Each country has its own laws, its own highway code and its own tax system. Wouldn't it be logical if everyone could set the same clear boundaries for the circulation of information online? The answer to this question might seem rhetorical, especially given that in the absence of national laws, all power over what can and can’t be said on the internet is in the hands of a very few international digital giants. Nations are left with just two options: to block certain platforms completely (from social networks to search engines), as is the case in China and a few other countries, or to enforce the deletion of any content deemed undesirable.

If such requests come from democratic countries, private companies operating online platforms usually adapt to the specifics of each country without any particular difficulty. For example, in Italy, it’s a crime to insult the President of the Republic (including online); in Germany, it is forbidden to display extreme right-wing symbols which are allowed in other countries.

What happens though when countries with little democracy ask for content to be deleted? This is what has happened in India, a country where the government has become increasingly authoritarian in the last few years: some parts of the country have seen large demonstrations recently, by farmers protesting against new legislation passed by Parliament. Citing its laws against threatening public order, the Indian government ordered Twitter to delete or hide more than a thousand accounts that disseminated information or videos related to the protests.

Instead of complying with the government's demands, Twitter objected and refused to delete the profiles of journalists, activists and others who were using the social network to disseminate information about the ongoing protests. Who’s right? "I don't think a government can simply order a company to comply with the law and the company has to obey," Chinmayi Arun, a member of the law faculty at Yale and founding director of the Center for Communication Governance at India's National Law University in Delhi, told the New York Times. "If companies are faced with the knowledge that a law interferes with human freedom, then I think backing down and claiming they have no choice is just a cop-out."

The dilemma we face is clear: must we always obey the demands of a legitimate government, or is it possible to refer to Article 19 in some cases, which enshrines the right to freedom of opinion through any media, regardless of frontiers, and refuse to comply with it on that basis? As you can see, it’s a complex issue and one that's becoming more complicated by the day. Human Rights Watch reported that in recent months, countries including Russia, Hungary and Poland have enacted new laws to ensure that platforms remove certain unwanted content quickly and can never delete government-issued content, regardless of whether it violates social network guidelines.

In Russia, for example, a law was passed at the beginning of 2021 that makes it possible to fine companies that do not promptly obey government orders and refuse to remove unwelcome or illegal content (including content that exaggerates the number of protesters and fake news about police abuse). The fines can be up to 10% of the company’s turnover and have already been enforced after the recent wave of protests, which were widely followed on social media. Is it right for social networks to yield to such demands or should they oppose them?

As you can see, it’s a very complex issue. In an attempt to bypass the difficulties posed by a global internet, where information tends to flow unfiltered, many countries are focusing on cyber sovereignty, a term used to indicate the willingness of governments to impose infrastructural limits on the circulation of online content. In 2017, India imposed a nationwide block on the Internet Archive, which aims to create a 'permanent copy' of materials on the internet. The following year it shut down all porn sites and in 2020, it blocked several environmental sites, including those referring to the 'Fridays for Future' movement.

However, when it comes to restricting the free flow of information online, no nation has taken more structural measures than China. This is not new: back in 1997, Wired reported on the Chinese project to censor and block unwanted sources of information from outside the People's Republic. This system is known as the Great Firewall: it became fully operational between 2006 and 2008 and can block all disapproved content, preventing Chinese users from accessing it.  It’s the reason why Facebook, Whatsapp, Google and Twitter can’t be used in China: they are replaced by local versions (including Wikipedia) which are often equally impressive in size (think of a 'super app' like WeChat or the Baidu search engine) and carefully monitored by the Beijing government.

However, what has been happening in China for a long time is now increasingly becoming the norm. The most striking example is the Halal Net which has been operating in Iran since 2012. In its most extreme form, this involves disconnecting all cables, servers and data centres from the rest of the network, making it impenetrable to outside influences and impermeable to the use of loopholes such as proxies or VPNs (which make it possible to bypass censorship).

The Halal Net could become a true national intranet, like the Kwangmyong in North Korea (where the internet is only accessible to a very small number of people), or the one that the Cuban people had access to before the partial liberalisation. Russia is also going down the same path: Moscow conducted a multi-day test at the turn of 2019-2020, to experiment with internet 'blackouts' (the ability to disconnect the Russian network from the global one in the event of an emergency) and to advance the RuNet project, another local intranet.

The greater the control over the Internet, the worse the freedom of the Internet inevitably becomes. In a recent report, the NGO, Freedom House reports that internet freedom has decreased for the tenth consecutive year due to restrictions in 26 of the 65 countries surveyed. Governments impose their will on platforms through laws, design alternative social networks that are easier to control and, as a last resort, isolate the national network from the global one.

The Internet started as a single, global network but is gradually fragmenting, a phenomenon known as the Splinternet. "Religious nations do not want to be inundated with blasphemy and pornography from the rest of the world and, globally, governments do not want insurgents to use the internet to overthrow them. Democracies do not want fake news to cause riots. China does not want people to support multi-party democracy. Russia does not want Western information about the oligarchs to circulate. The Americans don't want Russia meddling in their elections," wrote Mike Elgan, an expert on the subject. "The Splinternet is simply an extension of national governments' laws on cyberspace: an inevitable destiny”.

In a way, the Internet is a victim of its own success. In the early days of the Net, nobody could have imagined how it would change the world. In an article in 1998, economist and Nobel Prize winner Paul Krugman said that its impact would be no greater than that of the fax machine. Things have turned out very differently and the Internet is now a global infrastructure, used by 4.6 billion people daily, which theoretically makes it possible to reach and obtain information at any time and in any corner of the globe. Defending such an achievement and preventing each nation from building its own digital fence is probably one of the most important challenges of our time.

Journalist class of 1982, he writes about the interaction between new technologies, politics and society. He contributes to La Stampa, Wired, Domani, Esquire, Il Tascabile and others.