Online abuse is rife on social media and other sites across the globe but countries are attempting to deal with it in very different ways. As part the Guardian’s Web we want series investigating the dark side of the internet – and the efforts people are making to clean it up – we look at what different legislatures are doing.

China

With more internet users than any other country – 688 million, according to the government’s last count – China provides fertile ground for online abuse.

The most notorious form is the so-called “human flesh search engine”, by which internet users club together to identify and then publicly humiliate online targets who have been accused of anything from corruption to infidelity or animal cruelty.

Ding Jinhao, a teenager from the city of Nanjing, understands the dangers better than most. In May 2013 he was the target of a furious online campaign after another internet user accused him of carving the phrase “Ding Jinhao was here” into an ancient Egyptian temple while on holiday.

Facebook Twitter Pinterest Chinese characters that read ‘Ding Jinhao paid a visit here’ are seen carved on a statue on the wall of an ancient temple in Luxor. Photograph: China Stringer Network/Reuters

Tens of thousands of Chinese internet users shared reports of Ding’s infraction. His personal details and school address were published online to shame him and his school’s website was hacked.

So ferocious was the offensive against Ding that his family was forced to issue an online apology for his behaviour. “We want to apologise to the Egyptian people and to people who have paid attention to this case across China,” his mother told a local newspaper.

Beijing, despite boasting an immense army of online censors and perhaps the most sophisticated internet censorship apparatus on Earth, has been slow to react to the growing tide of online abuse.

Scholars warn that human flesh search groups, which first appeared more than a decade ago, have in many cases become “online lynch mobs”. But China still has no specific law to counter cyberbullying, says Zhou Zongkui, one of the few Chinese academics to have studied the issue.

Zhou describes cyberbullying on social media groups such as Weibo or Weixin as a serious and growing threat to his country’s youth. In a study of nearly 1,500 secondary schools he found that almost 35% of respondents admitted to having bullied someone online while nearly 57% said they had been bullied.

Facebook Twitter Pinterest Chinese school students: a survey revealed widescale cyberbullying among pupils. Photograph: Alamy

“They spread rumours about you or defame you online in order to isolate or marginalise you,” said Zhou, a specialist in teenager cyber psychology and behaviour from the Central China Normal University. “It is hard for people that age to bear and it makes them depressed.” Tom Phillips Beijing. Additional reporting by Christy Yao





Russia

The problem with online abuse in Russia is often not so much that the authorities do not take it seriously, but that they may actually be behind it.

Ruslan Leviev, a blogger who has used open-source information to chart Russian military manoeuvres in Ukraine and Syria, has been on the receiving end of many online threats on Twitter and Facebook. A “patriotic” website also published an home address and phone number that it attributed to him.

“Recently I’ve been getting a lot of calls from people saying they’re going to come and get me,” he said.

So far, none of the threats have turned into real physical action. He has not contacted police about the threats, believing it is unlikely that anything would be done.

Ruslan Leviev Photograph: Twitter

“Anonymous murder threats by phone or internet are almost never investigated, the police aren’t interested in such ‘petty’ crimes, because the evidence is weak for a court case.”

Additionally, given the political nature of his work, he believes it is unlikely that he would find allies among the police.

“If I feel that there is a real danger for me, then I would go to the police, but not so that they’d solve the case, but merely so that when I do get attacked in future I can show that I did go to the police.”

Even in cases where abuse comes from non-official sources, the legal framework can act as an aggravating factor. Gay rights activists cite the controversial 2013 laws against “homosexual propaganda” as contributing to an environment where online and real-life harassment of gay people is encouraged.

Russia has no specific laws on online abuse but the phenomenon is theoretically covered by standard laws against threatening violence or murder. For cases of revenge porn, Russians are often reluctant to go to the police, with just a handful of cases each year.

“Often people will come to us but will then decide not to go public when it becomes clear that it will involve the police investigating their private affairs and so on,” said Damir Gainutdinov, a human rights lawyer.

Online abuse in Russia can be sophisticated and multifarious. At Russia’s notorious “troll farm” in St Petersburg, thought to have shadowy links to the country’s authorities, hundreds of people put in all-day shifts on social networks and online comment forums, spamming the internet with pro-Kremlin views on the issues of the day.

Many of the trolls also spend their days curating fake personal blogs; one former troll told the Guardian how she was instructed to post blog entries hectoring opposition leaders or unfriendly public figures on her accounts, among more innocent posts about trivia and daily life. Shaun Walker Moscow

UK

“I call the internet and social media the ‘wild west’,” says Nik Noone, CEO of Galop, London’s LGBT anti-violence organisation. “People are in this territory that changes quickly but rules or norms are not evolving at the same pace. The criminal justice system and legislation has struggled to keep up with the pace of change and the reality of what people are experiencing.”

Online abuse in the UK can be broadly broken down into two categories. The first is the more targeted abuse that is directed towards someone often by a partner, ex-partner, colleague or classmate. Noone’s group places revenge pornography as well as stalking into this category. “It’s very targeted, very persistent, potentially extremely dangerous and can have a very powerful impact,” she says.

It is often women, victims of domestic abuse and LGBT people who are the victims of these targeted attacks. “There’s quite a hidden LGBT element in terms of revenge porn,” adds Noone, who says attackers will sometimes threaten to post pictures “outing” someone to family and friends unless blackmail demands are met.

“An ex-partner can put a photo online that would out someone, even if it’s not sexually explicit and police might say ‘What’s the problem with that, it just shows a nice cosy picture of two people snuggling on a couch.’ But that threat is part of a coercive situation.

“That for me harks back to a pre-legalisation world,” says Noone.

But this targeted abuse is beginning to be tackled by legislation. In April 2015, revenge pornography – the sharing of private sexual photographs or films without consent – became a criminal offence. In the six months after it was introduced, nearly 200 cases of revenge pornography were reported to police across England and Wales, leading to 13 convictions – of 12 men and one woman.

Facebook Twitter Pinterest Caroline Criado-Perez received threats via Twitter after her campaign to have Jane Austen featured on banknotes. Photograph: Murdo Macleod/The Guardian

In March, a senior police officer dealing with cyber crime called for new legislation to deal with online abuse, which he said was occurring on an “unimagined scale” that could overwhelm the police service.

Other steps, such as the introduction of a national stalking helpline and national revenge pornography helpline have assisted victims. In a promising step, in March 2015, the Crown Prosecution Service updated its guidelines to cover a wider range of cyber-related crimes, including those involving people setting up fake profiles in the names of others.

The second element of online abuse in the UK is related to more general abuse directed towards someone in a public online space. This can be targeted at someone with a public profile, such as the death and rape threats directed at activist Caroline Criado-Perez via Twitter in 2013 for her campaign to have Jane Austen featured on banknotes, which led to two convictions. Or it can be aimed at less prominent figures, for example by shaming and ostracising people in particular online communities – Facebook groups for particular subcultures or Tumblr communities, for example. This abuse is often difficult to prosecute, but makes people “scared and distressed in their virtual communities,” says Noone.

“When these things happen they feel very frightening and overwhelming, they come into your pocket; they come into your home, where you’re supposed to feel safe,” she says. Kate Lyons

Colombia

Colombian internet users face the same issues as those elsewhere – harassment, stalking, revenge pornography and blackmail, largely aimed at women. But in the South American country, which has been plagued by long-running conflict, the situation is complicated as this abuse sometimes comes from paramilitary groups who threaten to take the abuse from the computer screen to the victim’s home.

Olga Paz Martinez, coordinator of the Take Back the Tech project in Colombia, says such online violence is often directed against women’s rights campaigners and in particular those who speak out about sexual violence against women.

Between 2009 and 2012, Colombian feminist organisation Mujeres Insumisas received a series of online threats about the work they were doing campaigning for women’s rights. The abuse occurred through emails and mobile phone messages and at least three women working for the NGO were victims of sexual violence, harassment and stalking during this period, which they believed to be connected to the online abuse.

Facebook Twitter Pinterest Women protest against discrimination and sexual violence on International Women’s Day in Bogota earlier this month. Photograph: John Vizcaino/Reuters

During this time, the NGO also received 12 threatening emails from paramilitary groups urging them to stop their work. One email threatened the group, saying “we will not be respsonsible for what might happen to the leaders of these organisations ... we have begun to exterminate each one of them without mercy”.

The situation in Colombia is also complicated by a deeply-rooted cultural machismo, which prizes hierarchical notions of gender and traditional family roles. In some cases of abuse against women who have spoken out against sexual violence, says Paz Martinez, the victim’s husband has been contacted and told to “make your wife shut up” or the abuse will continue.

In this culture, many women who are the victims of revenge pornography, return to their former partners or give in to other blackmail demands to protect their reputation and safety, says Paz Martinez.

In 2008, a landmark piece of legislation was introduced in Colombia which addressed violence against women, but there is no specific mention of technology-related violence and the law is ill-equipped to help people who are the victims of online harassment and abuse. Kate Lyons

Sweden

Shortly before Christmas in 2012, nearly 30 pupils were arrested during a full-scale riot outside a secondary school in Gothenburg, Sweden’s second city.

The spark for the brawl was an Instagram account, “Sluts of Gothenburg”, set up that week by two girls aged 15 and 16, which asked people to send in photos of other local teenagers along with allegations about their sexual history.

About 200 photographs, of both boys and girls, were published on the account. Many of the pictures were accompanied by names, and most included accusations of promiscuity.

At their subsequent trial in June 2013, the two girls were found guilty of defamation, sentenced to juvenile detention and community service, and ordered to pay 15,000kr (£1,450) compensation to each of 38 victims identified by the court.

Facebook Twitter Pinterest Police confront youths in Gothenburg in December 2012 amid protests over the ‘Sluts of Gothenburg’ Instagram account. Photograph: AFP/Getty Images

The case, which attracted massive media attention, is perhaps Sweden’s best-known incidence of online abuse and harassment – and a rare example of successful prosecution by police and judicial authorities battling, campaigners say, inadequate legislation and technology they do not fully understand.

A study published in June 2015 by the Swedish National Council for Crime Prevention (NCCP) suggested that across all categories of online threats, abuse and offensive behaviour, only 4% of complaints may result in prosecution, often because the incident does not constitute a criminal offence or, in more than 40% of cases, because of difficulties identifying perpetrators and obtaining evidence.

The study found that the most common platform for online abuse was Facebook, particularly among young people. Among adults, abusive and threatening emails were also frequent.

The NCCP study found that men and boys were most often victims of offences that could be classified as defamation (being described as a criminal, paedophile or rapist, for example) or threats to the person, while offences against women were mostly molestation (posting derogatory remarks or sexual images).

Some 44% of incidents reported by women involved a present or former partner, while nearly half of those reported by children involved a friend or classmate. Only a third of all abuse was anonymous.

According to Angla Eklund, project manager of the Institute of Law and Internet, a non-profit organisation set up to help victims of online abuse, part of the problem for authorities was that existing laws were often not up to the job.

“For example,” she said, “the highest court in Sweden has ruled that publishing a naked or sexual image of a woman does not in itself constitute defamation, which is defined as ‘exposing someone to the disrespect of others’ – it is normal for an adult to be sexually active.”

A bill is going through parliament to address many of these issues and make prosecution of online abuse easier. In the meantime, Eklund’s institute, founded in 2013 by a leading law professor, Morten Schultz, has pursued through the civil courts several cases that have failed to make it to criminal trial.

“Suing people forces the system to confront the problem,” Eklund said. “But in the end, this is about information and education. People need to understand that the law will apply to abusive behaviour online just as it does offline. You cannot hide behind anonymity or a screen.” Jon Henley

Australia

Australia has broad criminal laws that could be used to prosecute individuals for online abuse, but a consistent problem raised is education across the board.

The most important federal law that covers this area is an offence in the Criminal Code that makes it illegal to “menace, harass or threaten” using a carriage service. This has been used to punish serious cases of abuse on social media sites such as Facebook or Twitter.

Recently a 25-year-old Australian man, Zane Alchin, was charged after allegedly making rape threats on Facebook. It is alleged that Alchin made the threats after one of his friends shared a Tinder profile of a woman on his Facebook page with an explicit caption, and an argument broke out on the social networking site. He has pleaded not guilty.

In Alchin’s case, the response from police, rather than the law itself, has raised bigger concerns. The woman who made the complaint, Paloma Newton, said police were not responsive to her allegations and she was initially rebuffed by officers.

“The training needs to be way better,” she said. “The cop I spoke to didn’t even have Facebook – explaining to her the post, the reposting, the screenshotting, the comments, was harder than it needed to be.”

Facebook Twitter Pinterest A 25-year-old Australian has been charged after allegedly making rape threats on Facebook. Photograph: Karen Bleier/AFP/Getty Images

There is also a plethora of state and territory laws that can operate in different circumstances. In some states, such as New South Wales, making threats is an offence in itself. Although mere words won’t generally be considered assault, in some very serious cases they have been found by courts to be sufficient to constitute an offence.

Revenge pornography is a less clearly covered area in Australian law. While two states – Victoria and South Australia – have introduced their own laws to criminalise the sharing of intimate photos without consent, there’s no federal laws covering everyone.

In February, a Senate committee recommended the federal government introduce a national law to criminalise unauthorised sharing of intimate photos. Paul Farrell Sydney

Democratic Republic of Congo

In the Democratic Republic of Congo, which has staggeringly high rates of sexual violence, online abuse against women is not taken seriously.

“People see that you are still walking and able to do whatever you used to do, so there is a denial of emotional, psychological, moral pain. The only violence that is recognised as such is the cruellest and most visible sexual violence done in relation with armed conflicts,” says Francoise Mukuku, executive director of Si Jeunesse Savait, one of seven organisations that took part in Take Back the Tech research.

Despite this, problems with online harassment are significant in the country, in particular the non-consensual sharing of intimate images. Women and LGBT people are frequently targeted for abuse.

Facebook Twitter Pinterest A rape victim in the Democratic Republic of Congo talks to a counsellor. High rates of sexual violence in the country means that online abuse is not taken seriously. Photograph: KeystoneUSA-ZUM/Rex Shutterstock

There are no laws that specifically protect people against online harassment, and prosecution for these crimes is non-existent. The situation is made more difficult by corruption within the system, says Mukuku. She says police officers will often ask women for bribes before taking on their case and victims who report crimes to police risk being prosecuted for ruining the reputation of their attacker. Because of this, as well as a lack of understanding of the issues and fear for their reputation, most victims do not report abuse to the police.

One example of the lack of recourse available to victims was seen in the recent case of a young student who was filmed by her boyfriend, without her knowledge, while they were having sex. The video was shared online and her family made her flee the country out of “shame”. No prosecution was brought against the boyfriend, who has since graduated from university.

Campaigners want online abuse recognised as a significant issue. “We want decision-makers to recognise that although online abuse might not cause actual physical harm in all instances, it can also cause significant emotional and psychological harm, as well as impact on issues such as mobility, employment and public participation, which are equally important factors to address,” says Mukuku. Kate Lyons

US

In 2014, the journalist Amanda Hess chronicled her efforts to engage with the American criminal justice to end two cases of cyberstalking. The first time she went to police, in 2009, it was after a reader began issuing graphic rape threats online and then escalated this to phone calls; the police refused to do anything unless the man making the threats showed up at her apartment.

She was eventually able to use a then-recent change to the law that allowed her to file for a civil protection order in family court. The order lasted for a year; he started to contact her again as soon as it expired.

Facebook Twitter Pinterest American journalist Amanda Hess who has written about her experiences of being stalked online. Photograph: Social media

The second time, in 2013, an anonymous Twitter user promised her: “You are going to die and I am the one who is going to kill you.” The police officer who arrived asked her to explain what Twitter was. Hess never found out if the anonymous Twitter user was her original harasser, or someone else.

These cases aren’t unique: there have been numerous cases of online harassment reported to police, including Anita Sarkeesian, Zoe Quinn, Brianna Wu and Rebecca Watson – with little effect.

Research into online abuse by Pew in 2014 said that 40% of people had experienced some form of harassment on the internet – and that young women were among the most commonly targeted groups.

In June 2015, the US supreme court decided in favour of Anthony Elonis, who posted graphic depictions on Facebook of his desire to kill his estranged wife, saying they weren’t a crime if he didn’t intend to follow through and the trial hadn’t established Elonis’ intent.

Prof Danielle Citron, an expert in law and online harassment, told Fast Company that there was an small upside to Elonis’ win: “It implicitly suggests that threats online are no different [than threats made via other interstate communication methods]” – which was not the case before the decision.

That’s little comfort to victims of online harassment, who still face uninterested or uninformed law enforcement officers when they report, a patchwork of laws that makes harassment difficult to prosecute across state let alone international lines, and a civil process that is expensive and time-consuming even when it works at all.

Citron suggested a few solutions, including making sure that laws are technology and platform agnostic; allowing prosecutors to present to judges and juries a totality of the abuse; and increasing penalties for those convicted. Megan Carpentier New York