The Chinese Social Credit System (SCS), known as the first national digitally-implemented credit rating system, consists of two parallel arms: a government-run and a commercial one. The government-run arm of the SCS, especially efforts to blacklist and redlist individuals and organizations, has attracted significant attention worldwide. In contrast, the commercial part has been less often in the public spotlight except for discussions about Zhima Credit.
The commercial arm of the SCS, also referred to as the Consumer Credit Reporting System (CCRS), has been under development for about two decades and took a major step forward in 2015 when 8 companies were granted permission to implement pilot consumer credit reporting programs. This development fundamentally increased the reach and impact of the SCS due to these companies’ sizable customer base and access to vast troves of consumer-related information.
In this paper, we first map the Chinese CCRS to understand the actors in the credit reporting ecosystem. Then, we study 13 consumer credit reporting companies to examine how they collect and use personal information. Based on the findings, we discuss the relationship between the CCRS and the SCS including the changes in the power relationships between the government, consumer credit reporting companies and Chinese citizens.
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 01caijing, The old-brand credit reporting entity: Claimed to have data covering 1.3 billion people which was more than that in the Credit Reference Center PBoC, available at https://www.01caijing.com/article/4988.htm, August 5, 2016. Last accessed on June 9, 2020. (in Chinese)
 S. Abraham, and E. Hickok, Government access to privatesector data in India, International Data Privacy Law, 2(4): 302–315, 2012.
 J. Cao, Protecting the right to privacy in China, Victoria University of Wellington Law Review, 36(3): 645–664, 2005.
 F. H. Cate, J. X. Dempsey, and I.S. Rubinstein, Systematic government access to private-sector data, International Data Privacy Law, 2(4): 195–199, 2012.
 Y. Chen, Zhima Credit admitted that using the default option of opting in to Zhima Credit in Alipay’s annual bill was wrong, The Paper, available at: https://www.thepaper.cn/newsDetail_forward_1934070, January 4, 2018. Last accessed on June 12, 2020. (in Chinese)
 Y. Chen, Zhima Credit: Not thinking about making profits in two to three years, no data exchange with Baihang Credit, The Paper, available at: https://www.thepaper.cn/newsDetail_forward_4827406, October 31, 2019. Last accessed on March 3, 2020. (in Chinese)
 Y. Chen and A. Cheung, The transparent self under big data profiling: Privacy and Chinese legislation on the social credit system, The Journal of Comparative Law, 12(2): 356–378, 2017.
 China Internet Network Information Center (CCNIC), The 45th China Statistical Report on Internet Development, April 2020. (in Chinese)
 M. Chorzempa, P. Triolo, S. Sacks, China’s social credit system: A mark of progress or a threat to privacy?, Policy Briefs PB18-14, Peterson Institute for International Economics, 2018.
 Credit Reference Center, An Operation Report of Credit System Construction (2004-2014), The People’s Bank of China, 2015. (in Chinese)
 R. Creemers, China’s social credit system: An evolving practice of control, available at: SSRN 3175792, 2018.
 X. Dai, Toward a reputation state: The social credit system project of China, available at: SSRN 3193577, 2018.
 S. Engelmann, M. Chen, F. Fischer, C. Kao, J. Grossklags, Clear sanctions, vague rewards: How China’s social credit system currently defines good and bad Behavior, Proceedings of the ACM Conference on Fairness, Accountability, and Transparency, 2019.
 General Administration of Quality Supervision, Inspection and Quarantine and Standardization Administration, The standardization administration of China, Information Technology Personal Information Security Specification, GB/T 35273-2017, 2017. (in Chinese)
 H. Harkous, K. Fawaz, R. Lebret, F. Schaub, K. Shin, and K. Aberer, Polisis: Automated analysis and presentation of privacy policies using deep learning, Proceedings of the 27th USENIX Security Symposium, 2018.
 D. He, Y. Zhang, L. Zhang, D. Zhang, An industry report of Chinese consumer credit system, The Boston Consulting Group, 2016. (in Chinese)
 R. Hillman, Consumer credit: Limited information exists on extent of credit report errors and their implications for consumers, Statement for the Record Before the Committee on Banking, Housing, and Urban Affairs, U.S. Senate, 2003.
 S. Hoffman, Programming China: The Communist Party’s autonomic approach to managing state security. Merics China Monitor, 44: 1-12, 2017.
 C. Hoofnagle, Big brother’s little helpers: How ChoicePoint and other commercial data brokers collect and package your data for law enforcement, North Carolina Journal of International Law and Commercial Regulation, 29(4): 595–637, 2003.
 National Development and Reform Commission (NDRC), National Development and Reform Commission and Ant Financial signed a Memorandum on Cooperation for the Implementation of Joint Incentive and Punishment, available at NDRC’s website https://www.ndrc.gov.cn/fzggw/jgsj/cjd/sjdt/201608/t20160803_1111383.html, August 3, 2016. Last accessed on March 4, 2020. (in Chinese)
 M. Ohlberg, S. Ahmed, B. Lang, Central planning, local experiments: The complex implementation of China’s social credit system, Merics, 2018.
 R. Olegario, The Engine of Enterprise: Credit in America, MA: Harvard University Press, 2016.
 Y. Pu, and J. Grossklags, Towards a model on the factors influencing social app users’ valuation of interdependent privacy, Proceedings on Privacy Enhancing Technologies, 2016(2): 61-81, 2016.
 M. Rhoen, Beyond consent: Improving data protection through consumer protection law, Internet Policy Review, 5(1): 1-15, 2016.
 N. M. Richards, A. B. Serwin, and T. Blake, Understanding American privacy, in G. González Fuster, R. van Brakel and P. De Hert (eds.), Research Handbook on Privacy and Data Protection Law: Values, Norms and Global Politics, Edward Elgar Publishing, 2018, available at https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3256918.
 A. Schmitz, Secret consumer scores and segmentations: Separating haves from have-nots, Michigan State Law Review, 2014(5): 1411–1473, 2014.
 S. Shorey and P. Howard, Automation, big data, and politics: A research review, International Journal of Communication, 10: 5032-5055, 2016.
 State Council, Planning Outline for the Construction of a Social Credit System (2014-2020), June 2014. (in Chinese)
 J. Turow, C. Hoofnagle, D. Mulligan, N. Good and J. Grossklags, The Federal Trade Commission and Consumer Privacy in the Coming Decade, I/S: A Journal of Law and Policy for the Information Society, 3(3): 723-749, 2008.
 L. Ulbricht and M. von Grafenstein, Big data: Big power shift?, Internet Policy Review, 5(1): 1-15, 2016.
 J. Van Dijck, Datafication, dataism and dataveillance: Big data between scientific paradigm and ideology, Surveillance & Society, 12(2): 197-208, 2014.
 Z. Wang, Systematic government access to private-sector data in China, International Data Privacy Law, 2(4), 220–229, 2012.
 J. Weidman and J. Grossklags, What’s in Your Policy: An Analysis of the Current State of Information Security Policies in Academic Institutions, Proceedings of the 26th European Conference on Information Systems (ECIS), 2018.
 Xinhua, Alipay health code was implemented in over 100 cities in 7 days; the digitalisation of epidemic prevention is characterised by “China Speed”, available at: http://www.xinhuanet.com/tech/2020-02/19/c_1125596647.htm, February 19, 2020. Last accessed on March 11, 2020. (in Chinese)
 Y. Xu, None of the eight companies was qualified for the license for running consumer credit reporting business after the two-years experiment, Yicai, available at: https://www.yicai.com/news/5271750.html, April 23, 2017. Last accessed on June 10, 2020. (in Chinese)
 Z. Zhang, Institutional Construction for social credit system in the era of big data, Credit Reference, 9(212), 58-61, 2016.
 R. Zhong, China’s virus apps may outlast the outbreak, stirring privacy fears, The New York Times, available at: creditchina.gov.cn/gerenxinyong/?navPage=14, May 26, 2020. Last accessed on June 9, 2020.
 S. Zuboff, Big other: Surveillance capitalism and the prospects of an information civillization, Journal of Information Technology, 30(1), 75-89, 2015.