如何平衡治理效率與隱私保護？中國和新加坡新冠病毒接觸者追蹤應用程式隱私政策的文本分析

The COVID-19 pandemic has spawned the spread of contact-tracing applications represented by China’s “Health Code” and Singapore’s “TraceTogether”. How to balance the relationship between efficiency and privacy ethics in data governance has become a common problem faced by countries using digital tracing tools to control the pandemic. The laws of both countries stipulate that before collecting personal information, the organizations or institutions must clearly inform individuals about the types of personal information collected, the rules for the use of personal information; and obtain the authorized consent from individuals. This article analyzes the content of the privacy policies of HealthCode in China and TraceTogether in Singapore, and identifies five potential problems in the Chinese HealthCode’s privacy policies: wide personal information collection, multiple processing purposes, ambiguous storage time, ambiguous privacy policy content, and ineffectiveness of informed consent, even though HealthCode has been an efficient tool to fight against the pandemic. Singapore’s TraceTogether has better followed the principles of minimum information collection, limited information processing purpose, minimum information storage time, openness and transparency of privacy policies, and informed consent. These two models of using big data to fight against the pandemic in China and Singapore suggest that data governance needs to reconcile public interests and individual rights, and to balance governance efficiency and data ethics.