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China's single portal

Under the Chinese authoritarian model, citizens give everything to public safety entities. They look at power data to find Bitcoin mining, check public transit data to make sure no one is meeting subversive people, and read text messages.

The scattered US picture

In the United States, no gigantic master repository holds everything about a citizen or consumer in one database. The data sits across many databases in many places, some in government hands, some in corporate hands, some for sale, and some not for sale.

Companies build detailed dossiers from property records, email addresses, purchasing habits, browsing habits, and geolocation. Some dossiers collect in the hands of data brokers, and companies sometimes trade the information among themselves or sell it when they go bankrupt.

Why must Chinese companies share data with the state?

China's National Intelligence Law of 2017 says organizations and citizens must support and cooperate with state intelligence work. The 2017 Cybersecurity Law requires network operators to give technical support to public security and national security agencies.

How do data brokers build dossiers?

Brokers collect from public records, store loyalty programs, website cookies, and apps, then link rows by shared keys such as email address, phone number, and home address. A 2014 Federal Trade Commission report studied nine data brokers and found one database with information on 1.4 billion consumer transactions and more than 700 billion aggregated data elements. Brokers sort people into categories and sell those lists to marketers and others.

What happens to customer data in bankruptcy?

In US bankruptcy proceedings, a customer database can be treated as an asset that creditors want sold. In 2000 the online toy retailer Toysmart went bankrupt and tried to sell its customer list despite a promise in its privacy policy not to. The Federal Trade Commission sued to stop the sale, and the list was eventually destroyed.

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