A Comparative Analysis of Media Systems and Regulation: UK vs China

This essay provides a comparative analysis of media systems in the United Kingdom and China, focusing on media regulation and the concepts of convergence and divergence. It begins with an introduction to media's role in society and its evolution across different platforms, including the internet and social media. The essay then defines media convergence and divergence, exploring various types of convergence such as technological, global, economic, social, and cultural. It further examines the differences between the Global North and Global South media systems, highlighting how globalization impacts media and the disparities in media access and influence. The study delves into the media regulatory frameworks of both the UK and China, detailing the UK's reliance on independent bodies and codes of practice, and China's strict state control, censorship, and influence over both traditional and new media. The comparison analyzes the differences in regulatory approaches, emphasizing the UK's focus on self-regulation and China's comprehensive control, including internet censorship and the manipulation of online discourse. The essay concludes by highlighting the different approaches towards media regulation, and the different levels of freedom and control in the UK and China.

Running Head: SOCIOLOGY 1
Comparative media analysis
Author's Name
Institutional Affiliation

PSYCHOLOGY 2
Introduction
Media has always been an integral part of society and a medium for collecting and
disseminating information to the masses. Today, people can access the media not just on radio,
newspapers but on TV and the internet. As the involvement of media and technology deepens,
the current and next generations find it much easier to access media, and it could be their cell
phones, laptops, and iPods. The paper discusses the media systems of the global North and South
in comparative perspective and if they are convergent or divergent in nature. The assignment
tests the divergence of media in the 21st century and the claims of growing homogenization of
media systems by comparing the comparing media regulation in China and the UK.
Media convergence and divergence
Different types of media convergence have been identified - technological, global,
economic, social and cultural. The process of media convergence involves technology,
utilization, commercialization, and structure (Sullivan & Jiang, 2016). The worldwide industries
have been impacted by the globalization of manufacturing, consumption, and distribution. The
global media and its widening reach around the world have led to new constructions and
challenges. New media technologies have contributed to a new media revolution. The dynamics
of media globalization have created different impacts in the global South as asserted by
Wasserman (2014). When media manages its content across multiple platforms such as print,
radio, Internet, social media and other interactive platforms, becomes a convergent media. In the
rapidly-changing 21st-century, with high-speed broadband in almost every home and
workplaces, there is a universally accessible platform for convergent media (Flew, 2012). Policy
convergence is a generic process where policies tend to grow alike in terms of structures,
processes, and performances (Olsson, Deverell, Wagnsson, & Hellman, 2016). In terms of media

PSYCHOLOGY 3
convergence, it refers to the process of merging previous media technologies due to the
digitization and computer networking. The emergence of digital technologies and technological
changes have made the convergence of media and communications prevalent and promoted
many companies to extend their reach (Sullivan & Jiang, 2016). Even traditional vehicles like
newspapers, magazines, and television can be accessed on the Internet. The phenomenon of
media convergence has impacted the media industry and ownership decisions.
Global North-global South media
The phrase “Global South” refers to the family of countries at the Periphery or the
regions outside North America and Europe. The terms like “Global North” and “Global South”
were used to denote the geopolitical relations of power in the world. These terms found
increasing use in academic fields like political science and international relations (Dados &
Connell, 2012). Regions like Asia, Africa, Oceania, and Latin America broadly constituted the
Global South. As asserted by Pfetsch (2013), the global North and South stand in contrast in
terms of economic welfare, culture, and political stability. The economic and social differences
between the North and South deter cooperation. The global North includes the world's most
developed countries like the United States and European countries. The world has become a lot
more complicated in terms of economic and social development.
While Global North is in favor of globalization, there is a mixed stance in the Global
South. The news media is a primary vehicle for globalization as it reaches out to a global
audience. CNN and BBC networks have used technology to create internationally oriented news
programs and connect to wider audiences (Beer & Boynton, 2006). Aljazeera, a southern
network has supplemented its Arabic language with English to spread its global influence. As
global media develops, the use of standard technology can help drive international integration.

PSYCHOLOGY 4
While the northern actors have held an essential influence on political and media elites, the
Southern actors have mostly tried to fit themselves in. The Southern media tries to create its
niches within the Northern-dominated conventional technology and norms. The media actors
have only partial freedom, and different media actors can vary in terms of traditions, cultures,
and agendas. The localized differences interact with the globalizing media to create mixed result
(Beer & Boynton, 2006).
The research on neoliberal globalization reflects upon the disparities in some urban
regions of the Global and the embedded poverty in the Global South. Moreover, research from
the Global South has been primarily a Northern undertaking (Gulson, & Pedroni, 2011). The
media-soaked countries of the global North are witnessing the demise of newspapers because of
social media and smartphones. However, the newspaper trade is still vigorous in many countries
of the global South. The political, social and historical progresses impact the growth and
development of media (Wasserman, 2014).
The Global North and Global South divide can be seen to some extent in the use of
media. In today’s media ecology, audiovisual media content is a liquid asset that can be
streamed on various platforms as a corporate strategy. Dissemination takes place on different
platforms can be a linear broadcast, video-on-demand, webcasting and illegal peer-to-peer
circuits (Courtois, De Marez, & Verdegem, 20142). Thus, the numerous screen media have
converged regarding their affordances. The media convergence raises new problems with the
current framework of media and its content. The nature of the media consumer has shifted from
being an audience member to media participant and co-creator (Flew, 2012). There is a need for
developing a framework that concentrates on media content rather than the platforms for delivery
and distribution. Regulatory arrangements and the current framework need to be revised and be

PSYCHOLOGY 5
more effective to deal with the challenges posed by the media convergence. While the use of
technologies behind media is more or less the same, the difference lies in how they are used and
the regulatory framework around them.
Media regulation in the UK
Media regulation in the UK revolves around specific codes of practice supported by
largely independent bodies. BRICS nations are more different than being similar (Moon, 2016).
It is because of the inherent competition among members that prevents united front to develop.
There is still not ugh internal coherence to challenge the existing Western-centric political realm.
UK commercial radio industry, established in the 1970s, has seen several changes within the
regulatory environment on the sector (McDonald & Starkey,2016). Today, news journalism and
programming production is intended to become increasingly profitable in the much-altered
media landscape. BBC is the only source of local and international news on UK radio
(McDonald & Starkey,2016). In a democratic society, it is not regarded as healthy because of the
absence of any other medium. The smaller stations struggle to survive the competitive media
market, and local radio journalism can be encouraged to survive the changing media landscape.
The incident of British newspapers involved in the phone-hacking scandal calls for a new
structure of press regulation. Questions are being raised upon the century’s old tradition of press
freedom in the UK (Burns, & Cowell,2012). The report on the incident examines the relationship
between the politicians and the powerful media baron of the country. Advocates for press
freedom in Britain are concerned about how a media regulatory body would weaken press liberty
in the U.K and give more power to the governments to control the journalists through such
regulations. An official inquiry committee was set up in the UK to study the practice and ethics
of the press in 2011. This was in the wake of exposures due to phone-hacking of celebrities,

PSYCHOLOGY 6
politicians and public members. New press standards are demanded the regulation of the press
(Cohen-Almagor,2015). The competition between British tabloids is brutal, and that drives the
tabloids to follow illegal practices to get information and create interesting news. The press
standards get lower and lower as they violate ethical boundaries. Currently, the situation is far
from satisfactory in Britain as the press needs self-control and self-awareness of ethical concerns
(Cohen-Almagor,2015). While any restriction on free expression is an infringement of
democracy, what happened in British press demands for strong regulation. Unfortunately, the
tabloid journalism in the UK fails to manifest rigorous standards for its conduct (Cohen-
Almagor,2015). The internet and media experts discuss if there should be a regulatory
framework for the internet and the different platforms on the web. Open Rights Group is a digital
campaigning organization that works towards protecting the rights to free speech and privacy
online (Parliament UK, 2018).
Media regulation in China
China has two distinct kinds of media, public and internal and the content and purpose of
each is intended for two different audiences. Public media includes print media, broadcast media,
and digital media. Internal media includes books and documentaries that carry investigative news
reports and in limited-circulation. While the public media circulates openly, internal media
circulates only among certain leadership positions (Dimitrov, 2017).
In China, political opinions can be discussed and shared in private but not in public.
However, the digital age has encouraged the online public opinion, and the explosion of Social
media forced the Chinese government to respond accordingly (Stockmann, 2017). The traditional
and new media are under the tight control of China. Every imported motion picture is viewed by
the Chinese government so that it does not erode their national identity. Regulation and

PSYCHOLOGY 7
censorship still block foreign filmmakers and producers from entering the Chinese markets.
There is strict control over controversial content with censorial tactics (Geltzer, 2015). Weibo,
WeChat, and Baidu Tieba are popular social media in China. These social media platforms that
carry business goals as well as to foster certain kinds of political behavior (Stockmann, 2017).
While there is no indication that the Chinese state endorses specific social media platforms, it
can be speculated that a suppression on opinion leaders have diverted the users to certain
platforms. The government can indirectly impact product design by manipulating the broader
information environment (Stockmann, 2017).
Censorship is prevalent in China and applies to all kinds of media. Foreign newspapers
and magazines can be sold only if free of any banned articles. The state controls the Chinese
radio and television, and any foreign broadcasts are transmitted with a 12-second delay so that
they can be checked for any sensitive content (Dimitrov, 2017). Internet and social media go
through a complicated system of keyword filtering and website blocking to prevent any
offending material from reaching Internet users. The content removal in China is pervasive and
systematic and occurs within a few hours. It is a good strategy to suppress any conversation of
collective action and thus declines the organization potential of social media. (Pan, 2017). The
Chinese state is now outsourcing censorship, and an army of web commentators work towards
changing the online public discourse. The cyberspace is thus directly manipulated by the
Chinese state (Stockmann, 2017). Chinese leadership relies on human monitoring and
technological surveillance for control in modern China. The future for Chinese media is likely to
remain the same as the regime continues to readjust the objectives of public media regulator in
the digital age (Dimitrov, 2017).
Comparison

PSYCHOLOGY 8
A study on how the EU states work and the prospects for convergence emerge when one
looks at the use of social media. Cooperation and institutions are the two main factors for
convergence and can impact the convergence of policies (Olsson, Deverell, Wagnsson, &
Hellman, 2016). In Europe and UK jurisdictions, the authoritative reactions are still moderate
and focus more on the management instead of the filtering and blocking technologies in
cyberspace. There is a higher intent on promoting internet self-regulation (Muller, 2018). The
interplay between public and private regulation can increase the intensity of public control. In
China, the mainstream media remains under state control, and Facebook and Twitter remain
blocked (Wasserman, 2014).
According to Pfetsch (2013), the study of Media Systems outside the West offers
essential lessons to be learned. Western media systems can be divided into three models, liberal,
polarized pluralist and democratic corporatist. The applicability of these media models beyond
Europe and the United States remains questionable. The fundamental fissures that can impact the
media systems are political transformation, political conflict, economic development,
geopolitical separation and language cultures (Pfetsch, 2013). Authoritarian governments have
often gone to extremes to control traditional media through government ownership, by giving
bribes and even through intimidation. Looking at the past and current scenarios, it seems that the
efforts to control media have been mostly successful (Pan, 2017). China is different from the
other countries as its top social media platforms are domestic. While U.S. social media platforms
are used in many other countries, Chinese social media companies are in demand and popular
only in China. Iran is another country where the leading social media firms are not the U.S.
owned (Pan, 2017). Content removal does hurt the prospects and profits of Chinese social media
firms and discourages them from expanding beyond China. The Chinese social media firms bear

PSYCHOLOGY 9
the cost of paying sensors to comply with the government stipulations (Pan, 2017). The new
social media indeed makes it difficult for authoritarian regimes to control and censor the
information. Social media is often seen as a tool to improve coordination and take collective
action against controlling regimes. However, the successful control of the Chinese regime on the
internet and social media shows that censorship activities can be followed by other authoritarian
regimes (Pan, 2017). The authoritarian governments try to control the media on the web
platforms.
What about China: global North or global South?
China can be seen as something of an intermediary between the global North and global
South. While it is still categorized as a 'developing' country, its media technologies and control
over media are far superior to others. The Chinese internet characterize more than twenty percent
of the world’s total internet users (Pan, 2017). That gives the impression of China ebbing way
advanced in terms of internet use and web media expansion. Research on internet censorship
shows that any criticism of government policies, terms like freedom of the press, freedom of
speech are deleted. China has expertly avoided the impact of media liberalization and kept it in a
highly restraining environment. It ranks 176th in the world for press freedom. Despite having
700 million Internet users, the internet cannot be seen as a liberation technology in the country
(Dimitrov, 2017). Why China has been successful in its web censorship can be partly due to the
dominance of domestic firms and lack of need for U.S. social media sites. On the one hand,
online discussions are promoted by the Chinese state to some extent. In fact, the Chinese state is
actively encouraging public deliberative forums where the citizens can make policy suggestions
and provide feedback on topics like corruption, the environment, or financial policies
(Stockmann, 2017). At the same time, the state also tries to control the content of those

PSYCHOLOGY 10
discussions. As a result, the final outcome is Internet surveillance and manipulation to support
the authoritarian rulers. China has the most sophisticated and extensive system for Internet
surveillance and manipulation for blocking websites and filtering information.
As the internet is a complex network of networks and is multilayered, it is indeed
challenging to regulate the internet. One can control individual human behaviors with laws and
regulations. The control of content is one part of internet regulation (Muller, 2018). The
regulators' main concerns are the use of defamatory speech, misleading information, illegal
content and infringement of intellectual property rights in the web content. Although media may
find a homogeneous medium in the web, there are divergent media within it like blogs,
discussion forums, news feeds and more. The use of online media and the level of interactivity
varies among divergent news platforms (Opgenhaffen, 2011). The concept of multimedia
remains ambiguous as it employs multiple media formats and delivers content through different
media platforms. The news may be presented on multiple divergent platforms, and within each
platform, there are features of convergent multimedia (Opgenhaffen, 2011). For example, the
digital newspapers make use of a news forums, news blogs and news feeds to dispense the news.
These sub media vary in terms of key features and stand on their own. The continuing centrality
of nation-states carries an ongoing significance in an age of media globalization. Internet policies
in China indicate that nation-states and domestic actors play an important role in media
governance (Flew, & Waisbord, 2015).The issue lies with the culture of journalism, that
demands free expression for itself but can breach the privacy of others for its personal gains. The
freedom to print does not mean the liberty to enter one’s private life (Cohen-Almagor,2015).
While it is essential to protect the freedom of expression, it is also essential to show respect for

PSYCHOLOGY 11
others.
Conclusion
The role and nature of media have undergone significant variations over the past few
decades in terms of technologies, usage, and regulations. The global divide between North and
south remains, despite the pervasive nature of the web. Social media and digital technology are
used for political talk and to share the news. Online activism develops because of contribution in
online political discourse. However, the margins between political exchanges and public
opinions are often indistinct. One finds both convergence and divergence within multimedia. A
comparison of media regulation in the UK and China shows that while the UK suffers from an
excess of freedom given to the press, the current Chinese leadership shows a firm resolve to
maintain control over the media. It would be difficult to find the right balance between the
freedom of expression and privacy and the right extent of control over the media.

PSYCHOLOGY 12
References
Beer, F.A. & Boynton G.R. (2006). NorthSouth Globalization and Action Initiatives: Multiple
News Media in the Emerging Global Communication Space. University of Colorado,
1(1), 1–10.
Dados, N., & Connell, R. (2012). the global south. Contexts, 11(1), 12-13.
Burns, J & Cowell, A. (2012). Hacking Report Says New Regulatory System Needed for British
Newspapers, NY Times Retrieved from
https://www.nytimes.com/2012/11/30/world/europe/leveson-report-phone-hacking-
scandal-britain.html
Cohen-Almagor, R. (2015). Press self-regulation in Britain: a critique. Science And Engineering
Ethics, 21(1), 159–181.
Courtois, C. De Marez, L., & Verdegem, P. (2014). Composition and role of convergent
technological repertoires in audiovisual media consumption. Behaviour & Information
Technology, 33(8), 844–858.
Dimitrov, M. K. (2017). The Political Logic of Media Control in China. Problems of Post-
Communism, 64(3/4), 121.
Flew, T., & Waisbord, S. (2015). The ongoing significance of national media systems in the
context of media globalization. Media, Culture & Society, 37(4), 620-636.
Flew, T. (2012). Media Classification: Content Regulation in an Age of Convergent Media.
Media International Australia (8/1/07-Current), (143), 5–15. Gulson, K., & Pedroni, T.
(2011). Neoliberalism, cities and education in the Global South/North. Discourse: Studies
in the Cultural Politics of Education, 32(2), 165–169.

PSYCHOLOGY 13
Geltzer, J. (2015). Censoring the Silk Screen: China’s Precarious Balance between State
Regulation and a Global Film Market. Journal of International Media and Entertainment
Law, (Issue 2), 123.
Moon, R. (2016). Mapping BRICS Media. International Journal of Communication (19328036),
10, 6165–6168.
McDonald, K., & Starkey, G. (2016). Consolidation in the UK commercial radio sector: The
impact on newsroom practice of recent changes in regulation, ownership and local
content requirement. Radio Journal: International Studies in Broadcast and Audio Media,
14(1), 123–135.
Muller, M. W. (2018). Mapping Paradigms of European Internet Regulation: The Example of
Internet Context Control. Frontiers of Law in China, (Issue 3), 329.
Olsson, E.-K., Deverell, E., Wagnsson, C., & Hellman, M. (2016). EU armed forces and social
media: convergence or divergence? Defence Studies, 16(2), 97–117.
Opgenhaffen, M. (2011).” Multimedia, interactive and hypertextual features in divergent online
news platforms: An exploratory study of Flemish online. University, 16(3), 12–22.
Pfetsch, B. (2013). Comparing Media Systems Beyond the Western World , edited by Daniel
C.Hallin and Paolo Mancini. Political Communication, 30(1), 162–165.
Parliament UK. (2018). Digital media experts discuss internet regulation. European Union
News. Retrieved from
https://www.parliament.uk/business/committees/committees-a-z/lords-select/
communications-committee/news-parliament-2017/internet-regulation-digital-media-
evidence/

PSYCHOLOGY 14
Pan, J. (2017). How Market Dynamics of Domestic and Foreign Social Media Firms Shape
Strategies of Internet Censorship. Problems of Post-Communism, 64(3/4), 167.
Sullivan, D., & Jiang, Y. (2010). Media Convergence and the Impact of the Internet on the M&A
Activity of Large Media Companies. Journal of Media Business Studies, 7(4), 21–40.
Stockmann, D., & Luo, T. (2017). Which Social Media Facilitate Online Public Opinion in
China? Problems of Post-Communism, 64(3/4), 189.
Wasserman, H. (2014). The ramifications of media globalization in the global south for the study
of media industries. Media Industries Journal, 1(2)