Chinese digital platforms in Australia: From market and politics to governance

Abstract

Through the lens of platform governance, this paper examines the market, politics, and governance of made-in-China digital platforms in Australia, with a focus on WeChat and TikTok. It investigates how formal and informal arrangements are intertwined in the governance regimes and market strategies of these Chinese digital platforms when trying to navigate the turbulent waters of intensified Sino-Australia relations and a global trend towards increased government intervention in platform governance. The two made-in-China platforms represent two different models in platform governance adopted by Tencent and ByteDance: one conditioned by the Chinese ‘strict liability’ model and the other leaning toward the Western ‘broad immunity’ model. The Australian case illustrates the strife, success and politics of outbound Chinese digital platforms in a Western liberal democracy. It also highlights the dilemma, conundrum, and possible breakthrough in platform governance on a splintered and yet increasingly interconnected social media space.

Keywords

WeChat TikTok tencent ByteDance Chinese platforms platform governance

Introduction

The rapid surge and ubiquity of social media platforms is viewed by communication scholars as a manifestation of ‘platform capitalism’ and ‘platform society’ (Srnicek, 2017; Van Dijck et al., 2018). In platform studies, the focus has been on international (aka American) platforms, such as Facebook, Twitter, YouTube, Google, Airbnb and Uber. However, there has been a growing interest in Chinese social media platforms in industry and academia. Scholars have called for ‘de-Westernising platform studies’ (Davis and Xiao, 2021; O’Regan and Li, 2019) and recognising (or acknowledging) the role of made-in-China platforms in technological, business and cultural innovation. Indeed, we have seen growing global attention on Chinese platforms, mostly those owned by Baidu, Alibaba and Tencent (BAT) and ByteDance, Meituan and Didi-Chuxing (BAD) (e.g. Keane et al., 2020). These platforms are notable for their technological innovation, dominance in national and private lives, and most of all, their embeddedness in and co-existence with media infrastructures.

China's digital platforms have permeated and dominated everyday Chinese lives, from searching, social networking, buying and selling, to advertising, gaming, crowdsourcing and cloud computing. They have contributed to the ‘platformisation of Chinese society’ (De Kloet et al., 2019). As current scholarship on Chinese digital media studies has pointed out, Chinese internet and social media companies stand on the frontiers of Chinese capitalist expansion, economic restructuring and massive uptake in digital transformations (e.g. Hong, 2017). As China becomes a leading digital economic power, more and more attention has been paid to the political economy of Chinese digital platforms. This includes the penetration of the Party-state in platform infrastructures in the everyday life, and the implications of such entanglement on platform governance, user practices, labour and everyday life (e.g. De Kloet et al., 2019; Jia and Winseck, 2018; Plantin and De Seta, 2019).

Chinese digital platforms are also known for their ambition to take on American platforms in competing for market and influence outside the ‘walled’ Chinese internet. They start from places Chinese migrants and visitors go, such as Southeast Asia and Australia. In Australia, technically, all Chinese digital platforms are accessible and used by Chinese migrants, students and visitors. Research has shown that social media habit formation is an intentional and emotional process driven by conscious decision-making and unconscious affective attachment (Hu et al., 2018). Migrants take their social media habits to their host countries. Like other migrants to Australia, Chinese migrants from the People's Republic of China (PRC) often stick to their social media habits even after they have adopted Western platforms. Most Chinese migrants in Australia have WeChat, TikTok, Weibo, or Xiaohongshu on their phones alongside Facebook, Twitter, YouTube, WhatsApp, Signal, Telegram or Line. This is no different to anyone else using a range of social media platforms to conduct personal messaging, engage in group communication and community business activities, produce and distribute news, and access and share information.

In this article, we focus on two digital media and social commerce platforms—WeChat (the international version of Weixin) and TikTok (the international version of Douyin)—for their growing popularity and influence in Australia. They have explicit global visions and have already built up their presence and influence in overseas markets beyond the Chinese diaspora. As a result, they have been under greater scrutiny from Australian policymakers and security and intelligence apparatus. The two made-in-China platforms have responded to such a market and politics by way of optimising platform governance regimes.

This research is taken over three years (2019–2021) using mixed qualitative methods, comprising the walkthrough method, policy analysis and discourse analysis. The walkthrough method allows researchers to engage with an app in a comprehensive and systematic way, with its focus on the app's technical and governance features, intended purpose, and embedded cultural meanings (Light et al., 2018). We have had personal accounts on WeChat and TikTok since 2013 and 2018 respectively and used these accounts to ‘walk into’ the apps’ infrastructure and experience new features and policy changes in service agreements and content moderation practices over the years. This has enabled us to gain insiders’ knowledge of their modus operandi. In policy analysis, we focus on key policy documents like the News Media Bargaining Code (passed in February 2021) and those released from senate hearings on the Select Committee on Foreign Interference through Social Media (December 2019 and September 2020). This is in addition to corporate policies including terms of use, community guidelines, and privacy policies developed by these two platforms. We also employ critical discourse analysis to analyse Australian mainstream media coverage of Chinese technology companies, Chinese digital platforms, and Sino-Australia relations. We do not intend to paint a comprehensive picture of such media coverage through detailed content analysis. Rather we focus on producing nuanced insights about the trend that Chinese platforms are represented and discussed in the Australia public space.

The article starts with a brief discussion of the theoretical framework, followed by an overview of WeChat and TikTok as example of made-in-China platforms operating in Australia. It is followed by a discussion of the politics of WeChat and TikTok in Australia, particularly their responses to the suspicion and hostility towards their ownership and content moderation practices. The fourth part focuses on the governance issue. We unpack the two dimensions of platform governance by and of WeChat and TikTok in the Australian context.

Theoretical framework

This article deploys Gillespie (2017)'s notion of platform governance to examine the dynamic interrelations between ‘governance of platforms’ and ‘governance by platforms’—the two dimensions of platform government in Gillespie's conceptualisation, referring respectively to the policy framework to regulate platforms and the ways in which the major platforms regulate their users—in the cases of WeChat and TikTok in Australia. The first dimension, governance of platforms, refers to the regulatory frameworks designed to rein in highly concentrated global digital intermediaries like GAFA (Google, Apple, Facebook, Amazon) in content agglomeration, search, and social media. It is recognised that information technologies and social media platforms are the sites for new contestations of power that can be employed by geopolitical actors for surveillance and information control—what is called ‘politics of platforms’ (Gillespie, 2010). It is known that the “neutrality” of technology companies is a myth, as illustrated by American and Chinese digital platforms surveilling citizens at home and abroad (Napoli, 2015; Ryan et al., 2019). These platforms use proprietary algorithms to filter and hierarchise news and information online, and thus enjoy enormous amount of power and influence over people's views and lives through information manipulation and electoral interference. National governments are increasingly concerned about such power and influence of global digital media companies, whether these concerns are economic (e.g. market dominance and anti-competitive practices), social and cultural, or political in nature. They have sought strategies, including applying competition and media content regulations, to regulate the content and operations of online platforms through policies like European Union's General Data Protection Regulation, which regulates platforms’ data practices, or the News Media Bargaining Code in Australia that specifies platforms’ liabilities and responsibilities for user content and activities.

In the global ‘techlash’ (Flew et al., 2019), digital platforms are not passive respondents to national regulators. How they respond to geopolitics and develop their own algorithms and policies to enact the regulations and requests from national governments and regulate content and user behaviours on their platforms form part of the parameter in platform governance. This is the second dimension in Gillespie's terms, ‘governance by platforms’. It refers to platform policies and their algorithms in regulating online content and user behaviours, out of economic considerations as well as public obligation in nurturing healthy communities on their platforms. In other words, digital platforms are self-governed and governed by nation-states at the same time. They enact regulatory frameworks not simply to meet legal requirements or placate advertisers to maximise profits but also to protect their corporate image and honour their own corporate ethics.

Popiel and Sang (2021)'s research on policy preferences of platform companies like GAFA suggests the merging of platform co-governance (with state regulators) and self-governance regimes and as such enabling them to assume more power as policy actors rather than simply business entities, particularly in electoral politics, content moderation, and cybersecurity. They are open to the multi-stakeholder model in platforms’ governance, which includes partnership with national governments and civil society organisations. Such private-public partnership is characterised by what Popiel and Sang (2021: 12) call ‘frictionless regulation’: a necessary but light and narrow regulatory oversight from state regulators; it ‘accepts errors, prioritizing quick action and experimentation over carefully designed regulatory framework’ (ibid); and it is characterised by tech solutionism.

Governance of platforms and governance by platforms are interconnected and mutually constitute each other. As Gorwa (2019)'s study of the ‘governance triangle’ model (state, NGO, and industry) suggests, platform governance goes beyond the formal channels and space of the formal arrangements, particularly in regulating online content. The multi-stakeholder regulatory framework does not automatically guarantee effective platform governance in practice. There are other important factors like ‘the legitimation politics between informal arrangements and traditional regulation or other informal arrangements, the importance of the varying regulatory competencies that different actors bring to the table, and the dynamics of power, authority, and coercion between actors in the implementation of informal governance measures’ (Gorwa 2019: 12). Such an understanding will help us navigate the complex relationships of contestation, negotiation and bargaining across key stakeholders, often carried out behind the scene.

Platform government in the Chinese context takes a different trajectory, because of the intrusive role of the state, the dominance of the state in setting the parameter of discourse and policies in Internet governance, and the techno-nationalist shaping of the Chinese information and communication technologies. Platform companies are regarded as a core component in China's ‘networked authoritarianism’ (MacKinnon, 2011); their market power is filtered through institutionally fragmented Chinese party-state and supported by the state to meet its goal of legitimacy through economic performance and technological innovation (McKnight et al., 2021). Platform companies in the meanwhile adopt the collaborative approach with regulatory authorities and operate in the government's orbits as public-good utilities while pushing their datafication and infrastructuralisation strategies to increase their market power (e.g. Chan and Kwok 2021). Through platformisation of cultural production and the economy, platform governance is intertwined with social governance. It is characterised by the complex interplay between digital platforms and the state, “between datafication and affordance, between money and meaning, and between surveillance and security” (de Kloet et al., 2019: 253).

Platform governance in China plays the canary's role in a coal mine to signal the changing conditions in social, economic, and technological governance. This is demonstrated by China's new regulations of technology companies and digital platforms since 2021. The re-tightening regulations of big tech companies focuses on market monopoly, data and algorithm security, fintech regulation, and digital labour (Wang, 2022). The Chinese move from online content governance to data and fintech governance illustrates the recognition by Chinese authorities of data security and fintech development as national security (Wheeler, 2021). This, together with its promotion of consumer welfare and gig workers’ rights and effort to curb market concentration, goes against the anti-regulation rhetoric and the multi-stakeholder co-governance framework in the West and sends a strong message to national governments around the world in their search for effective ways to govern digital platforms in their countries.

Guided by the platform governance framework, this article examines WeChat and TikTok as examples of non-Western platforms that are stuck between two opposite spectrums in platform governance: the ‘broad immunity’ of the US model with regard to the liability of online intermediaries for their online content and ‘strict liability’ model of China referring to state's total control over platform governance (MacKinnon et al., 2014). It is important to understand how these two Chinese platforms develop their platform governance regimes in response to the evolving local market and politics in Australia, particularly amid the hawkish rhetoric calling for ‘reining in China's technology giants’ in the country (Ryan et al., 2021).

Made-in-China digital platforms in Australia

China's tech companies and their digital platforms are on the frontiers of Chinese state-capitalist expansion and national economic restructuring (Hong, 2017), and have become part of a ‘digital empire in the making’ (Keane and Yu, 2019). Like Western/US digital platforms, the logic of capitalism, expansionism and dataism have characterised tech companies’ daily operations, global marketing, financing and investment strategies (Fuchs, 2016; Jia and Winseck, 2018; Xia and Fuchs, 2016). They often assert a mercantilist imperative to capture new markets and ‘obtain greater integration and control over their supply and value chain’ (Wang and Lu, 2016: 4). Tencent and ByteDance represent two different modus operandi when made-in-China digital platforms go overseas. One adopts ‘one app, two systems’, while the other operates on the principle of complete separation—what we call ‘two apps, two systems’.

Launched in August 2012, WeChat is the English name and international version of Weixin (launched in January 2011) owned by Tencent. WeChat/Weixin is known as the ‘digital Swiss Army knife for modern life’ (Lee, 2018) and a ‘super-sticky all-in-one app’ (Chen et al., 2018). It combines many of the functions of Facebook, Twitter, WhatsApp, Instagram and PayPal with additional features of e-payment, e-commerce, e-lifestyle and e-government. WeChat is designed for non-Chinese mobile users outside mainland China, governed by local (not Chinese) laws and operated by WeChat International (Singapore). Weixin is designed for Chinese mobile users, governed by PRC law and operated by its Chinese entity (Shenzhen). The phone number used for registration decides whether it is a Weixin or WeChat account. In addition to different governing laws, terms of service and privacy policies, Weixin and WeChat utilise different server architectures. Unlike Weixin, WeChat servers are all located outside mainland China. This style of operation is ‘a conscious decision designed to serve different users while ensuring compliance with applicable laws across different jurisdictions’ (WeChat International, 2020).

WeChat is the most popular social media platform among the Chinese diaspora in Australia, with ‘approximately 690,000 daily active users in Australia based on IP address and registered Australian mobile phone number’ (WeChat International, 2020). Research has shown that WeChat/Weixin is the most used social media platform among Chinese living in Australia, followed by Weibo and Facebook, with 92% (573 out of 623 respondents) reporting hourly and daily access. These statistics are based on surveys conducted in 2018 and 2019 among Mandarin-speaking migrants from China on their media access and usage patterns, habits and preferred platforms or sources (Sun and Yu, 2020). WeChat subscription accounts were identified by 60.31% of survey participants as their primary source of news and information (followed by news media websites, Facebook and Twitter), with 51.22% checking their accounts daily (ibid). Many first-generation migrants rely on WeChat/Weixin to communicate with people in China and among members of the Chinese community. Those without sufficient English-language proficiency use WeChat/Weixin to get news and information in Chinese, which is consistent with other migrants relying on their own ethnic/community media for news, particularly during the pandemic.

In contrast to Tencent's ‘one app, two systems’ arrangement for WeChat/Weixin, ByteDance operates on the principle of ‘two apps, two systems’ for TikTok and its Chinese counterpart Douyin. Launched in September 2017, TikTok is the brand used outside China and develops in parallel with its domestic twin Douyin (released in September 2016). The two apps do not overlap or interoperate; they are separate entities headquartered in Beijing and Culver City (California), respectively. Chinese app stores only offer Douyin, while non-Chinese app stores only offer TikTok. Kaye et al. (2021) argue that the co-evolution of Douyin and TikTok is a new paradigm of global platform expansion that differs from previous major social media platforms’ strategies of regionalisation. It uses the concept of parallel platformisation to explain ByteDance's strategies for surviving in two opposing platform ecosystems in China and abroad.

The ‘radical’ separation of TikTok from its domestic counterpart from the onset has contributed to its success in the global market, mostly seen in its wider reach (compared with WeChat) into non-Chinese speaking populations globally, including Australia. TikTok is the most downloaded app globally and enjoys the highest popularity among Generation Alpha (born between 2010 and the mid-2020s) and Generation Z (born between 1995 and 2009). It is available in 75 languages in 155 countries, with over one billion active users worldwide (Iqbal, 2021).

Australia is a relatively small market for TikTok, with 1.6 million users as of February 2020 (Roy Morgan, 2020) accounting for about 1.6% of their global users. To date, it is the only Chinese digital video platform that has landed successfully in the mainstream Australian market. Many Australians and Australian businesses have become visible on the app (Masige, 2014). In June 2020, the company opened its Australian office in Sydney intending to grow the down-under TikTok business. A growing number of Australian young people have made a profitable career on the platform as top TikTokers or TikTok influencers, becoming middle- to high-income earners in Australia through gifting, brand sponsorship, events and e-commerce/transactions (Lu, 2021).

In sum, WeChat and TikTok are distinctive Chinese digital media platforms that have garnered substantial followings and market success in Australia, albeit in different ways. Market observers have championed Chinese digital companies’ leading role in technology and business innovation (Poo, 2019). However, the road to becoming truly global players competing with US-led platforms is laden with challenges, as we discuss in the next section.

Chinese platformised influence in Australia

In recent years, Chinese tech champions’ drive to expand overseas has been met with suspicion and resistance over their connection with the Chinese government, often around data sovereignty and national security issues, amid the rising ‘China threat’ narrative and geopolitical tension between China and the US (and its allies). Chinese platforms are regarded by hawkish Western commentators as Trojan horses that enable the Chinese government's control of data and export of China's digital authoritarianism (Cave et al., 2019). It is believed that while most of the Chinese tech firms expanding abroad are private firms, they cannot distance themselves from China or escape of the Chinese Communist Party's (CCP) powerful influence across many businesses, from content regulation to market prioritisation (Stec, 2018). Chinese digital platforms are seen as data dominant oligopolies (Mayer-Schönberger and Ramage, 2018) and empire builders working with and alongside the Chinese state in its ‘going-out’ strategy. Such political baggage associated with the authoritarian state and communist ruling party weighs down Chinese enterprises’ ambitions to go global. We have seen this in a series of controversies concerning Chinese tech companies and platforms, from the disputes over Huawei's foreign influence and Alibaba's technology transfer and intellectual property rights (Hong and Xu, 2019), to accusations of TikTok over its control of data and WeChat over Beijing's propaganda on one hand and their supposed interference in Australian domestic politics through misinformation on the other (Cave et al., 2019; Sear et al., 2018; Zhang, 2017). Such global scrutiny of Chinese digital platforms has been front-page news since July 2020, first with India's ban of TikTok and WeChat along with 57 other Chinese apps and then with Trump's executive orders banning any US transactions with WeChat operator Tencent and TikTok operator ByteDance.

Global users’ anxiety and confusion over the Chinese origin and connection of WeChat and TikTok are widespread in the West, including Australia. Despite being the most popular social media platform among Chinese migrants in Australia and playing a constructive role in civic and citizenship education among Mandarin-speaking first-generation Chinese migrants (Sun and Yu, 2020), WeChat is regarded by Australian conservative politicians and rightist media as a security risk. It has been banned for government employees. Some media organisations also ban their staff from using WeChat for work. WeChat is also blamed for interfering in Australian local politics by a former backbencher staffer of Chinese background in New South Wales through a WeChat group, in which two Chinese scholars and two Chinese media officials are involved (Rubinsztein-Dunlop and Hui, 2020).

Apart from being framed as part of China's ‘influence’, WeChat is often accused of censorship practices in Australian and Western media. It is described as a ‘trap for China's diaspora’ (Wang, 2020), which forces users to practice self-censorship even after they have migrated to another country. Such a claim is misleading as it conflates WeChat with Weixin. As discussed earlier, Weixin and WeChat are ‘two systems’ that operate on ‘one app’: they are interoperable and interchangeable; that is, a Weixin user and a WeChat user can interact and communicate with each other on the same platform. Chinese in Australia use either WeChat or Weixin. They often interact and mingle in group chats without knowing or checking who are Weixin or WeChat users until they encounter censorship.

Weixin accounts are under terms of service and privacy policy in the jurisdiction of China and are subject to Chinese censorship. Censorship persists for Weixin accounts even if the account holder has migrated to another country. In principle, WeChat accounts are not subject to China's content censorship, even when interacting with a Weixin account in the same chat groups. For example, a WeChat account can post and share anything (including content censored by Weixin), and it can view anything posted by a Weixin account. However, the Weixin account is under Chinese censorship and therefore cannot post or see censored texts and images sent by the WeChat account. We call this ‘targeted censorship policy’. Yet, Ruan et al. (2016) found that while WeChat accounts are not under political censorship, documents and images sent from WeChat accounts are nevertheless under political surveillance, and this content is used to invisibly build up the Weixin censorship system for China-registered accounts.

Some also view TikTok as ‘a vector for censorship and surveillance’ (Ryan et al., 2019). Lawmakers in the US are worried about how TikTok handles the data it gathers on its US-based users (Roumeliotis et al., 2019) and what the Chinese company would do to help the Chinese government's broader artificial intelligence and data ambitions to conquer the world. The claim that ByteDance is advancing Chinese foreign policy objectives abroad through TikTok is echoed in Australia. TikTok is under scrutiny for its ties to China, with some of Australia's ‘top cyber and national security minds warning the app could potentially be used by Beijing authorities to influence and monitor millions of Australian users’ (Tobin, 2020).

The public scrutiny of these Chinese platforms intensified in Australia in 2020 amid the potential WeChat and TikTok ban in the US. On 5 December 2019, the Australian Senate convened a ‘Select Committee on Foreign Interference through Social Media’ to conduct inquiries into the potential risks posed to Australia's democracy by foreign interference through social media platforms including TikTok, with particular reference to the spread of misinformation. In September 2020, TikTok fronted the Senate inquiry again and submitted evidence to address key concerns raised over the platform's China connection. TikTok Australia vehemently denied such a connection: ‘We really, really promise we’ve got nothing to do with China’ (Wilson, 2020). TikTok's submission to the inquiry detailed its data governance regime—its user data is stored on servers located in the US and Singapore—to address the cybersecurity concerns and distance itself from its Chinese twin Douyin. It further emphasised the procedural requirements for cross-border data access for law enforcement. Any request for Australian TikTok user data needs to go through a mutual legal assistance treaty process, an inter-state agreement established over terms of managing cross-jurisdictional requests for evidence.

To further distance itself from China, TikTok emphasised itself as a privately owned global company, whose major international investors include Sequoia Capital, General Atlantic and Softbank, also investors of Google, Apple and Uber. By emphasising the private nature of the company and the global nature of its investors, TikTok has depoliticised its existence and strategically aligned itself with transnational tech capital whose operations often transcend geographical boundaries. A similar kind of ‘globalism’ is alluded to when the company emphasises that its board of directors comprises two Chinese citizens, two US citizens and a French citizen.

In addition to foregrounding its ownership structure and board of directors, TikTok Australia stresses its integration into the global tech regime, compliance with ‘Silicon Valley’ norms and standards, and localisation (of content and legal support team) and transparency efforts. It has hired a US law firm to develop and improve its community guidelines and opened a transparency and accountability centre in Los Angeles. Further, like Facebook's Oversight Board, which brought together outside experts and civic leaders, TikTok has formed a Content Advisory Council that aims to incorporate industry experts, academics and civil society organisations to improve their content moderation policies. TikTok Australia also engages with its American and global counterparts as part of its globalism policies. For example, following a senator's interrogation of viral suicide videos on TikTok, Hunter Lee responded that ‘one of the things that would have been helpful in this regard is collaboration across platforms. Recently, we wrote to the heads of some of our peers, including Google, Facebook, Twitter, Pinterest, Reddit and others, proposing a memorandum of understanding’ (Senate Select Committee, 2020, our emphasis).

The Trump administration's attempted ban of the two apps in the US market¹ and increasing tension between China and the US have immediate repercussions in Australia, as seen in the Australian Senate inquires. Facing scrutiny from the Australian public, both WeChat and TikTok have adopted distancing strategies in their technical, marketing, financing, legal and consumer market operations by marking themselves out from their Chinese twins (Weixin and Douyin, respectively). Further, both have stressed their General Data Protection Regulation compliant privacy policy, their compliance with international standards in consumer data protection (e.g. their overseas servers and data centres for international users), and good citizenship in content moderation. The backlash against the two platforms prompted by the potential ban in the US market has prompted WeChat to clarify its ‘one system, two apps’ policy by updating the terms of services and privacy policies for both WeChat and Weixin and clarify ambiguity over account registration, as elaborated in the next section.

Governing made-in-China platforms

As already noted, the biggest challenge for Chinese tech companies outside the PRC is arguably Western countries’ suspicion, if not hostility, towards China's presence and influence in key infrastructure and cyberspace governance projects. Meanwhile, Chinese platforms have tried to brand themselves as private and transnational businesses and distance themselves from the Chinese government. How Chinese platforms respond to the geopolitical–economic dynamics will be a crucial indicator of their evolving platform governance regimes.

The geopolitics of WeChat and TikTok in Australia (and the West generally) is entangled with the discourse of how the country frames platform governance amid a global trend moving away from an industry self-regulatory model towards increased governmental intervention and multi-stakeholder approach—’understood as the set of legal, political, and economic relationships structuring interactions between users, technology companies, governments, and other key stakeholders in the platform ecosystem’ (Gorwa, 2019: 2). As discussed in the introduction, there are two dimension of platform governance: governance of platforms and governance by platforms (Gillespie, 2017). Governance of platforms is normally regarded as the responsibility of nation-states, even though corporations and the states are often entangled in their political and commercial interests. Governance of platforms in Australia has been lacking for many years, until recently when the Australian government started taking measures to regulate online news content and misinformation. Social media platforms have since been subject to increasing scrutiny for allowing fake news, misinformation and inappropriate content during significant events such as the federal election and COVID-19 pandemic (e.g. Pickles et al., 2021; Warren, 2020).

In early 2021, Australia became the first country in the world to make Google and Facebook pay for news content on their platforms with the News Media Bargaining Code, after Google threatened to leave Australia and Facebook temporarily blocked Australian users from sharing or viewing news content on its platform in response to the proposed Code (Khalil, 2021). The Code applies to the two tech giants but may include other platforms in the future. This peculiar arrangement between news organisations and tech companies is mediated and pushed through by the government. Domestic political concerns primarily drive such platform governance: the Australian centre-right government is more concerned about the news and dominant mainstream media influencing things such as elections (Cave, 2021).

From the perspective of platform governance, Chinese platforms may concern Australian regulators because of their Chinese background and association with the so-called Chinese influence in Australia rather than their market power or influence, as Google and Facebook are a duopoly in the country's digital advertising revenues. The Australia Competition and Consumer Commission's 2019 Digital Platforms Inquiry mainly focused on the American duopoly. TikTok was only mentioned once in the report—as one of Facebook's major competitors rather than recognition of the platform itself.

Australian regulators are concerned about the impact of digital platforms on the quality and choices of news and journalism supplied to consumers by digital platforms (Australian Communications and Media Authority, 2020). The Australian government has taken a voluntary regulatory pathway to tackle fake news, launching a voluntary code of practice on disinformation by Digital Industry Group Inc. in February 2021. However, the code of practice does not solve the platforms’ siloed approach in response to balancing freedom of expression online against misinformation and cybercrimes. Similar to their Western counterparts, WeChat and TikTok have adopted user self-regulation as alternatives to government intervention in Australia while simultaneously collaborating with civil society actors and government players to manage the harms caused by misinformation. Empowering users to manage fake news and misinformation is also a strategy to mitigate unwanted attention on its association with their Chinese twins.

WeChat and TikTok fall outside this regulatory purview, given their influence is limited to the Chinese community or entertainment. Yet, both are subject to pressure from the Australian public for their roles in spreading misleading content and subsequently causing social harm. This is particularly so for WeChat, a predominantly Chinese diaspora social media platform that carries news content through private chat groups, Moment (similar to Facebook's News Feed) and subscription accounts. WeChat subscription accounts are only available to Weixin users with Chinese citizenship and therefore are under the direct control of Chinese authorities in content censorship.² Such content censorship, however, applies mainly to topics or issues related to Chinese domestic affairs and politics, not electoral politics in foreign countries. As such, WeChat has been criticised for spreading misinformation during the US 2016 presidential election (Zhang, 2017). In Australia, it has been accused of allowing fake news and disinformation in its private chat groups and semi-closed ‘Moments’ about Australia's 2019 elections, COVID-19 outbreak and COVID vaccines, and blamed for undermining the diversity of political discussions and Australian democracy (Chan and Zhang, 2021; Sun, 2020b; Xiao et al., 2021). In response, WeChat Australia emphasises its user complaint mechanism as the main channel to raise concerns of and deal with misinformation, but has not resorted to tech solutionism, such as the use of keyword censorship algorithms in combatting ‘rumour’ and ‘disinformation’ (as per the practice of Weixin).

Although not a ‘Chinese’ app in terms of its user demography (mostly among Gen Alpha and Gen Z beyond the Chinese-speaking population), TikTok is under pressure to tackle harmful user-generated content on its platform, particularly in the context of COVID-19 misinformation. Like WeChat, users are asked to flag content for misinformation or violating any of the community guidelines (developed by a US law firm). TikTok content moderators then do fact checks, working with third-party partners at PolitiFact and Lead Stories (Marquez, 2021). When unable to verify content, TikTok adds a banner to the post to warn users of unverified information and notify with a ‘caution’ icon before sharing it (Marquez, 2021).

Both platforms have adopted the multi-stakeholder approach in platform governance. WeChat International (2020) has announced that it will appoint a senior legal representative as the contact point of public engagement in Australia (McIlroy, 2021). TikTok has made efforts to increase content transparency by publishing transparency reports since 2019 and establishing transparency and accountability centres in Los Angeles, Washington DC and Dublin in 2020 and 2021, respectively. It has also worked with its Content Advisory Council to improve its platform governance (TikTok, 2020b). In Australia, TikTok has introduced a third-party fact-checking program, with a team of global fact-checkers who review and verify reported content across 16 languages (TikTok, 2020b). It has also worked with public health organisations and Australian industry players and regulators to push authorised information to users through its information resource pages, public service announcements and hashtags. This ‘guiding’ strategy works alongside ‘impeding’ tactics through content recommendation algorithms (limiting suggesting misinformative hashtags), a warning banner (mentioned above) and the in-app user reporting function (similar to WeChat).

Like platforms such as Facebook, TikTok adopts an industrial approach to content moderation where tens of thousands of moderators are employed to enforce rules made by a separate content policy team and hence regulate its users’ online speech and behaviours (Caplan, 2018). TikTok's latest Transparent Report reveals that in the second half of 2020, the company removed 89,132,938 videos globally that were flagged as violating their community guidelines or terms of service, either by its users or internally by its human workforce or automated technology (TikTok, 2020b). In addition to filtering and removing content, the company also governs its content by regulating its (in)visibility to the public. As stated in its community guidelines, TikTok (2020a) ‘may reduce discoverability, including by redirecting search results or limiting distribution in the For You feed’ for content that could be considered ‘upsetting or depict things that may be shocking to a general audience’. Companies such as YouTube have exercised a similar approach, known as shadowbanning, claiming that ‘we’ll begin reducing recommendations of borderline content and content that could misinform users in harmful way’ (Lapowsky, 2019).

Despite the similarities in the governance of platforms and platform responses, there is a significant difference between WeChat and TikTok in the ‘governance by platforms’ practices. With its ‘one system, two apps’ arrangement for WeChat and Weixin, Tencent has created a calculated confusion and precarity among users, which is subsequently beneficial in regulating content and user behaviours on its platform. As discussed earlier, Weixin enables content filtering if a Chinese mobile phone number is used to register, even when the account holder travels or migrates overseas. This means Chinese international students, tourists, visitors, academics and business travellers attending international meetings and events, and new Chinese migrants—all Weixin users—remain within the same bounds of content control and censorship even when physically outside PRC borders. This has caused lots of confusion and complaints among international Weixin users, including Chinese migrants to Australia, who feel their freedom of speech under their local jurisdictions (such as Australia) is violated by the Chinese platform's censorship regime. This has been the main argument of the Trump's attempted ban of WeChat.

To solve the problem and avoid future accusations from international users, in September 2021, Tencent updated the terms of services and privacy policies for both Weixin and WeChat. It asked previous Weixin accounts registered with non-Chinese mobile phone numbers to either migrate to WeChat and accept WeChat terms of services (and hence lose some of the services only available to Weixin users) or change their international phone numbers to Chinese phone numbers to continue as Weixin users and subject to Weixin terms of services (including its censorship regime). Once a user chooses to migrate to WeChat, it takes 10 days for their previous Weixin data to migrate to overseas WeChat servers (located in Singapore and Europe). Most Chinese living in Australia have chosen to keep their Weixin accounts because they do not want to lose all contacts associated with their Weixin accounts. Some have chosen to register WeChat accounts with their Australian phone numbers and use them alongside their old Weixin accounts.

Hence we have witnessed a curious situation among Weixin/WeChat users in Australia. Many people continue to use their Weixin accounts while complaining about censorship on the Tencent platform. Those with both Weixin and WeChat accounts often post innocuous content with their Weixin accounts and politically sensitive topics with their WeChat accounts. Meanwhile, those with only WeChat accounts—although not under direct Weixin censorship—complain about Weixin censorship, as their posts sometimes cannot be seen by Weixin accounts in the same chat groups if deemed ‘sensitive’ and therefore blocked by Weixin censorship algorithms. In other words, although there is no direct political censorship for WeChat accounts, they encounter censorship and truncated communication with Weixin users on the same platform.

The WeChat/Weixin-style governance by platform is characterised by precarity and paradox for Australian content providers. The direct Weixin content censorship and indirect WeChat content surveillance have worked together to nudge users to shy away from discussing Chinese politics to focus on ‘light’ topics such as lifestyle, entertainment, Australian civic affairs and policies. The cross-over operation between WeChat and Weixin is hence a calculated platform governance strategy by Tencent, which ultimately works to discipline both WeChat and Weixin users while still claiming separate governance regimes for the two apps.

Conversely, ByteDance operates on the principle of parallel platformisation and governs TikTok and Douyin as two separate platforms with separate content moderation regimes over user-generated content. It has invested hugely in content moderation for Douyin and developed sophisticated censorship algorithms and tools that automatically detect sensitive content, such as ethnic languages and dialects in livestreaming, or help low-level content moderators filter out content the Chinese government considers politically dangerous and morally hazardous (Lu, 2021). In contrast, TikTok does not apply the same censorship regime. Its content moderation is limited to restricting search results for hate speech, suicide prevention and misinformation, similar to many of its Western counterparts. A series of research on TikTok, such as the Australian Strategic Policy Institute (September 2020), Jia and Ruan (2020), and Lin (2021) of the Citizen Lab, have looked into its privacy and censorship governance. They are inclusive as to whether TikTok has employed any censorship of user posts if it did so in the past (e.g. Robertson, 2019). It is found that TikTok is ‘attentive to users from different geographical regions by designating jurisdiction-specific privacy policies and terms of service’ and does not employ overt political censorship (Lin, 2021).

Conclusion

WeChat and TikTok are part of Australia's multicultural social media ecosystem, alongside Line (used by Japanese migrants), VK (popular among Russian migrants) and WhatsApp (popular among Southeast Asian migrants). The backlash against WeChat and TikTok in the West is driven by political and economic concerns, as both represent a serious challenge to the Western online advertising duopoly of Google and Facebook. Their parent companies, Tencent and ByteDance, are advertising juggernauts, important nodes and disruptors in the global financial networks and infrastructure. Their access to massive quantities of user data (in and outside China) and their artificial intelligence-powered advanced algorithms—on China's list of export-controlled products (Brandom, 2020)—have made Silicon Valley very nervous (Sun, 2020a). WeChat and TikTok could fundamentally shift trade and financial flows towards a China-centric economic order, realign technological systems and platform governance with a Sinophone standard and potentially influence foreign domestic politics where they have a sizeable market. The scrutiny of WeChat and TikTok (and engineering distrust of all made-in-China apps); attention to digital surveillance, data security and privacy; regulation of speech on platforms; and government sponsorship (implicit or explicit) of new technologies are all part of the battle and information warfare in the new tech cold war (Jeong, 2020).

In response to the new dynamics in geopolitics and the emerging platform governance framework in Australia, WeChat and TikTok have adopted a distancing strategy by emphasising their separate content, user and data governance regimes from Weixin and Douyin, respectively. Such a response to platform governance creates a dual structure in which Chinese platforms manage their branding and operations differently inside and outside China. This dual structure allows Chinese tech capital to reach deeper into the global market while avoiding potential breaches of China's stringent content rules. Both WeChat and TikTok have adopted a more relaxed approach to self-regulation of content than their Chinese counterparts, and in the case of TikTok even more so than their Western counterparts. While Western platforms recommend their content moderators err on the side of caution and remove content when the age of subjects it features is unclear, TikTok's default position is to treat subjects as informed users who have complied with its terms of services and hence over 18 years (Hern, 2019). This lax attitude is underpinned by its desire to comply with the Silicon Valley ethos by adopting a more ‘liberal’ free-speech approach to online content. Yet, the motivation to ‘fit in’ can ironically end in overly permissive content that flouts Western protocols of platform moderation.

WeChat, on the other hand, adopts a mixed approach to its cross-platform governance regime: ‘mixed’ because of its crossover with Weixin in user engagement and content regulation practices. It creates calculated confusion and precarity among its international users who encounter and live with content censorship regularly via WeChat subscription accounts in terms of content censorship and via Weixin users who interact with them on the same platform. Despite the in-app user reporting mechanism and its willingness to engage with Australian authorities via a third-party local representative, WeChat is still guilty of either lack of or too much platform oversight of misinformation or content censorship in its international markets. Its close link with its Chinese twin and embeddedness in the Chinese platform governance regime will continue to be its sword of Damocles.

Under the legal constraints of Western countries like Australia, both WeChat and TikTok have relegated the responsibility for identifying and flagging misinformation to users and local third-party players while claiming to commit to freedom of speech and content transparency. The two cases illustrate the continuing tension between the Chinese ‘strict liability’ model and the Western ‘broad immunity’ model in platform governance. Their localisation strategies and attempts to self-brand as responsible and ethical global players are closely observed, even quietly copied, by other made-in-China platforms in their outbound activities and overseas markets.

Footnotes

Declaration of Conflicting Interests

The author(s) declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.

Funding

The author(s) disclosed receipt of the following financial support for the research, authorship, and/or publication of this article: This work was supported by the Australian Research Council, (grant number DE210100092, FT200100100).

ORCID iD

Haiqing Yu

Notes

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