Aadhaar and the Social Credit System: Personal Data Governance in India and China

Abstract

The Social Credit System in China and the Aadhaar system in India constitute 2 cases of the most rapid capture of personal data about national populations in history. So far, there is limited research about how the 2 systems operate in practice, on the ground. Yet for the longer-term shaping of the 2 systems—including notions of privacy, the role of the state in promoting digital technologies, and the relation among states, markets, and civil societies—there is extensive research to draw on. This article puts the comparison between the 2 systems into a larger framework of the experiences of other countries. It also locates the comparison in current debates about the governance of digital media companies and the regulatory regimes that pertain to them, including other personal identification systems. The article concludes with reflections on the prospects for China’s and India’s systems and beyond.