DIGITAL COLONIALISM 2.0: HOW GLOBAL SOUTH DATA FUELS GLOBAL NORTH ARTIFICIAL INTELLIGENCE

Author- Anubhuti Singh

Dr. Ram Manohar Lohiya National law University, Lucknow

ABSTRACT

This analysis presents Digital Colonialism 2.0. The article maintains that our current economy, which is data-driven, is a reflection of the same practices of colonialism in the form of extractive resource economics, regional dependency and inequalities between governance structures within the Global North and Global South.The article draws parallels to resource exploitation that occurred during the period of colonisation and is now occurring through data extraction practices. The definition of data is a product produced from the Global South, but each step in the process of usage, trade and ownership is completed by a corporation that is located in the Global North.

Dependency theory will be the basis for the analysis of the role of digital infrastructure, artificial intelligence (AI) systems and cloud platforms as a mechanism to facilitate value creation and value accumulation for these corporates.In addition to analysing data generated in the Global South and the labour of digital data workers from the Global South to train AI systems in the Global North, the article critiques consent-based governance, demonstrating that consent is typically a legal fiction because of the coercive nature of digital architectures, the lack of transparency regarding who owns and profits from the use of data, and the broader socio-economic inequalities that exist. Finally, the article argues that the concentration of cloud computing infrastructure within a small number of multinational corporations creates "cloud empires" that undermine the ability of lesser-developed countries to have control over their data; they dominate how much data is exchanged, how much is charged for its exchange, and what standard should apply to data governance (pricing, regulation, etc.).

In conclusion, the article calls for a transition from compliance-based to data justice in the form of equity, participatory governance, and global collaboration. The article contends that unless power, ownership, and advantages of data are distributed fairly, we can anticipate that digital technologies will further create inequitable outcomes in the digital age.

1.     From Plantations to Platforms: A Familiar Extraction Story

The relationship of the colonial powers and their colonies was that while the colonial powers took resources from their colonies (i.e., cotton, rubber, minerals) and turned them into money in the distant imperial centres that controlled those colonies, the relationship between the Global North and the Global South today regarding the digital economy is similar in structure and outcome.While the Global South is where much of the data is generated, that data is processed, monetised, and controlled by corporations located in the Global North. Scholars refer to this imbalance as "data colonialism", because the infrastructure of the digital economy continues to replicate the exploitation and systemic dependency that existed historically between the colonies and their imperial centres. Additionally, UNESCO[1] has reported that "the rapid expansion of digitalisation has resulted in large disparities between the Global North and Global South".[2] Furthermore, both Couldry and Mejias have successfully made comparisons between current data practices and the appropriation of land, describing data extraction as "a land grab in progress".[3] According to this perspective, data is effectively the new commodity that is being freely taken, unequally valued, and centrally governed. Though modern data extraction is similar to extraction in the past, the current practice exists within the absence of effective international legal mechanisms that would protect the communities from which the data is derived, relying instead on fragmented and localised regulations that only operate within national and sub-national boundaries.

By applying dependency theory, we can see that the core structure of the peripheral economy remains dependent on the dominant economy for value creation and accumulation.[4] Even though formal colonialism has ceased to exist, digital infrastructure (digital platforms, algorithms, and data governance systems) now provides the means through which control is exercised. Since no binding international law exists to govern the extraction of cross-border data, multinational corporations are able to accumulate wealth and power while at the same time externalising social and regulatory costs.[5] Therefore, digitalisation represents not only technological evolution but also operates as a political-economic process that recreates established patterns of extraction, dependency and unequal governance in the digital age.

2.     How Global South Data Trains Global North AI

In the same way that colonial powers took raw materials from their colonies to make the imperial centre richer, today, people’s digital activities (in the Global South) – such as their social media interactions, online shopping, mobile payments, and biometric ID use- are the raw data used by artificial intelligence systems in the Global North. In fact, Artificial Intelligence (AI) systems rely not only on big data but on huge amounts of human input and intervention.[6]The work of developing AI consists almost solely of repetitive, low-wage, and high-pressure tasks, yet they remain unqualified as skilled labour, even though they are essential to the overall success of AI development, meaning that the human aspect is very rarely considered in the conversation around innovation and AI.In addition to human inputs needed for large datasets to be created and labelled, there is also a lot of human labour that goes into preparing the massive datasets for the training of algorithms. Most of these employees have short-term contracts or work through crowdsourcing platforms, which provide little or no transparency regarding accountability. This means that they are at risk of wage theft, do not have access to social protections and work in dangerous environments; yet without them, these workers are essential for providing accurate and fair AI systems.As has been reported in the news, it is increasingly common for this kind of labour to be outsourced to developing countries like Kenya, India, and the Philippines, where workers perform the work of "training AI models" by filtering and classifying data while working in difficult and often mentally taxing environments.[7]In spite of the importance of this work to our economy, there are many contractual relationships that do not benefit from any formal protections, exposing the inadequacies of the current systems for categorising workers, ensuring their workplace safety, and allowing them to collectively bargain. There is a structural inequality present throughout the Global North and Global South, and this is reflected in the AI value chain, where the economic value generated from the data, and the payouts to the workers are vastly different - a systemic injustice in place.Workers from these countries earn very low wages (relative to other industries in their respective countries) and often work in jobs that do not enjoy the protections offered to workers under Labour legislation, despite the fact that they are essential to the development of the accuracy and safety of AI technologies.[8] Furthermore, the legal ownership of datasets, AI models, and the intellectual property rights associated with both are held by corporations in the Global North, where most of the largest corporate headquarters and data storage facilities for these companies are located. Therefore, while the majority of data generation and digital labour occurs in the Global South, economic value, control of regulations and authority to make decisions remain in the Global North, reinforcing an extractive power imbalance associated with colonial economic relations.[9]

3.     Consent Without Power: The Myth of Free Choice

While consent serves as the legal underpinning for lawful data processing in many jurisdictions, itis often viewed as a formality when individuals do not have sufficient choice. For example, so-called clickagreements (i.e., contracts signed by clicking an "I agree" button), as well as preconditioned agreements, can lead to an individual being coerced into accepting data collection terms for essential services.[10]This occurrence is sometimes called "consent fatigue," in which users receive far too many lengthy and complicated contracts that they are not going to read or understand. As a result, a vast majority of users will automatically accept these types of contracts without understanding how much data will be collected or how they'll be used which is a critical issue regarding whether or not any legal framework for obtaining consent is effective if there is no autonomy or understanding of what is being agreed to.Academic research on digital consent has shown that, unfortunately, many individuals accept complex terms without understanding the implications of those terms related to the processing, sharing, and monetisation of their data.[11] In India, the issue of Aadhaar typifies the breakdown of the relationship between the legal status of consent vis-à-vis the substantive nature of consent. While the Supreme Court of India affirmed that the right to privacy is a fundamental right under Article 21 of the Indian Constitution[12], the Court did not rule out a reasonable expectation of privacy where such privacy had not been violated through either consent or through unreasonable statutory means.[13]Structural and systemic pressures associated with needing to associate an individual’s identity with required government services through an Aadhaar System demonstrate how seemingly voluntarily provided consent can be transformed into a coercive obligation. Similar issues can be seen in other jurisdictions such as the European Union’s General Data Protection Regulation (GDPR).[14] In those jurisdictions, even though legal consent is formally required, individuals generally do not have the ability to negotiate meaningful terms. These issues illustrate a global problem, as consent is at risk of acting as a legal fiction instead of a true protection of one’s individual autonomy unless power imbalances and lack of transparent information are effectively addressed.It is worth noting how the structural requirement imposed by the Government of India for linking Aadhaar to banking, welfare, and/or education ultimately creates a system of coercion and effectively removes the possibility for refusal. The coercive nature of this environment illuminates how, in many instances, particularly in countries with unequal socio-economic status, consent reflects permission without any measure of bargaining power.

4.     Cloud Empires and Borderless Power

Digital infrastructure, cloud services, data centres, and cross-border data channelshave been used to intensify inequalities between the global North and South beyond that of just data extraction.[15] The cloud services market is dominated by a handful of global multinational cloud providers, predominantly AWS, Azure, and Google Cloud, that make up an overwhelming majority of this market's infrastructure.[16] The dependence on these foreign providers means firms based in North America and Europe define the legal and technical terms, as well as geographical boundaries, for processing and transferring data. The Global South's dependence on foreign services limits its bargaining power when it comes to negotiating the terms of service agreements and regulatory standards, while exposing it to legal regimes that may permit excessive surveillance or provide for excessive access to information based on the laws of one country. This concentration creates what are referred to as “cloud empires” that are dominated by only a handful of corporations, giving these companies significant control over data flow, pricing, and service availability.[17] Most countries in the Global South lack alternative data centre options that are regionally based, and as a result, governments and businesses have no choice but to accept contract terms that have already been predetermined with little or no meaningful negotiation. This creates or exacerbates issues around economic dependency on foreign corporations, creates or continues to perpetuate economic inequity, and creates security and privacy risks, as the policies of these companies rather than local regulations often govern operational risk, and thus the Global South assumes the liability associated with these risks without having the ability to exercise control over the risks or mitigate their potential impact. This imbalance needs immediate attention through investment in local data centres, regional cloud providers, and government-supported digital public infrastructure, in order for the Global South to regain its strategic independence.The debates surrounding data localisation illustrate attempts to regain control over digital assets; however, without complementary legal safeguards supported by robust legal frameworks balancing sovereignty and interoperability, the cost of doing business will increase, and the global data ecosystem will become increasingly fragmented.[18] Many countries have achieved political independence without achieving true digital sovereignty.Achieving true digital sovereignty ultimately involves a mixture of domestic policy reform, cooperation between states, and a commitment to invest publicly in digital infrastructure, so as not to complete the transfer of digital assets to foreign corporations, and to ensure that the benefits resulting from processing data will be shared fairly with local communities.

5.     Beyond Regulation: Towards Data Justice and Digital Sovereignty

Moving beyond critique, we need to rethink how to govern data using equity as the base, instead of compliance. Increasingly, data is viewed by international institutions as serving a collective interest. The UN Secretary-General points out that "Data should be used to support the development of all individuals"; therefore, we need governance frameworks that treat Data as a Public Good instead of just Private Capital.[19] By strengthening South-South cooperation on Technology Policy and investing in state-owned Digital Public Infrastructure, it will diminish reliance on the Foreign Platforms (example:LinkedIn and Facebook, etc.) (as demonstrated by the National Digital ID and Payment systems supported by the World Bank).In addition to this, it is also important to ensure that Data and Digital Labour (which are still very much underpaid) are compensated fairly because they do not currently exist in existing legal frameworks. To reach data justice, it is essential to incorporate the principles of transparency, accountability and participatory governance in all policies related to data, ensuring that individuals, communities and nations have a say in how their data is collected, processed and monetised. Legally recognising digital labour as a form of productive work gives workers the rights of protection, fair payment and the ability to negotiate collectively. These standards for the sharing of data, ownership and the distribution of benefits from shared data should be defined through international treaties and transnational cooperation agreements to provide enforceable regulations against Global North dominance in data provisioning.Finally, it is important to have Global Frameworks that incorporate Data Justice within the framework; this ensures that those who generate the Data also receive the benefits from that Data. Digital Sovereignty cannot be separate from economic justice and social justice; therefore, it requires coordinated efforts between government, civil society and the private sector. Failure to take deliberate steps toward redistributing control, value and governance of data means that technology will likely continue to reproduce long-standing injustices in a new format in a digital form. The overall result will be that AI and other data-driven technologies will serve only the interests of corporations, but will benefit all groups of people, especially those who reside in the Global South.Therefore, if Data is to be used as the "fuel for Artificial Intelligence, " justice will also depend upon who will benefit from the Data! It must also be determined who owns the Data.

[1]UNESCO, United Nations Educational, Scientific and Cultural Organization.

[2]BitangeNdemo, “ Addressing digital colonialism: A path to equitable data governance”,  UNESCO Inclusive Policy Lab,  08 August, 2024, available at<https://en.unesco.org/inclusivepolicylab/analytics/addressing-digital-colonialism-path-equitable-data-governance> (18^th December, 2025)

[3]Nick Couldry, Ulises A. Mejias, “ The Cost of Connection” ( Stanford Publishing Press, Stanford, California, 2019) available at <https://law.unimelb.edu.au/__data/assets/pdf_file/0008/3290381/Couldry-and-Mejias-Preface-and-Ch-1.pdf>  ( 18^thDecember, 2025)

[4]Safran Safar Almakaty, “A Comprehensive and Critical LiteratureReview of Dependency Theory from2005 to 2025 in the Context of theDigital Age”, Preprints, 8^thDecember, 2025, available at <https://www.preprints.org/manuscript/202512.0726/v1/download#:~:text=1.,has%20proven%20to%20be%20a> (18^thDecember, 2025)

[5]Supra note 2.

[6]Spencer Feingold, “ What is Artificial Intelligence  - and What is it not?”, World Economic Forum, 8^th March, 2023, available at<https://www.weforum.org/stories/2023/03/what-is-artificial-intelligence-and-what-is-it-not-ai-machine-learning/?gad_source=1&gad_campaignid=22234048793&gbraid=0AAAAAoVy5F6_XFI5Y9B8aYHKdSDHrnjQg&gclid=Cj0KCQiAxonKBhC1ARIsAIHq_lsdJXIEHucWUBv9EBtF4ndl3KI-6RiQ27nEig-v7wnvN0Mk4Coz8eUaAu_EEALw_wcB>  ( 19^th December, 2025)

[7]Arwa EIGhadban, “ The Return of East India Companies: AI, Africa and the New (Digital) Colonialism”, Data Pop Alliance, 3oth January, 2023, available at<https://datapopalliance.org/the-return-of-east-india-companies-ai-africa-and-the-new-digital-colonialism/>( 20^thDecember, 2025)

[8]Michelle Du and Chinasa T. Okolo, “Reimagining the future of data and AI labor in the Global South”, Brookings, 7^th October, 2025, available at<https://www.brookings.edu/articles/reimagining-the-future-of-data-and-ai-labor-in-the-global-south/> (20^th December, 2025)

[9]Manasi Sinha and Nandini Vengattaramanan, “ globalsouthmust reclaimdata sovereigntyneeddatadecolonization” South Asian Monitor, 13^th November, 2025, available at<https://www.southasiamonitor.org/spotlight/global-south-must-reclaim-data-sovereignty-need-data-decolonization> (22^nd December, 2025)

[10]Ironclad, “ What is a Clickwrap Agreement’, Ironclad, 21^stJune, 2021, available at<https://ironcladapp.com/journal/contract-management/what-is-a-clickwrap-agreement> (22^ndDecember, 2025)

[11]Abhisekh Sharma, “From Click to Contract: The Legal Validity of Consent in India’s Social Media Data Ecosystem”,  IJLSI, 2021, available at<https://ijlsi.com/paper/from-click-to-contract-the-legal-validity-of-consent-in-indias-social-media-data-ecosystem/>( 23^rdDecember, 2025)

[12]The Constitution of India, art. 21.

[13]Umang Podder, “Five years after the SC upheld the right to privacy, why does India lack a data protection law?”, Fcroll.in, 23^rdAugust, 2022, available at <https://scroll.in/article/1031054/five-years-after-the-sc-upheld-the-right-to-privacy-why-does-india-lack-a-data-protection-law>( 24^thDecember, 2025)

[14]European Union’s General Data Protection Regulation (GDPR), 2018.

[15]Neos Network, “What is Digital Infrastructure?”, Neos Network, 30^thJanuary, 2024, available at<https://neosnetworks.com/resources/blog/what-is-digital-infrastructure/>( 26^thDecember, 2025)

[16]Cody Singerland, “21+ Top Cloud Service Providers Globally In 2025”, Cloudzero, 21^stMarch, 2025, available at<https://www.cloudzero.com/blog/cloud-service-providers/>( 26^thDecember, 2025)

[17]Meghan Neville, “ The Ultimate List of Cloud Computing Stats for 2026: Market Growth, Adoption & Security Trends”, Softjurn, 21^st January, 2026, available at <https://softjourn.com/insights/cloud-computing-stats> ( 28^th January, 2026)

[18]Rana Saurav, Kumar Singh, Ujjwal Snehil Raj, Umang Sagar, Ramkrishna Rajak, “Data Localization And Its Impact On Cross-Border Digital Trade In India: Legal, Economic, And Strategic Implications", Educational Administration: Theory and Practiced, 20^th March, 2024, available at<https://kuey.net/index.php/kuey/article/view/10130> ( 2^nd January, 2026)

[19]United Nations, “ Report of the Secretary General Roadmap for the Digital Cooperation”, (June 2020).

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