United States:

The US has some federal and state laws that affect social media in the US, such as:

The Communications Decency Act (CDA) of 1996, which exempts internet platforms from liability for
user-posted content if they act lawfully to delete or restrict access to indecent or otherwise offensive
content3.

The Children's Online Privacy Protection Act (COPPA) of 1998 requires websites that collect sensitive
data from kids under the age of 13 to obtain verified parental approval, post a clear and comprehensive
privacy policy, and protect the confidentiality and safety of the information obtained3.

The 1996 Health Insurance Portability and Accountability Act (HIPAA) outlines restrictions for how
medical practitioners may utilize and share private medical information about their patients, including
on social media platforms2.

With rare exceptions, the Privacy Act of 1974 regulates how federal departments can acquire and use
data about people in their database systems and prohibits them from disclosing private information
without the individual's express consent.².

The California Consumer Privacy Act (CCPA) of 2018, as well as the Virginia Consumer Data Protection
Act (CDPA) of 2021, grant people of their respective states the ability to view, remove, or withdraw from
firms that collect or trade their personal information3 4.

In the United States, there is no extensive federal data privacy regulation that addresses every aspect of
social media firms' data collecting and utilisation. However, certain lawmakers have proposed legislation
to create such a law, such as the Safe Social Media Act of 2021, which would require the Federal Trade
Commission (FTC) to conduct studies on social media use by teenagers1,

or the Social Media Privacy Protection and Consumer Rights Act of 2021, which would need social media
platforms to provide users with concise and prominent notice of their terms of service, as well as obtain
voluntary permission for gathering sensitive information.

The First Amendment to the United States Constitution protects free expression, restricting the
government's role in regulating social media. (https://sgp.fas.org/crs/misc/R45650.pdf)

Section 230 of the Communications Decency Act exempts internet platforms from responsibility for
user-generated content, allowing them to control content in a lawful manner.

Section 230 reform to address concerns like as misinformation, hate speech, and political prejudice has
lately been addressed in order to enhance transparency, accountability, and regulation while upholding
free speech values.
(1) Social Media Privacy Laws - FindLaw. https://www.findlaw.com/consumer/online-scams/social-
media-privacy-laws.html.

(2) U.S. Data Privacy Protection Laws: A Comprehensive Guide - Forbes.

https://www.forbes.com/sites/conormurray/2023/04/21/us-data-privacy-protection-laws-a-
comprehensive-guide/.

(3) Social Media Policies | HHS.gov. https://www.hhs.gov/web/social-media/policies/index.html.

(4) S.1630 - Safe Social Media Act 117th Congress (2021-2022). https://www.congress.gov/bill/117th-
congress/senate-bill/1630/text.

Turkey:
Turkey's Internet Law (Law No. 5651) grants the government considerable authority to monitor and
restrict online information, including social networking platforms. Platforms must establish local
representatives, work with government officials, and respond to material requests for removal within
defined time constraints.

Turkish authorities frequently use the Internet Law to prohibit or limit access to webpages or social
media sites that are believed to breach certain legal criteria. Political criticism, religious blasphemy, and
content deemed dangerous to public order are all examples of this. (https://mbkaya.com/turkish-
internet-law/#:~:text=The%20main%20legal%20framework%20governing,or%20Turkish%20Social
%20Media%20Law.)

Turkey adopted legislation in July 2020 putting new charges on social media companies with more than
one million daily users in Turkey2. Among these responsibilities are:

Appointing a permanent representative in Turkey who will receive and respond to legal and regulatory
queries23.

Domestic user data is retained in Turkey, and every six months, fulfilment of material prohibition and
removal orders is recorded.12.

Removing or blocking internet content that violates personal rights, privacy, or public safety within 48
hours after receiving a request.23.

Critics fear that the bill will limit free speech and enhance censorship in Turkey.13. The law also includes
a "right to be forgotten" provision that allows a court to order that an individual's identify not be linked
to a website that appears in search engine services².
(1) Turkey: Parliament Passes Law Imposing New Obligations on Social Media ....
https://www.loc.gov/item/global-legal-monitor/2020-08-06/turkey-parliament-passes-law-imposing-
new-obligations-on-social-media-companies/.

(2) Blog: Regulating disinformation and social media platforms ‘alla Turca’.
https://www.article19.org/resources/regulation-of-social-media-platforms-in-turkey-internet-law/.

(3) Critics fear Turkey's new social media law could hurt freedom of ....
https://www.cnn.com/2020/07/29/europe/turkey-social-media-law-intl/index.html.

(4) Turkey Passes Law to Regulate Social Media Content. https://www.gadgets360.com/social-

networking/news/turkey-social-media-law-content-regulation-2270651.

(5) Turkey’s new Internet Law: local rules apply to local presence. https://www.ibanet.org/human-
rights-responsibilities-of-social-media-platforms-under-Turkey-new-internet-law.

China:
Censorship is used to control information in the news, online, and on social media in China, which has
one of the world's most restricted media environments1. In China, the following rules and regulations
apply to social media:

The Chinese Constitution, which guarantees citizens' freedom of expression and press but also permits
authorities to crack down on news reports on the grounds that they disclose state secrets and put the
country at risk1.

The Intermediary Guidelines for Information Technology and Digital Media Ethics Code) Rules 2021,
which require social media platforms to comply with Chinese regulations and laws, nominate a local
representative, report compliance with blocked content and removal orders, and enable encrypted
message tracing2.

The Public Pledge on Self-Regulation and Professional Ethics for China's Internet Industry, which includes
stricter rules for internet service providers, such as preventing false information, promoting extreme
emotions, plagiarism, cyberbullying, blackmailing, and deliberately increasing the number of clicks1.

China's Great Firewall, which controls and limits access to many foreign websites and services, including
Google, Facebook, Twitter, YouTube, and Wikipedia1.

According to the government, these rules and regulations are vital to defend China's national security,
public order, and social stability12.

Critics, however, claim that they violate human rights, restrict dissent, and limit the range of
perspectives and information in China134..
(1) Media Censorship in China | Council on Foreign Relations. https://www.cfr.org/backgrounder/media-
censorship-china.

(2) Restrictions on online freedom of expression in China - Chatham House.

https://www.chathamhouse.org/2021/03/restrictions-online-freedom-expression-china/chinas-
domestic-restrictions-online-freedom.

(3) China Bans Use Of Social Media In News Stories | Digital Trends.
https://www.digitaltrends.com/social-media/social-media-news-china/.

(4) China Imposes New Rules to Restrict Independent Online ... - Variety.
https://variety.com/2021/digital/news/china-cac-self-media-new-regulations-censorship-1234913799/.

India:
Intermediary Guidelines and Digital Media Ethics Code: In 2021, India introduced new rules called the
Intermediary Guidelines and Digital Media Ethics Code. The regulations require social media platforms
to appoint local grievance officers, establish complaint resolution mechanisms, and comply with content
takedown requests from government authorities
(https://india.org.pk/adminpart/Backgrounder_DM.pdf)

Content Regulation and Takedowns: The Indian government has been actively requesting social media
platforms to remove or block content that is deemed unlawful, incites violence, or threatens national
security. Failure to comply with these requests can result in penalties or even potential bans on
platforms.

In February 2021, India proposed new guidelines to control social media businesses, streaming
platforms, and digital news publications with more than 5 million subscribers in India2. Some of these
rules are:

Appointing a chief compliance officer, a point of contact, and a resident grievance officer to handle user
complaints and liaise with law enforcement.12.

Enabling the originator of end-to-end encrypted messages deemed unlawful by a court order or the
government23.

Within 36 hours of receiving a notice or an order from a court, remove or limit access to content that is
illegal, harmful, or violates the privacy of others.12.

According to the government, the laws are intended to protect customers and their fundamental rights
online, as well as to ensure openness and accountability for online platforms. However, some fear that
the laws could jeopardise India's privacy, freedom of expression, and innovation23. Some digital media
outlets and civil society organisations have also filed legal challenges to the rules3.
https://www.aljazeera.com/news/2021/7/15/india-internet-law-online-speech-privacy-twitter-facebook

(1) Press Information Bureau. https://www.pib.gov.in/PressReleseDetailm.aspx?PRID=1700749.

(2) New Rules For Online News And Social Media: 10-Point Guide - NDTV.com.
https://www.ndtv.com/india-news/government-moves-to-regulate-digital-content-streaming-with-new-
rules-2378284.

(3) India's new social media rules explained - Tech Wire Asia. https://techwireasia.com/2021/06/indias-
new-social-media-rules-explained/.

(4) Social media and Indian laws - Legal Desire Media and Insights. https://legaldesire.com/social-media-
and-indian-laws/.

(5) Regulation of social media - INSIGHTSIAS. https://www.insightsonindia.com/2019/10/22/regulation-

of-social-media/.

Denmark:
Denmark has some laws and regulations that affect social media in Denmark, such as:

The Danish Constitution protects freedom of expression and press, but also limits these rights, such as
respect of human dignity, individual respect, and privacy, as well as the prohibition of hate speech and
defamation2.

The Media Liability Act governs the liability of media providers and intermediaries for illegal content
such as defamation, invasion of privacy, or instigation to violence2.

The government proposed a new policy in March 2021 that would oblige digital giants like Facebook and
Google to compensate Danish media for utilising their material on their platforms1. In order to display
videos or music, the law would also compel platforms that exchange media content, such as YouTube, to
enter into agreements with rights holders.

According to the government, these rules and regulations are intended to protect the interests and
rights of online consumers, media organisations, and producers, as well as to promote a diversified and
autonomous media landscape in Denmark12.

Some sceptics however, contend that these laws and regulations may jeopardise freedom of speech,
innovation, and competitiveness in the digital market13.

(1) Media Law in Denmark — University of Southern Denmark.

https://portal.findresearcher.sdu.dk/en/publications/media-law-in-denmark.
(2) Social media guide for Denmark - Business Culture.
https://businessculture.org/northern-europe/denmark-business-culture/social-media-guide/.

(3) Denmark proposes new law to make Facebook pay for news and music.
https://www.thelocal.dk/20210326/denmark-proposes-new-law-to-make-facebook-pay-for-news-and-
music.

(4) Denmark criminalises social media impersonation of others.

https://www.thelocal.dk/20220303/denmark-criminalises-social-media-impersonation-of-others.

Singapore:

Singapore has passed laws to combat foreign intervention in domestic politics, allowing authorities to
make social media platforms and Internet service providers to provide user information or restrict
content that they consider hostile1.

The law is intended to protect Singapore's national security and sovereignty, as well as its diverse
people, from hostile information campaigns1.

(1) Singapore passes controversial law to counter foreign interference - BBC.

https://www.bbc.com/news/world-asia-58798373.

(2) Singapore passes law requiring social media sites to block ... - CNA.
https://www.channelnewsasia.com/singapore/social-media-sites-block-access-harmful-content-within-
hours-under-new-law-passed-parliament-3057041.

(3) Singapore tightens the reins on extreme social media content.

https://www.japantimes.co.jp/life/2022/11/12/general/social-media-content-law-singapore/.

(4) Singapore Passes Social Media Regulation Law Restricting ‘Harmful ....
https://saharareporters.com/2022/11/10/singapore-passes-social-media-regulation-law-restricting-
harmful-content.

Singapore has enacted some rules and laws to deal with issues arising from social media use, such as:

The POFMA (Protection of Online Falsehoods and Manipulation Act), which went into effect in October
2019. This law attempts to combat foreign meddling and negative content on the web by granting
authorities the authority to require social media platforms and Internet service providers to divulge user
information, restrict content, or display updates at the government's request1. In addition, people who
violate the legislation face significant criminal penalties1.
Parliament enacted the Online Safety (Miscellaneous Amendments) Bill in November 2022. The law
mandates social media platforms to prohibit access to offensive content, such as those encouraging
terrorist activities, suicide, sexual or physical assault, and child sexual exploitation2, within 24 hours. The
law also gives the Infocomm Media Development Authority (IMDA) the authority to deal with harmful
online content that is accessible to the people of Singapore, irrespective of where the content is stored
or initiated2.

The Framework for Equitable Sharing of Losses Resulting from Scams, announced in January 2022 by the
Monetary Authority of Singapore (MAS) and the Association of Banks in Singapore (ABS). This
framework attempts to safeguard customers from financial losses caused by scams involving
unauthorised transfers of funds from their bank accounts. Banks can reimburse consumers for as much
as 90% of their losses under this system provided they disclose the scam within a three-day period and
assist with investigations3. Additional steps to avoid and identify scams are also introduced in the
framework, such as deleting links that can be clicked in emails or SMS sent to retail customers and
delaying the installation of new soft tokens3.

(1) Singapore: Social media companies forced to cooperate with abusive fake ....
https://www.amnesty.org/en/latest/news/2020/02/singapore-social-media-abusive-fake-news-law/.

(2) Singapore passes new law to police fake news despite concerns.
https://www.aljazeera.com/news/2019/5/9/singapore-passes-new-law-to-police-fake-news-despite-
concerns.

(3) A Framework for Equitable Sharing of Losses Arising from Scams.

https://www.mas.gov.sg/news/media-releases/2022/a-framework-for-equitable-sharing-of-losses-
arising-from-scams.