摘要
Amid the global wave of digital government transformation,China and the United States have pursued markedly different development paths.This paper investigates the fundamental differences between the two countries'approaches in terms of top-level design,technological applications,public participation,and the impact on privacy rights,as well as the underlying logic behind these differences.Through comparative case studies and policy text analysis,the research focuses on China's"Health Code"and"One-Stop Online Services,"alongside the EU's GDPR and California's CCPA as core cases.The main findings are as follows:China's path is state-led and efficiency-oriented,producing highly effective governance tools but facing the risk of a"Digital Leviathan";the U.S./EU path prioritizes rights and checks and balances,building a"Digital Commons"at the potential cost of efficiency.Both approaches must confront their respective challenges and explore avenues for dialogue and mutual learning.
基金
Youth Fund for Humanities and Social Sciences Research,Ministry of Education:"The Impact of Artificial Intelligence on Global Security and Its Governance Obstacles"(24YJC810002)。
