citizens who are quarantined, for example. According to CNN, an alarm will ring out if the infected user leaves their “designated location.”

And it’s not total dystopia inside China, either, with the BBC reporting that robots have been used to deliver meals to isolated patients and drones to transport medical samples.

But some experts indicated it was the invasive nature of the COVID-19-linked apps that meant they would be unlikely to be seen outside of the country.

Robert Pritchard, a security specialist who previously worked in the U.K. government, told Newsweek he couldn’t imagine an application like Alipay Health Code in any western country.

He said: “It would probably not be legal in most cases. Never mind the intrusiveness, it looks like it must rely on data from other surveillance systems to give people the codes.”

The view was not universally accepted, however.

At least in theory, Jackie Singh, founder and CEO of Spyglass Security and a former U.S. soldier, said she believes a similar system to China’s health app could indeed be implemented in the United States due to the broad territorial reach of some federal agencies, as highlighted by the ACLU.

“The Department of Homeland Security/Customs and Border Protection could be requested by the federal government to use their current powers,” Singh said. “In theory, the Department of Homeland Security could contract with a software company to produce an app which collects and analyzes data to approve travel, and make it compulsory to use to be cleared for travel within 100 miles of a border.

“While the states have varying privacy laws, federal laws supersede those of the states as long as they are constitutional, which sometimes takes years to decide.

“Many states may not push back if federal law is amended to enable dragnet surveillance of the type seen in China today. My concern is that state governors won’t be pushing back against such legislation once the number of cases is high enough and further ‘states of emergency’ are declared across the U.S.

‘If containment becomes number one priority, and an app helps with that, the legislation enabling the app becomes politically untouchable.”

But another barrier of a hypothetical American roll out of such an app, according to Shahbaz, is that it would likely face significant legal scrutiny by campaigners and rights groups.

“China doesn’t have a free press and vibrant civil society to effectively conduct oversight over the government,” the Freedom House researcher told Newsweek.

“If such an app were to be instituted in the U.S., there would be uproar among advocacy groups, media scrutiny, and legal challenges by the courts.

“Democracies can be slower to react to crisis, but checks and balances are vital for protecting individual rights and ensuring that politicians don’t rush into poor decisions.”

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