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Internet Censorship and Digital Surveillance Under Hong Kong’s National Security Law

March 28, 2024


Tin Pak

Hong Kong is a special administrative region of the People’s Republic of China (PRC), with a common law legal system inherited from its time as a British colony.[1] Hong Kong has a high level of autonomy from the PRC, enjoying many personal freedoms unknown to the rest of China such as suffrage, the right to privacy, and an open internet. However, since the National People’s Congress—China’s supreme law-making body—passed The Law of the People’s Republic of China on Safeguarding National Security in the Hong Kong Special Administrative Region, more commonly known as the National Security Law, in 2020 there has been an erosion of Hong Kong’s autonomy and its citizen’s individual rights.[2] Of the many impacts of this law, it has also subtly changed the internet landscape of Hong Kong by creating new law enforcement agencies under the purview of the PRC and coopting colonial-era ordinances to censor online content and surveil citizens.

This report’s findings indicate that the pressuring of major tech firms, blocking of online content, interception of communications, an anti-doxing law, proposed crowd-funding regulations and implementation of novel surveillance technologies have reduced fundamental freedoms in Hong Kong. These developments present a dilemma to the paradoxical socio-political structure of the city whose foundations are rooted in liberal legal traditions but face increasing interference from the PRC in its governance. Furthermore, the Safeguarding National Security bill that was passed recently by Hong Kong’s legislature has expanded the legal mechanisms and capabilities of the government in censoring and surveilling its citizens in coordination with the National Security Law.

Hong Kong’s Unique Political Status

Central to understanding the contemporary political situation in Hong Kong is the city’s unique history. In a series of wars in the 19th century between the United Kingdom (UK) and the Qing Dynasty over opium trade disputes, the UK gained control over Hong Kong island.[3] In the subsequent treaty of Nanking, the Qing government agreed to allow the UK to possess the island of Hong Kong in “perpetuity.”[4] The territory under UK control would be expanded with the Lease of New Territories agreement with the Qing government in 1898, incorporating a small portion of mainland China into its Hong Kong colony for a period of 99 years.[5] During British rule, the common law legal, and political systems took root in the colony. Although there was no representative government for most of British rule—as the governor-general of Hong Kong was still appointed by British fiat—many of the individual rights enjoyed in other Commonwealth countries were integrated into the societal framework of the city. Thanks to its strategic location at the mouth of the Pearl River and commercial liberalism, Hong Kong quickly became a trading hub in East Asia.[6]

The city’s growing separation from the cultural identity of mainland China caused in part by the citizenry’s adoption of Western customs and rule of law, presented a dilemma to the colonial government when the UK’s 99-year Lease of New Territories neared its end. Following the PRC’s admission into the United Nations as the sole representative of China in 1971, the PRC replaced the Qing Dynasty as the party to this lease.[7] Shortly afterward, the PRC successfully maneuvered Hong Kong out of the list of non-self-governing territories that were promised “complete independence and freedom” by the United Nations indicating the PRC’s desire to re-incorporate the territory.[8] During a meeting between UK Prime Minister Margaret Thatcher and PRC leader Deng Xiao Peng in 1982, the main point of contention between the two leaders was the political fate of Hong Kong. Deng unequivocally stated that the PRC “cannot but resume the exercise of sovereignty over the whole of the Hong Kong area” not just the New Territories.[9]

Despite Thatcher’s strong desire to maintain British authority in Hong Kong, according to agreements such as the Nanking Treaty guaranteeing British sovereignty over the island indefinitely, the contemporary geopolitical realities forced her hand. To normalize relations with the PRC and avoid conflict, the UK agreed to hand over the entirety of its colony including Hong Kong island with the signing of a joint declaration in 1984 in which the UK pledged to complete the transfer of power of the city in 1997.[10] In return, the PRC agreed to allow Hong Kong to maintain a high level of autonomy for a period of 50 years after the handover and the continuation of its common law political system and capitalist economy. Under this agreement, legal frameworks and ordinances that existed under UK rule remained in place along with the establishment of a parliamentary government.

In the lead-up to the handover, Hong Kong’s new mini-constitution called the Basic Law was adopted in 1990.[11] Included in this constitution were the right to elections, judicial independence, freedom of speech, and the right to privacy. The Basic Law gave the Hong Kong Legislative Council the authority to create and amend laws while the High Court was given final adjudicative authority. However, all matters of military and foreign affairs became the prerogative of the PRC. Most importantly, the Standing Committee of the National People’s Congress—the PRC’s supreme political decision-making body—was granted the power to invalidate any bill passed by the Legislative Council deemed not in conformity with the Basic Law.

Since the handover, growing public support for democratic reforms driven by a coalition of pro-democracy legislators led to increasing demands for the right to directly elect the Chief Executive and Legislative Council members which is indirect in both cases.[12] In an attempt to compromise with the pro-democracy block, the Standing Committee of the National People’s Congress proposed a bill altering the voting procedures for the Chief Executive. Instead of having a 1,200-member Election Committee directly select the Chief Executive, they suggested introducing universal suffrage.[13] The caveat was that all candidates would be vetted by a Nominating Committee composed of mainly pro-Beijing officials. This recommendation led to a series of large-scale protests known as the 2014 Umbrella Revolution. Under public pressure, the Hong Kong Legislature rejected the bill. However, the Umbrella Revolution laid the groundwork for the next political crisis by polarizing the city into a pro-democracy camp, whose demand for democratic reforms grew in scope, and a pro-Beijing camp.[14]

Following the Umbrella Revolution, the largest series of protests in the city’s history took place in 2019-2020 sparked by a proposed extradition bill that would have allowed the PRC to extradite criminals in Hong Kong to the mainland.[15] Armed clashes between police and protesters became a daily occurrence while multiple large-scale demonstrations filled streets with hundreds of thousands of protesters. Vandalism, attacks on government buildings, and illegal occupations of public spaces became prevalent as the protests became more extreme eliciting a strong police response. Over 10,000 people would be arrested in connection with the 2019-2020 protest movement with approximately 1,300 incarcerated as of 2023.[16]

After the police crackdown on the protests, the National People’s Congress passed the National Security Law (NSL).[17] This law introduced far-reaching enforcement mechanisms to target anti-government individuals and groups that they deemed secessionist or subversive in the city. Following the implementation of the NSL and the subsequent quashing of political dissent, the PRC initiated an electoral overhaul of the Hong Kong Legislative Council. In 2021, the number of directly elected legislators in the council decreased from 35 to 20 while the overall number of legislators increased from 70 to 90—diluting popular representation.[18] A new constituency of 40 legislators selected by the Election Committee was also created, solidifying the dominance of the pro-Beijing block. Moreover, the Election Committee was expanded from 1,200 to 1,500 members; however, the number of eligible voters for the election of committee members was cut by 97% with those deemed “unpatriotic” being disqualified leading to a solidly pro-Beijing committee.[19] This development is significant for this report as it allows for the passing of major constitutional amendments and laws along with the formation of new government offices to support PRC internal security interests.

The National Security Law

The National Security Law (NSL) is a broad-reaching legislation enacted by the PRC that has created legal mechanisms for the PRC and the Hong Kong government to directly censor the information space in the city in coordination with colonial-era ordinances. The NSL criminalizes a wide-ranging number of national security threats, defined extremely broadly, including secession, subversion, and terrorist activities.[20] Significantly, it also criminalizes supporting national security threats; specifically, those who “incites, assists in, abets or provides pecuniary or other financial assistance” to those committing subversion or secession can face up to ten years of imprisonment.[21] Individuals can be charged whether these offenses were committed “by force or threat of force”–meaning that those planning to or under suspicion of violating the NSL can be targeted under this law. In addition, persons who “directly or indirectly receive instructions, control, funding or other kinds of support” from external elements can be charged with foreign collusion.[22] The scope of what is considered an external element in the NSL is not clear, possibly incorporating non-government individuals and groups.

The implementation of the NSL created new enforcement agencies that are directed by the PRC and are immune to judicial review by local authorities. Following the NSL, a Committee for Safeguarding National Security was established to direct its enforcement.[23] The committee is accountable to the PRC and cannot be interfered with by local institutions and courts. Moreover, a Department for Safeguarding National Security was created in the Hong Kong police force to serve as the enforcement and investigative mechanism for the Committee for Safeguarding National Security. This department may also recruit non-Hong Kong residents.

Additionally, the Office for Safeguarding National Security of the Central People’s Government was formed to oversee the Committee for Safeguarding National Security.[24] This office, which is funded and managed by the PRC, possesses jurisdiction over complex NSL cases involving a “foreign country or external elements” and imminent national security threats.[25] In these circumstances, the PRC designates mainland prosecutors and judges for the adjudication of these special cases.[26] Furthermore, their officers and property are immune from detention and inspection by local Hong Kong authorities.[27] For the adjudication of the other NSL cases, Hong Kong’s Department of Justice was directed to create a specialized prosecution division that would handle such cases all of whose members are required to be vetted by the Committee for Safeguarding National Security.[28] What’s more, judges ruling on NSL cases will be directly selected by the Chief Executive. These judges must not have “made any statement or behaved in any manner endangering national security.”

Most significantly for Hong Kong’s internet landscape, Article 43 of the NSL empowers authorities to search and confiscate electronic devices and request “publisher(s), platform service provider(s), hosting service provider(s) and/or network service provider(s)” to remove content that endangers national security.[29] If a provider refuses to comply with government requests, it is liable for a $100,000 fine and a six-month prison sentence. Additionally, Article 43 allows NSL agencies to intercept communications and conduct covert surveillance on persons suspected of being a national security threat while requiring those with relevant information to furnish it to relevant authorities. Article 43 has international jurisdiction, applying equally to political organizations and officials of a foreign country.

However, the true power of the NSL is fully realized through its convergence and joint implementation with domestic laws. Any references to illegal activity in Hong Kong’s colonial-era ordinances, which is the law of the land, now apply to violations of the NSL. This has led to the utilization and modification of colonial-era laws to enhance the enforcement of the NSL. For instance, the Sedition Law has been coopted by NSL agencies to arrest political dissidents. This law criminalizes bringing “into hatred or contempt or to excite disaffection against the person of Her Majesty.”[30] The law applies to any such action against the current Hong Kong government since the Interpretation and General Clauses Ordinance stipulates that the PRC’s Central People’s Government replaces any reference to “Her Majesty” or similar expressions in ordinances.[31] This law had been unused for 50 years before the imposition of the NSL, since then, the two have been readily used in conjunction.[32] The High Court solidified this precedent by ruling that the NSL should “operate in tandem with the laws of the Hong Kong Special Administrative Region, seeking ‘convergence, compatibility and complementarity’ with local laws.”[33] This led to the repealing of bail and the right to a jury for Sedition cases as is the case for national security defendants.

The placing of colonial-era laws underneath the broader NSL framework has greatly expanded the mechanisms by which the PRC through local law enforcement can arrest political dissidents. As of January 5th, 2024, 286 people have been arrested and 68 convicted in relation to national security crimes. Of those arrested 160 of them were for either solely non-NSL charges such as for Sedition or both.[34]

The Hong Kong Legislative Council passed the Safeguarding National Security bill on March 19, 2024, creating a domestic national security ordinance.[35] An effort to enact similar legislation was halted in 2003 when as many as 500,000 demonstrators protested against it.[36] The 2024 bill has expanded the scope of national security-related laws by introducing new offenses while clarifying the definitions of previously criminalized actions. The ordinance includes new offenses such as insurrection, external interference, sabotage, and most significantly: “Doing an act in relation to a computer or electronic system without lawful authority and endangering national security.”[37] It also elaborates on the definition of colluding with external elements previously left vague by the NSL. Included in the bill’s definition of external elements are “international organizations,” and organizations “in an external place that pursues political ends.”[38] Additionally, punishment for previously criminalized national security offenses has been ratcheted up with acts of sedition being liable for ten years imprisonment if done so in collusion with external forces—an increase from two years as listed in the criminal ordinance. This bill passed with little opposition, as the 2021 legislative overhaul has ensured the dominance of the pro-Beijing block. In addition, John Lee, the current Chief Executive urged the legislature to pass the bill “at full speed” accelerating the process.[39]

Pressuring US-based Tech Companies Using the National Security Law

Ensuring the compliance of major tech firms to the NSL is critical for government censorship campaigns in Hong Kong. An assortment of major international tech firms operate in the city, with the top three most commonly used social media applications being Facebook, YouTube, and X.[40] These platforms represent the main communication channels between individuals and the primary source of information for the vast majority of citizens. A major aspect of the NSL is the pressuring of tech firms and service providers to assist in the censorship of their widely used platforms through Article 43 of this law.

Tech companies like Google, X, and Meta are now placed in a dilemma when operating in Hong Kong: either help the government enforce the NSL or possibly face charges of colluding with and abetting national security threats. Immediately after the passing of the NSL, these three companies in addition to Zoom, Microsoft, and Telegram stopped processing user data requests from the Hong Kong government citing privacy concerns, instead all requests must now be processed solely through the Mutual Legal Assistance Treaty the US has with Hong Kong.[41] Going even further, ByteDance halted services of its popular social media app TikTok in Hong Kong indefinitely citing similar concerns while attempting to distance itself from allegations of assisting the PRC in surveilling Hong Kong demonstrators during the 2019-2020 protests.[42]

Due to the differing legal systems that these US-based tech companies are confronted with when operating in the city, there are mechanisms that regulate their information disclosures to foreign governments. All US companies must abide by the Mutual Legal Assistance Treaty (MLAT) the US has with Hong Kong. This treaty outlines the structure of bilateral cooperation in legal investigations between the two parties.[43] Using the MLAT, US companies defer requests for user data from the Hong Kong government to the Department of Justice for approval; if the request meets the criteria of the MLAT, the company is obliged to assist in furnishing information, documents, and testimony to the foreign government. However, a party to the treaty can refuse to provide assistance if  “it is of the opinion that the request for assistance relates to a political offense” or if a criminal offense would not be constituted as one “within the jurisdiction of the Requested Party.”[44] These clauses provide the signatories with great leeway in terms of choosing when and when not to assist each other in legal matters.

Official statements and actions from the US expressed its view that the NSL is political in nature and used to target dissidents. The State Department’s 2023 Hong Kong Policy Act Report, condemned the use of the NSL by Hong Kong authorities to “further erode the rule of law in Hong Kong and the human rights and fundamental freedoms of people in Hong Kong.”[45] Furthermore, Donald Trump’s administration was very outspoken about the declining political situation in the city during the 2019-2020 protests and subsequent passing of the NSL. His administration sanctioned Hong Kong government officials, met with pro-democracy activists, and ended the city’s preferential economic treatment.[46] The Biden administration has continued these policies, recently barring the participation of Chief Executive John Lee from the 2023 APEC meetings in the US.[47] The US’s strong stance that the NSL is an illegitimate law and used to repress fundamental political freedoms disallows it from cooperating under the MLAT regarding NSL cases. Consequentially, the US State Department suspended three criminal cooperation agreements with Hong Kong in retaliation against the implementation of the NSL, leading Hong Kong to retaliate by suspending the MLAT in 2020 indefinitely.[48]

In these circumstances, US tech firms are stuck in a gray zone where the primary mechanism to authorize the provision of data to foreign governments is no longer in force. For instance, despite pledging earlier in the year they would not receive any requests from the Hong Kong government unless they were processed through the MLAT, Google in 2020 became the first major Western tech company to hand over data to Hong Kong authorities.[49] Out of 43 requests Google received in the second half of that year it disclosed data for three of them; one was an emergency request that involved a threat to life and the other two involved human trafficking which Google viewed as unrelated to the NSL. For this reason, Google stated that it wasn’t obligated to seek approval through the MLAT and followed its global policy regarding disclosing user data.[50] This is in contrast to Meta which has not produced data for any requests made by the Hong Kong government since the NSL came into force.[51]

Differing from the policy stance of these firms, Apple did not suspend the processing of NSL-related data requests from the Hong Kong government. In the second half of 2022, Apple received 272 requests and disclosed data for 181 of them.[52] The majority of these were requests for financial identifiers, such as credit card numbers in cases of fraudulent activity. However, 27 were requests for data from user devices such as Macbooks or iPhones, and four were for account information like emails and photos stored on iCloud; four and two of these requests were granted data by Apple respectively.[53] Apple does not indicate if any of these requests were NSL-related. A possible reason for Apple’s divergence in policy from the other firms mentioned is that it has greater investments in China so are cautious about provoking the Hong Kong government. Apple relies heavily on the industrial capacity of the PRC to manufacture its products while also providing its services to its large consumer market.[54] Nonetheless, like the other US-based companies Apple is still publicly committed to processing all national security-related requests through the MLAT.

In contrast to data request disclosures, tech company compliance with content restriction and removal requests has increased dramatically since the implementation of the NSL. For Meta, the number of complied with restriction requests from the Hong Kong government increased from 199 in the first half of 2020 to 4,004 in the first half of 2023. Meta has not disclosed if and how many of these requests were NSL-related.[55] Google received removal requests for 330 items by the government in 2022 which is a considerable increase from 116 the previous year.[56] According to Google’s transparency report, it did not take action for 48.1% of these requests while complying with 30% of them. Of the 330 item removal requests, 55 of them were NSL-related which when compared to the six NSL-related requests for 2021 represents a dramatic increase. Google’s transparency report does not reveal what portion of this subsection of NSL-related requests was complied with.

If the NSL continues to target user information on these platforms, many tech firms may consider reducing their operations in the city. As Google and Meta had their services blocked in China for not complying with domestic regulations, these tech companies face a similar situation in Hong Kong.[57] However, these two companies accounted for more than 60% of Hong Kong’s $1.15 billion in advertisement spending in 2019—the loss of revenue in halting operations in the city is a strong deterrent for such a move.[58] Nonetheless, their continued cooperation with authorities despite the suspension of the MLAT indicates that these companies do not plan to exit the city anytime soon. As was the case in Vietnam, these firms tend to abide by domestic laws and censorship regulations.[59]

Furthermore, legal loopholes in the NSL may incentivize these companies to remain in Hong Kong. According to the implementation rules of Article 43 of the NSL, firms may not face legal repercussions if the technology required for compliance with the law was not “reasonably available to the publisher or relevant service provider.”[60] This means that if these companies decide to end-to-end encrypt their services, they may be immune to the NSL.[61] For instance, Apple stores all their encryption keys for iCloud accounts in the US separate from their offices and data centers in Asia. As a result, they would need to seek permission to disclose such keys to the Hong Kong government through the MLAT.[62] This raises the possibility that encrypted services could remain uncensored.

Blocking Online Content and the Expansion of China’s Firewall

Websites and online content promoting conflicting narratives with the PRC have been blocked while aspects of China’s digital firewall are being implemented in Hong Kong under the NSL. The UK-based human rights group Hong Kong Watch’s website is no longer accessible on some internet networks in the city without using a virtual private network.[63] The internet providers of these networks likely blocked the website; however, they and the government declined to claim responsibility. A website dedicated to the Tiananmen Square massacres of 1989 called 8964museum is also reported to be partially blocked.[64] Additionally, the pro-democracy 2021 Hong Kong Charter group’s website was blocked after the Hong Kong government requested the site’s host Wix, an Israel-based company, to remove it on the grounds of violating the NSL—an example of the extra-jurisdictional dimension of the law.[65] Wix temporarily blocked access to the site but then reinstated it after claiming to have mistakenly done so.

Website blockage campaigns have been partially implemented with only certain networks having websites blocked by their internet providers. Out of 882 networks tested only 147 of them showed signs of potential blocking for the website 8964museum.[66] This could be a strategic decision by Hong Kong Authorities who seek to restrict access to these websites without administering a full-scale denial of service campaign. Such a move would inevitably lead to public outcry, further international condemnation of the NSL, and a decline in business confidence in the government.

Additionally, there has been a push to block online content deemed secessionist or subversive. In 2023, the government sought an injunction for the removal of the protest song titled Glory to Hong Kong from online platforms.[67] This song was the unofficial anthem of the 2019-2020 protest movement. When searching for “Hong Kong’s national anthem” on Google in 2022, a Wikipedia page for the Glory to Hong Kong song appears as the first result.[68] This song was deemed in violation of the NSL by the government for its promotion of subversive ideas and has even been banned from schools.[69] Before submitting an injunction, the government requested Google to modify its search engine to place the official PRC national anthem as the first result.[70] However, Google refused to alter its search algorithms and the injunction was ultimately denied by the High Court which ruled that the requests for the restricting of speech were not proportionate to the situation.[71]

Furthermore, the border between Hong Kong’s internet and that of the PRC is becoming increasingly blurry. Throughout the rest of China, the PRC’s internet firewall blocks popular search engines and applications like Google and Facebook because the companies refuse to comply with government censorship policies.[72] In contrast, Hong Kong maintains access to these services having a separate internet domain from the mainland. Nonetheless, an open-source code-sharing website called GitLab was temporarily blocked for some Hong Kong users by Safari’s safe-browsing feature—originally designed to prevent phishing and ransomware attacks.[73] This situation revealed that Tencent, the company operating the Safari safe-browsing feature for Apple in China, has extended its website blacklist to Hong Kong. A review of Safari’s privacy policies indicates that sometime after November 24, 2022 Apple modified its terms and conditions regarding its services in Hong Kong. In the Fraudulent Website Warning section, it is now listed that Tencent is operating Safari’s safe-browsing feature in the city.[74]

Monitoring Social Media Platforms

Increased monitoring of social media platforms by authorities is evident through the arrest of online political dissidents for publishing posts that violate the NSL. Social media applications allow for the wide proliferation of content to a large audience, which was crucial for the rallying of pro-democracy advocates during the 2014 Umbrella Revolution and the 2019-2020 protests.[75] However, its easy accessibility and wide use allow the police to easily track the publication of illegal content while identifying the publisher.

In an example of the coopting of colonial-era laws by the NSL, a university student named Yuen Ching-Ting pleaded guilty to charges of sedition made under Hong Kong’s criminal ordinance for online posts published while studying in Japan.[76] Yuen Ching-Ting was originally arrested on suspicion of inciting secession as listed under the NSL. She had been studying in Japan since 2018 and had made 13 posts on Facebook and Instagram such as “I am a Hongkonger; I advocate for Hong Kong independence.” She was detained when returning to Hong Kong to renew her identification card.

Another example is Owen Chow, a pro-democracy activist, who was out on bail awaiting his trial for a separate NSL case and was rearrested for a subversive social media post.[77] Associates of Chow reportedly posted remarks on his Facebook account encouraging voters not to go to polling stations for an upcoming legislative election as a form of protest to the Legislative Council’s electoral overhaul. Additionally, posts were made commemorating the “August 31 incident” which was a clash between protesters and police at a subway stop in the city during the 2019-2020 protests.[78] Following his rearrest, police warned that those who post subversive content on behalf of detainees like Chow would face legal consequences.

Interception of Communications and Covert Surveillance

Article 43 of the NSL empowers national security agencies to bypass traditional regulatory processes when intercepting communications and conducting covert surveillance. According to the domestic Interception of Communications and Surveillance Ordinance passed in 2006, any one of these operations requires authorization from a list of High Court judges selected by the Chief Executive.[79] Authorization is granted when these judges agree that the interception or surveillance is proportionate to the severity of the case—if it endangers public security or is a serious crime. This process is monitored by the Commissioner of Communications and Surveillance who is a former member of the High Court. Statistics for the number of authorization requests made by law enforcement agencies and the number of those that are granted are all publicly available in annual reports. In 2022, 1153 authorizations were granted from this office.[80]

Although this ordinance is still in force, with the passing of the NSL a legal backdoor has been created for national security agencies to conduct interceptions of communication and surveillance that is unfettered by judicial oversight. Diverging from the Interception of Communications and Surveillance Ordinance, an officer of the Department for Safeguarding National Security in the police force may request the Chief Executive directly for authorization of an interception or surveillance warrant.[81] Their authorization records are not publicly available with even the Commissioner on Interception of Communications and Surveillance not having access to these reports.[82] This opaqueness prevents an accurate estimation of the extent of communication surveillance under the NSL.

However, private communications have been used as evidence in NSL cases indicating an active employment of these activities. The prosecution in Jimmy Lai’s—founder of the pro-democracy newspaper Apple Daily—NSL trial utilized private WhatsApp messages sent between him and the associate publisher Chan Pui-Man of Apple Daily as evidence of foreign collusion. Chan who pleaded guilty to charges of colluding with foreign forces under the NSL testified for the prosecution during Lai’s trial.[83] Chan’s private WhatsApp messages with Lai indicated that Lai was trying to get in touch with foreign organizations. In one message from 2017, Lai asked Chan to connect him with Benedict Rogers, co-founder of the UK-based human-rights organization Hong Kong Watch.

It is unclear how the prosecution gathered these messages, particularly whether it was voluntarily given by Chan or intercepted by the authorities. Moreover, they also cited emails Lai made with former US officials and interviews he had with foreign media.[84] All this evidence is crucial in Lai’s trial as it directly connects him with foreign elements and reveals the content of high-level decision-making at Apple Daily after the implementation of the NSL—Lai faces a possible life sentence if convicted of the numerous violations of the NSL he is charged with.

Anti-Doxing Law

With the implementation of the NSL and subsequent restructuring of the Legislative Council to ensure the dominance of the pro-Beijing block, anti-doxing legislation that restricts government oversight has been implemented. The Legislative Council passed a bill amending the city’s Data Privacy Ordinance in 2021 to increase the enforcement of online doxing—the disclosure of personal information without the consent of the subject.[85] Under this amendment, if doxing was committed with the intent to cause “specified harm to the data subject or any family member of the data subject” this violator could face up to six years of imprisonment.[86] Specified harm is defined as harassment and intimidation that causes “bodily harm or psychological harm” to a person. The inclusion of psychological harm which can apply to many circumstances allows for a wide interpretation of doxing offenses by authorities. Furthermore, the amendment authorizes the government to request international and domestic internet service providers to remove online identifying data from their platforms and restrict services to those who disclose such information.[87]

During the 2019-2020 protests, doxing was used by both government supporters and pro-democracy protestors to intimidate their rivals. Personal information such as phone numbers, addresses, and names of family members was distributed online—doxing was most prevalent on encrypted messaging apps like Telegram. Protesters justified doxing as a way to expose government opaqueness; police officers stopped displaying identification badges during the protests. Pro-government groups sought to help law enforcement identify protesters and pressure pro-democracy groups to halt demonstrations through doxing.[88]

Many pro-democracy groups view the new amendment as a partisan tool for the government to target political dissidents and restrict oversight. An anti-government website that doxed police officers and pro-Beijing supporters called HKchronicles became the first website to be blocked under the modified ordinance.[89] Government authorities demanded that Hong Kong Broadband Network–one of the largest internet providers in the city– restrict access to the website.[90] Shortly afterwards, the Asia Internet Coalition representing various major tech firms in the region including Apple and Meta, published a letter warning the Hong Kong government that if their members are sanctioned for non-compliance with anti-doxing requests, they may refrain from further investments in the city.[91] During eight months between 2021-2022, Hong Kong’s privacy watchdog issued more than 770 notices to 14 social media companies to remove approximately 3,900 doxing messages.[92]

Despite the restriction of HKChronicles, a web of doxing websites identified as HKLEAKS targeting protesters remained online two years after the amendment was enacted.[93] Over 2,000 journalists and pro-democracy advocates were targeted by HKLEAKS with private information and other identifying data being distributed online. Toronto University’s Citizen Lab stated that it is highly likely that HKLEAKS was a non-organic campaign created by pro-PRC groups.[94] It pointed out that HKLEAKs became operational in August of 2019 a few weeks before Twitter removed 936 accounts originating from the the PRC for artificially disseminating information “attempting to sow political discord in Hong Kong.”[95] Citizen Lab concluded that the creation of HKLEAKS was a response by pro-PRC groups to Twitter’s crackdown on PRC interference in the city, as a way to continue influencing Hong Kong’s information space. Moreover, PRC state media publicly promoted HKLEAKS, giving further credibility to this theory.

The most recent iteration of HKLEAKS was a website listed under the URL “” This site is under a Pakistani domain, a strategy utilized by the group to skirt domestic regulation.[96] In response to media inquiries, the Personal Commissioner for Personal Data justified their selective non-enforcement of the law by stating that although HKLEAKS is in violation of the law, it remains outside the jurisdiction of the Privacy Ordinance which has no extraterritorial authority. As of June 2023, this site is no longer active under this URL.

Proposed Crowdfunding Regulations

There is proposed crowd-funding legislation aimed at restricting donations to groups and individuals deemed as national security threats in Hong Kong. After a three-month consultation period, the Financial Services and Treasury Bureau published a report in 2022 that proposed creating a Crowdfunding Affairs Office to regulate crowdfunding activities in the city.[97] Crowdfunding is described in the report as the raising of “funds from individuals or entities of Hong Kong, or individuals or entities located in Hong Kong.”[98] This definition does not delineate from subscription or payment platforms like YouTube or Paypal which have monetization and transaction features. This office would be empowered to take law enforcement action against crowdfunding activities they believe could “jeopardize public interests, public safety or national security.” In addition, paralleling the NSL the Crowdfunding Affairs Office would have international jurisdiction treating foreign and domestic fundraisers alike.

The proposal threatens the capacity of political and human rights groups to collect funds in Hong Kong. Online donations from around the world supported pro-democracy organizations and covered the legal costs for political dissidents on trial during the 2019-2020 protests.[99] Most notably, the Alliance for True Democracy Limited’s 612 Humanitarian Relief Fund was a crowdfunding initiative set up by pro-democracy activists to collect financial aid and materials.[100] In 2023, the fund’s trustees were accused of conspiring to collude with foreign powers, an NSL offense, and were arrested by national security police. A few months later, ten other people were arrested on suspicion of colluding with foreign forces by conspiring with the 612 Humanitarian Relief Fund to “provide financial assistance to organisations that support overseas fugitives or advocate for imposing sanctions on Hong Kong.”[101]

Under the proposed Crowdfunding Affairs Office, fundraisers who receive donations above a certain value can be required to have their finances audited.[102] Fundraisers will also be obligated to provide the identities of donors “from any crowdfunding platforms, financial institutions, or payment service providers they cooperate with.” This prevents the anonymous donation of funds to politically sensitive groups–exposing donors to arrest, as the NSL criminalizes those who “provide pecuniary or other financial assistance” to national security threats.[103] Furthermore, the report proposes mandating that crowdfunding companies keep “at least one person with a physical address in Hong Kong” as a representative. This feature seeks to ensure the compliance of foreign-based companies by threatening the arrest of representatives or the confiscation of property if they don’t abide by their regulations.

The broad surveillance capabilities this office would have will lead to self-censorship on crowdfunding platforms. Donors to groups in violation of the NSL would be vulnerable to being identified by authorities through their use of crowdfunding services. What’s more, service providers would be under greater pressure to preempt the creation of fundraising accounts that could violate the NSL. If they failed to do so, they could be at risk of being incriminated for abetting a national security threat. Subsequently, people in Hong Kong will likely be dissuaded from donating to politically sensitive causes that could be interpreted as violating the NSL out of fear of being targeted by the government.

Online News-Media Censorship

The self-censorship of media organizations is a major feature of the NSL that has assisted the government’s efforts in suppressing political dissent and in-depth reporting. Fearful of breaching the NSL, news organizations are removing online content and refraining from posting materials on their platforms that could violate the law. According to a 2023 survey by the Foreign Correspondents’ Club in Hong Kong, 65% of journalists reported self-censoring their writing in content or avoiding certain subjects which is a large increase from identical surveys taken in 1990 and 1997 by the Chinese University of Hong Kong that listed this figure at 20%.[104] Additionally, 57% of respondents reported that they encountered some form of censorship by their news organization an increase from 44% in 2021.

In this increasingly volatile legal environment, many news agencies treat political news stories blandly and avoid sensationalizing them to evade the government’s ire.[105] An anonymous informant within one of the major news agencies in Hong Kong reported how their editorial team categorized substantial new stories as “non-engaging” while focusing on trivialities when covering political content. For example, when Xi Jing Ping visited Hong Kong in 2017 news article omitted the historical significance of the event and instead focused on what type of luggage he carried and why his bodyguards wore sunglasses. In other instances, news agencies and reporters would just avoid political stories altogether.

The increased editorial self-censorship of these organizations in conjunction with modern online advertisement methods has been decreasing the visibility of political content on their platforms.[106] The greater commercial pressure to adopt online business strategies since the advent of the internet has led to the proliferation of advertising methods that promote sensationalist and click-bait content. Managers increasingly consider a multitude of viewership metrics when selecting topics and headlines for articles. Instead of basing their criteria on newsworthiness, they focus on the profitability of their content based on advertisement algorithms. This has led to political news articles being less propagated by online ad agencies that expect less revenue from them due to the moderated tone of writing caused by fears of violating the NSL on the writers’ part. On top of this, news managers who view certain stories as politically sensitive would omit them from traditional social media and app notification promotions to lessen the proliferation of such content. Indirectly, these advertisement mechanisms have assisted the government in the regulation of undesired political news and moderation of public discourse.

Along with this subtle approach, Hong Kong authorities have publicly pressured media companies to make editorial changes and remove content criticizing the government. Radio Television Hong Kong (RTHK)—the largest public broadcasting company in the city—announced in 2021 a new policy of deleting videos from its YouTube and Facebook accounts that are over a year old.[107] RTHK also blocked the commenting function on its X account citing a lack of resources to monitor misinformation in the comments section.[108] These developments were in response to a Commerce and Economic Development Bureau report criticizing RTHK for deficiencies in their editorial management leading to the replacement of the editor-in-chief with Patrick Li—a government official with no prior journalism experience. RTHK was previously criticized by the government for its investigative reporting on police negligence and publishing of a documentary on China’s suppression of Muslims in Xinjiang.[109] Additionally, RTHK provided live coverage for the protests of 2019-2020 and had a lengthy archive of videos of those events online which have since been removed under their new policy. Li would go on to modify the company’s corporate guidelines, adding that “RTHK has an obligation to safeguard national security,” by prohibiting content that provides a platform for activities “which are contrary to the interests of national security.”[110]

For avowedly anti-government newspapers, the government has taken a more severe approach. Apple Daily, a Hong Kong pro-democracy newspaper, was forced to close in 2021 after its offices were raided by police and its top executives arrested for their publication of 30 articles that allegedly had content violating the NSL—some called for foreign sanctions on the PRC and Hong Kong governments.[111] Simultaneously, they had $2.3 million of their assets frozen. With the leadership in jail and no longer financially viable, Apple Daily decided to shut down both its print and online editions. They took down their website and erased all content on their social media accounts leading many supporters to attempt to archive Apple Daily’s old articles and videos on decentralized storage platforms like ARWeave.[112]

SIM Card Registration

The registration of SIM cards in the city has allowed the government to monitor activity on mobile devices and track the movements of individuals. In March 2022, the Commerce and Economic Development Bureau began enforcing a new law regulating that all individual user SIM cards must be registered with a legal name, date of birth, and Hong Kong identification card number.[113] Corporate users must provide the name of their company and their business registration certificate number. Any SIM cards not registered accordingly will lose access to mobile and online services that are connected to their card. For instance, a person would not be able to access online banking services that rely on dual authentication processes tethered to a user’s phone number.

The stated purpose of the regulation is to help combat deception and criminal activity; violators can face up to ten years of imprisonment if they impersonate another individual. However, there is a national security dimension to the law with the press release announcing the beginning of consultations on this regulation citing the use of non-registered SIM cards for improvised explosive devices as a factor motivating the creation of this law—a clear reference to the unrest of the 2019-2020 protest movement.[114]

This new regulation prevents people from using digital platforms anonymously by tying mobile activity to identities. SIM cards are tethered to phone numbers and wireless data services allowing service providers to track the digital activity of users when requested under Article 43 of the NSL. Short messaging services and phone calls can now be directly linked to a user–deterring unlawful communication through these channels. A commonly used method of evading detection when communicating on mobile devices is a burner phone. Burner phones are devices that use a non-identifiable pre-paid SIM card that can be quickly disposed of if the user is being monitored.[115] In fact, the previously mentioned government press release indicates that the government was specifically concerned with this type of pre-paid SIM card as its purchase does not require the provision of personal information to the service provider or regular billing as is the case with subscription-based cards.[116] Now attaining such devices would not be possible with the new law as purchasing any type of SIM card would require the provision of identifying information to the service provider.

Individuals can also be geolocated from the pinging of their SIM cards with cell towers. In the US, devices called Stingrays which mimic the signal of a cell tower are used to connect to cellular devices so that it can triangulate the location of individuals.[117] Law enforcement in the US and other liberal democracies readily use such technologies as they skirt laws that prevent them from demanding service providers to track users for them. There is no reported use of Stingrays in Hong Kong, nonetheless, the expanded interception of communications and covert surveillance powers for law enforcement agencies granted by the NSL make such devices unnecessary as they have the authority to demand service providers to provide such assistance.[118]

Surveillance Devices & Facial Recognition

A critical aspect of enforcing the NSL is the physical monitoring of individuals in violation of the law through an extensive surveillance system that serves the dual purpose of accurately recording crimes and deterring illicit activity. On February 11, 2024, Police Commissioner Raymond Siu Chak-yee announced that 2,000 new CCTV cameras would be installed throughout the city. These cameras are planned to be located in high-density areas where crime is most prevalent and there are greater pedestrian flows. The first 615 of these cameras will be installed throughout March 2024 for a test period—the rest are planned to be installed by the end of the year.[119] When asked whether facial recognition technology would be included with these cameras, the commissioner did not rule out the utilization of this type of technology suggesting that it may help with law enforcement.[120] According to the Privacy Commissioner’s guidelines on the use of CCTVs, the use of facial recognition technology is not ruled out but “must be supported by strong justifications.”[121] Furthermore, the legislative report announcing this initiative states that the police are “studying the feasibility of equipping the CCTV system with artificial intelligence” to enhance criminal detection.[122] They do not elaborate on what forms of artificial intelligence technology they are considering.

The Privacy Commissioner’s guidelines on the use of CCTVs are the primary directive regulating the implementation of surveillance cameras by law enforcement.[123] It states that the use of CCTV cameras “should be properly controlled to avoid intrusion into the privacy of individuals.” However, the violation of privacy is permitted if it is proportionate to the severity of the situation; since national security is an apex priority for the government it can be assumed that the maximum use of surveillance cameras would be authorized in these circumstances. Furthermore, the guidelines state that the personal data collected from CCTV cameras should be deleted once its use is no longer necessary for authorities. With that being said, it is unclear whether NSL agencies are obligated to abide by these rules. As is the case for the requesting interception of communications and covert surveillance, these agencies act independently from other domestic law enforcement and do not have the same obligations to follow regulations governing local authorities.

This development comes on top of the completed installation of over 400 “multi-functional smart lamp-posts” throughout the city in December 2023—a project that began in 2019.[124] These posts are equipped with automatic license plate recognition, Bluetooth detectors, and pan-tilt-zoom surveillance cameras whose stated purpose is to monitor traffic and illegal dumping of garbage. Additionally, these posts have Radio-frequency Identification tags that use radio waves to track wireless devices according to a description by the US Homeland Security Agency.[125] Although the report states that due to privacy concerns from the public regarding these devices they will not activate these surveillance features, the smart lamp post remains capable of doing so at any time when requested.

During the 2019-2020 protests, 30 of these smart-lamp posts were dismantled or damaged by protesters as it was widely believed that they were used to monitor demonstrations with many fearing that they are equipped with facial recognition capabilities similar to those found in the rest of the PRC. Facial recognition cameras in some Chinese cities are capable of simultaneously detecting more than 60 faces at a time and the PRC is the most CCTV camera-saturated country in the world with an average number of cameras per 1,000 persons in major Chinese cities at 439—this is 26 times greater than Moscow’s rate.[126] Coincidentally, at the height of the 2019-2020 protests Megvii—a multi-billion dollar facial recognition company—filed its Initial Public Offering in the city heightening these concerns.[127] Despite claims by the company that their technology was not being used in the smart-lamp posts, the fear of being tracked and identified through facial recognition drove many protesters to wear masks and use umbrellas to hide their identities.[128]

In comparison to the rest of the PRC, Hong Kong has a low rate of CCTV cameras per citizen. According to a report by Comparitech, the city has 7.09 cameras per 1,000 citizens as of 2023, this is less than some US cities like Los Angeles which is at 10.27.[129] This disparity may partly be due to the higher population density of Hong Kong compared to other cities which reduces the need to have a high quantity of cameras as they have a smaller number of locations to surveil. Moreover, despite the increasing number of surveillance cameras equipped with greater levels of identification technologies, there is no solid evidence that the more advanced features prevalent throughout China have been implemented as of yet—most notably, facial recognition capabilities.

That said, with the expansion of the number of surveillance cameras throughout the city, prosecuting individuals for violations of the NSL will become easier for the government. During the 2019-2020 protests, demonstrators were largely successful in concealing their movements and hiding their identities.[130] Nonetheless, they remained greatly reliant on the overwhelming number of protesters that thwarted police efforts to track individuals through surveillance camera footage. In the event of another major protest movement, police may no longer be restrained by this factor with the implementation of advanced technology, whether it be facial recognition or other artificial intelligence, streamlining the identification of individuals.

Implications for the Future of Hong Kong

Hong Kong’s recently passed Safeguarding National Security bill will expand the scope of the NSL and create new avenues for local law enforcement to suppress anti-government dissent through the imposition of new criminal offenses. It remains to be seen how broadly the new National Security ordinance will be enforced and its implications for civil society. Particularly, we will see how the government decides to prosecute collusion with external forces using the broad definition they outlined and the clause criminalizing the usage of computers or electronics that endanger national security. Nonetheless, critics of the government who have avoided arrests since the passing of the NSL now face a new set of legal threats.

The internet censorship and digital surveillance campaigns listed in this report are a framework from which the implementation of the NSL in coordination with domestic laws can be understood. The internet is not an isolated information structure and our digital devices are not detached objects, instead, they are the foundation of our social life in the modern age. For this reason, by analyzing the enforcement of the NSL in the context of online activity we can gain a better grasp of how it and other national security-related laws will impact Hong Kong’s socio-political development.

Hannah Arendt described the true force of totalitarian regimes as not in its direct enforcement of repressive laws but its ability to atomize the individual from their communities, create a sense of paranoia, and instill compliance through self-censorship.[131] The NSL has done exactly this in Hong Kong and will continue to do so in the future as the 50-year time frame of autonomous rule nears its end and the PRC’s desire to enforce its will in the region grows. Moving forward, every online post, private message sent, and phone conversation a person has will be reconsidered with the heavy hand of government persecution hanging over them. This phenomenon has led to a version of what George Orwell termed “Newspeak” in his book titled 1984, meaning the usage of terminology in everyday life following the ideological requirements of the state.[132] Hong Kong citizens are already avoiding the use of certain words commonly censored in mainland China, more readily deleting social media posts, and using ambiguous language when discussing sensitive political topics.[133] In an ironic twist, journalist Allan Au was arrested for sedition when pointing out this correlation between Orwell’s fictional dystopia and Hong Kong.[134] Through proof by contradiction, Au’s persecution symbolizes the memory of Hong Kong’s liberal past–as an island of relative freedom amidst a sea of authoritarianism–being buried in history.


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