The landmark 2014 policy on social credit touched briefly on what data would be included in social credit records of government entities and officials:
“Bad behavior such as favoritism, perverting the law and [lying by] omission should be included in these records according to law and regulations, and used as the basis for assessment, reward and punishment.”
Mention was also made of setting up special archives to collect data on lawyers, judges, public security personnel, notaries and other legal professionals. 1
Beyond that, there are few specifics on exactly how government data will be gathered at the national level. But we do have one source that clearly maps out how this information is gathered in Shanghai.2 Since the lower-level social credit systems typically mirror the national level system, a look at the Shanghai model gives us the clearest picture of how government integrity data is likely to be gathered nationwide. 3 4
Shanghai is creating a government integrity database that’s based on the structure of the SCS for citizens and businesses, in the sense that it consolidates information from numerous state bodies. But instead of gathering information on people and enterprises, it gathers information on government employees and state bodies. And instead of gathering information from agencies involved in market regulation, it gathers information from agencies involved in internal affairs.
While we know which agencies the data comes from, we do not know what data they are submitting, and can only make educated guesses about exactly which records each agency might contribute.
|Who’s contributing to the Shanghai government social credit database|
|Data source||What it is||What data might be contributed|
|City courts||Shanghai’s local legal system||Records on government departments and personnel that have had legal action taken against them|
|National Supervisory Commission||Manages internal affairs||Records of disciplinary actions or awards meted out to government employees|
|State Administration of Civil Service||Oversees civil servants||Personnel files on government employees|
|Legal affairs office||Provides legal advice and helps craft administrative laws that govern the behavior of government bodies||Would have records of any time a member of the public had submitted an appeal against a government body’s decision|
|12345 Hotline||Takes public complaints on government affairs||Public feedback and criticism|
|Other ministries and district governments||Misc.||Misc.|
We also know generally what categories of data the Shanghai database will store…
Considering that “assessments” make up the majority of the datasets on government integrity, we wanted to get a clearer understanding of who is conducting those assessments, and what metrics they’re evaluating.
Social credit policies on government integrity indicate that two types of assessments will be conducted: “self-assessment”, wherein higher levels of government audit lower levels of government, and “third-party assessments”, where outside sources are called in to do research and reporting. 5 6
In the 2016 policy “Guiding Opinions on Strengthening Integrity in Government Affairs”, the State Council expresses an intention to:
“Support third-party institutions, such as credit evaluation services, universities, and scientific research institutes to carry out assessments and rate government integrity across various regions and departments.”
Some of those third-party appraisals have already taken place. In June 2019, Zhongding Credit Rating Service — in cooperation with some of China’s top universities — released its second annual report evaluating 2,794 county-level governments across 30 provinces. 7
Regional governments were assessed along five primary metrics:
- Diligence in constructing and launching county level government websites to push out public information
- Utilizing new media resources
- Usability and efficiency of government channels for collecting and responding to public feedback and complaints
- Supervision of law enforcement
- The gradual formation of a “social consensus towards legal administration”
- Taking the initiative to publicize administrative data
- Honoring agreements
- Keeping promises to the public
- Keeping promises to higher-ups in terms of implementing policies
- Internal focus on government integrity
- Whether or not the government is taking the initiative to foster administrative integrity internally
- Public opinion
- General positive vs. negative public opinion on government activities
- Incidents involving government dishonesty that attract media attention
The top 100 districts were then ranked from most honest to least honest.
Of course, for these types of reports to carry real weight, the third-party evaluator would have to be completely impartial, and that’s where things get murky: Zhongding Credit is owned by a couple of holding companies, one of which is owned by a man with close ties to government (a member of the Guizhou municipal CPPCC). 8
Perhaps even more interesting is the case of Zhongdaxin Credit, another approved third-party government credit evaluation company, which was founded by Lin Junyue, who you may remember is the man credited with the invention of social credit theory. Zhongdaxin has been involved in assessing regional government compliance in getting new data transparency systems and procedures up and running, and setting up internal evaluation mechanisms. 9
The point here is that the people in charge of these assessments can hardly be considered impartial observers. Their close relationship with the government is not particularly incriminating, nor does it completely nullify the validity of the reports, but it is a reminder that there’s very little separation between the public sector and the private sector in China, and truly objective “third-party” evaluations of government are unlikely.
Equally interesting is the inclusion of public opinion data as an evaluation metric. Public feedback on government behavior is gathered through a dedicated complaint hotline, and also assessed by looking at formal protests lodged against government decisions.
Government grading systems
There have been a few hints dropped that government bodies might receive letter-based integrity grades (potentially ranging from AAA-D), just like the compliance grades given to companies by some state agencies, but we haven’t yet seen this confirmed in policy documents, so whether or not this will happen is still up in the air. 10