Internet Control or Internet Censorship? Comparing the Control Models of China, Singapore, and the United States to Guide Taiwan’s Choice

Internet censorship refers to a government’s unjustified scrutiny and control of online speech or government-approved control measures. The danger of Internet censorship is its chilling effect and substantial harm on free speech, a cornerstone of democracy, in cyberspace. This article compares China’s blocking and filtering system, Singapore’s class license system, and the United States’ government-private partnership model and identifies the features of each model. This article also explores the pros and cons of each model under international human rights standards. By finding lessons from each of the models, this article contends that Taiwan should retain its current minimal Internet control model. Further, Taiwan should fix flaws in its current Internet control system, including the private partnership model adopted by the Copyright Act, to be consistent with Article19.3 of the ICCPR.