CHAPTER 7
Institutional Responses of European Countries
Jan Hanzelka and Miroslava Pavlíková
7.1 Introduction
After the Ukrainian conﬂict began in 2014, disinformation campaigns
were identiﬁed in various European countries. Occurrences like the Brexit
campaign ‘#leave’ inﬂuence operations during parliamentary elections in
Europe (in Germany or France, for example) or domestic active measures
scandals, such as Austria’s Freedom Party of Austria (FPÖ) stressed the
need to counteract such tactics and protect targets—nation states as well
as supranational structures. The dynamics of inﬂuence operations and
forms of disinformation dissemination are very fast, ﬂexible, and even
harder to maintain.
In reaction to the latest disruptive propaganda campaigns in Europe,
the institutions of some countries have focused on countermeasures.
Some include the establishment of special governmental bodies, the installation
of special task force groups, new laws, and active cooperation
J. Hanzelka · M. Pavlíková (B)
Department of Political Science, Faculty of Social Studies, Masaryk University,
Brno, Czechia
© The Author(s), under exclusive license to Springer Nature
Switzerland AG 2021
M. Gregor and P. Mlejnková (eds.), Challenging Online
Propaganda and Disinformation in the 21st Century,
Political Campaigning and Communication,
https://doi.org/10.1007/978-3-030-58624-9_7
195
196 J. HANZELKA AND M. PAVLÍKOVÁ
between governments, political parties, media, non-governmental organisations,
and academia. However, particular counter steps, the willingness
of authorities, and the adequacy of measures differ. This chapter analyses
how European countries deal with malicious online disinformation and
propaganda. We will assess the European state authorities’ and institutions’
countermeasures against information warfare, especially the good
examples and speciﬁc approaches of particular countries. The text focuses
on lessons from election interference and the preparedness of particular
countries, taking into consideration long-term measures as well.
According to the mentioned approaches, we have formulated a categorical
framework for the analysis of institutional countermeasures, which we
then use to analyse the cases of several European countries.
Actors who aim to defend themselves against propaganda and disinformation
campaigns need to study the newest cases, technologies, and
tactics to counter these hostile activities effectively. Although we can
perceive coordination efforts on the international level, there are still
many differences between European states in their approaches to countermeasures.
There are good examples of preparation, active responses, as
well as coordination and the sharing of good practices among states. On
the other hand, some actors still have a lot to learn. In this chapter, we
will focus on three examples from across Europe: The case of Denmark
demonstrates a country which has a leading position in countermeasure
formulation; in central Europe, Czech Republic is an example of
a country which is ‘half-way’; and the south-eastern European country
of Bulgaria reveals a country with barely noticeable measures. All three
countries are members of the European Union and NATO. However,
all three have different approaches to challenging propaganda and disinformation,
and they thus make evident how different political attitudes,
different histories, and different starting positions can affect the approach
towards countermeasures.
7.2 Framework for Analysis: Institutional
Countermeasures Against Influence Operations
In the following section, a framework with types of institutional responses
for the complex analysis of case studies is proposed. In this chapter,
inﬂuence operations instead of disinformation and propaganda are often
mentioned, even though this concept is more complex and also covers
other activities (see Chapter 1). The reason is European states’ usage of
7 INSTITUTIONAL RESPONSES OF EUROPEAN COUNTRIES 197
inﬂuence operations in its proclamations and documents. Countermeasures
against disinformation and propaganda are often part of the bigger
package covered under the inﬂuence operations’ umbrella.
The particular categories are derived from the most viable countermeasure
examples found in different European countries and existing
frameworks, which have been evaluated as relevant and actual. The
framework proposal by Brattberg and Maurer (2018) of the Carnegie
Endowment for International Peace serves as inspiration in its consideration
of good examples from chosen European countries (Germany,
Sweden, France, and Netherlands). It focuses on resilience and legal
measures, public statements, and the education of voters as it concerns
disinformation campaigns. They also suggest training and educating political
parties, conducting government-media dialogue, engaging media
companies to mitigate threats, and, ﬁnally, sharing lessons learned as
well as best practices to support international cooperation. Moreover,
the authors suggest clearly warning citizens about possible interference,
promoting citizen fact-checking and investigative journalism, and urging
political parties to assert that they will not use social media bots. This
might generally cover avoidance of negative campaigns and usage of disinformation,
as well as placing stress on transparency (see Flamini and
Tardáguila 2019). The analysis is secondly inspired by the categorisation
of the Ministry of Foreign Affairs of Denmark, which presented 11 initiatives
to counter hostile inﬂuence operations. Besides the abovementioned
responses, Denmark suggests the establishment of an intergovernmental
task force to strengthen the monitoring of disinformation, train communication
ofﬁcers, and reinforce intelligence services activities (Ministry of
Foreign Affairs of Denmark 2018).
The following section will introduce particular categories and their
measures. Furthermore, examples of real countermeasure usage will be
explained with a focus on European countries. These examples have been
chosen based on the availability of information and the possible effectivity
of the countermeasures. The aim is to focus on good or even best
practices. However, it is obvious, that some countermeasures are unique
and evaluation on effectivity needs historical distance. In accordance with
an index from the European Policy Initiative of the Open Society Institute
(2018, In: Mackintosh and Kiernan 2019) measuring the post-truth
phenomenon in countries, the Scandinavian countries, Estonia, and the
Netherlands rank ﬁrst. If possible and available, good examples from these
countries are described in more depth. Besides European countries, we
198 J. HANZELKA AND M. PAVLÍKOVÁ
also focus on the supranational level. Countermeasures from the European
Union and NATO will also be assessed, including the actions of
particular European countries in regard to these supranational entities. We
consider this one of the categories for analysis, and it is listed in Table 7.1.
7.2.1 Actions with the Public
The institution of clear warning resonates especially with the secret
services or other governmental bodies in terms of its impact on security.
Secret services might occasionally present warnings about serious
security issues or present actual threats in their annual public reports.
Warning by secret services might have greater value for the public than the
proclamations of other authorities. In the Netherlands, for example, the
2018 annual public report of the General Intelligence and Security Service
(Algemene Inlichtingen- en Veiligheidsdienst in Dutch) mentioned covert
Table 7.1 Categorisation of institutional countermeasures against inﬂuence
operations
Category Activities
Actions with the public Clear warnings
Public statements
Voter education
Education of parties
State measures Establishment of special ministerial bodies or
other state institutions
Employee education
Legal measures Implementation of legal measures
Cooperation with business
Actions with the media Train communication ofﬁcers
Strengthen disinformation monitoring
Support investigative journalism
Actions with political parties Urge parties into political culture compliance
Organise training for political parties and
campaigners
Direct countermeasures Information operations against hostile actors
Diplomatic pressure
Actions with supranational entities Cooperation
Join task forces
Join discussions
Accept recommendations
Source Authors
7 INSTITUTIONAL RESPONSES OF EUROPEAN COUNTRIES 199
inﬂuence and manipulation of the public perception by Russia and China
(General Intelligence and Security Service 2018). It also informed about
surveillance by the Russian hacking group Cozy Bear, after which they
publicly attributed an attack to Russia (Brattberg and Maurer 2018).
In a public report from March 2019, the Estonian Foreign Intelligence
Service (Valisluuveramet) warned about the Russian threat before the
European parliamentary election, revealing that France, Germany, and
Italy were the main targets (Estonian Foreign Intelligence Service 2019;
EU Observer 2019). The report considers cyber threats by Russian secret
services especially, in addition to mention of troll activities, to be an integral
part. A recent Estonian report also stresses that ‘China is more and
more active in inﬂuence operations and propaganda’. Islamic State propaganda
in Europe is also highlighted. In May 2019, the Federal Ofﬁce for
the Protection of the Constitution (Bundesamt für Verfassungsschutz) in
Germany, warned against the Austrian government (saying it could not
be trusted) because of its ties to Russia and a possible information ﬂow
between them (Stone 2019). The whole warning derives from the activities
of the then governing party FPÖ, the Russians, and negotiations
about the production of favourable media coverage.
Naturally, a lot of clear warnings or public attributions were made by
governments, politicians, and other high state authorities. French President
Emmanuel Macron, the British foreign secretary at the time, Boris
Johnson, as well as German chancellor Angela Merkel warned against
Russian interference into election processes (Brattberg and Maurer 2018).
This might be connected to public statements and voter education, which
is often utilised by governments or authorities. An interesting example can
be found in the French government’s clear labelling of Sputnik and RT
as pro-Kremlin outlets, and their subsequent exclusion from press conferences
in Élysée Palace as well as regular refusal in covering ofﬁcial events
(EUvsDisinfo 2019). The Swedish Civil Contingencies Agency, under the
Ministry of Defence, launched an awareness campaign for public education
about propaganda (Robinson et al. 2019). In a 20-page-long document
called If Crisis or War Comes, a chapter about false information has its
place with easily written advice and interactive questions (Swedish Civil
Contingencies Agency 2018). The government also planned to teach
children in primary schools how to recognise fake news (Roden 2017).
A similar governmental approach appeared in Finland as well (Charlton
2019). CNN labelled Finland a country which is winning the war on fake
news (Mackintosh and Kiernan 2019). The government’s anti-fake news
200 J. HANZELKA AND M. PAVLÍKOVÁ
programme is based on cross-departmental engagement, learning best
practices from around the world, and a bottom-up approach starting with
country’s education system1 (KennyBirch 2019). Public governmental
campaigns in the United Kingdom have intensiﬁed after the Skripal case.
Shortly after the attack, the UK government established communication
teams which informed the public about Russian manipulative tactics.
Currently, the British government is starting a public campaign focused
on empowering citizens in disinformation recognition and awareness of
its malicious effects. The campaign started with the issue of measles and
vaccination against it.
7.2.2 State Measures
State measures is mostly meant as the formation of special governmental
or state bodies, strengthening the role of institutions in the inﬂuence
operations ﬁght, and other intragovernmental provisions. In some countries,
special task forces or other ministerial bodies have been established
to counter-inﬂuence operations. In 2017, as a reaction to Russian activities,
the Danish government established an inter-ministerial task force for
countering these campaigns. This special body coordinates efforts across
government as well as Danish national intelligence and security services
(EUvsDisinfo 2018). In Sweden, for example, a psychological defence
authority (psykologiskt försvar) has been launched. This authority focuses
on countering disinformation and boosting the population’s resistance to
inﬂuence operations. In the Netherlands, the National Coordinator for
Security and Counterterrorism received in 2019 responsibilities related
to the detection of inﬂuence operations run by foreign state powers.
In Czech Republic, the Ministry of the Interior established the Centre
Against Terrorism and Hybrid Threats for expert and analytical activities,
including disinformation campaigns (Ministry of the Interior of
the Czech Republic 2017). Its activities remain mostly classiﬁed. In
Ukraine, meanwhile, a whole ministry focusing on information policy
was founded. The ministry was established to ﬁght against information
attacks (Interfax-Ukraine 2014). In 2019, it presented a white book on
information operations against Ukraine (Bila kniga specialnih informacijnih
operacij proti Ukra|ni, see Ministry of Information Policy of Ukraine
1For example, the project for schools called ‘Facts, please!’.
7 INSTITUTIONAL RESPONSES OF EUROPEAN COUNTRIES 201
2018) considering Russia’s inﬂuence operations in the country between
2014 and 2018 (Ukrainian Independent Information Agency of News
2019).
As regards state employee education, Finland launched a programme
on countering propaganda for government ofﬁcials. The programme
emphasises the importance of creating a new narrative which highlights
Finnish values and a ‘Finnish story’ (KennyBirch 2019). In Sweden,
the Civil Contingencies Agency produced a manual countering information
operations which might target public service workers (Klingová
and Milo 2018). Countering Information Inﬂuence Activities: A Handbook
for Communicators (Swedish Civil Contingencies Agency 2019)
provides techniques and advice on how to counter information inﬂuence
operations, including preparing organisations for a quick and effective
response.
7.2.3 Legal Measures
Focusing on legal measures would take an entire chapter or even book
(see Chapters 4 and 6 for European level of legal measures), thus we will
cover only special laws reacting to disinformation. In Italy, for example,
citizens can use a special online service where it is possible to report fake
news to the police (Robinson et al. 2019). After abandonment of this
measure, a bill proposing sentences for spreading fake news was tabled
in 2017. In 2017, Germany passed a law called NetzDG which is meant
to combat fake news and hate speech on the Internet. Under this law,
social media platforms have 24 hours after receiving a report to remove a
post which violates German law. It furthermore forces networks to reveal
the identities of those behind posts. The law has become a subject of
discussion about freedom of speech violations (Bleiker and Brady 2017).
In 2018, the French parliament passed a law related to election
campaigns, according to which the electoral jurisdiction has a responsibility
to decide on the withdrawal of manipulative materials from the
Internet. However, there must be evidence that such material was intentionally
spread on a wide scale with the intention of interfering and
disrupting the elections (Rozgonyi 2018).
Nevertheless, these legal measures have a few weaknesses. First of
all, they mix together terrorist content, hate speech, and acts that are
part of inﬂuence operations. However, inﬂuence operations may demand
different counter approaches than terrorist propaganda. Secondly, the
202 J. HANZELKA AND M. PAVLÍKOVÁ
legal measures focus on content and do not deal with the tools and techniques
of inﬂuencing, for example, the use of fake accounts, bots, and
algorithms.
Currently, we can see a trend in the efforts of European governments
to engage the cooperation of Facebook and Google in the case of
negative social issues.2 General efforts, such as systematic work towards
‘stopping of misinformation and false news’ can be seen. In Facebook’s
‘Community Standards’ there is a paragraph which reads, ‘There is also
a ﬁne line between false news and satire or opinion. For these reasons,
we do not remove false news from Facebook, but instead signiﬁcantly
reduce its distribution by showing it lower in the News Feed’. The article
is part of a broader Facebook strategy to handle fake news (Facebook
2019). This solution is dependent on the problematic identiﬁcation of
fake news without deep research and fact-checking. They are trying to
avoid accusations of political persecution from certain opinion groups,
which would otherwise be faced with the deletion of content. In certain
countries (Facebook 2020), Facebook has third-party fact-checking partners.
There, partners are trained to assess the truth of a post and, in the
case of fake news, use predeﬁned tools to limit the available contributions
or prohibit monetisation (Facebook 2020). Google has a similar initiative,
which is described in the white paper How Google Fights Disinformation
(Google 2019). The Google initiative is based on ranking and labelling
content, and the results are reﬂected in the search algorithm. Less credible
news is less relevant in a search. Google declares that they ‘welcome
a constructive dialogue with governments, civil society, academia, and
newsrooms’ (Google 2019).
7.2.4 Actions with the Media
Cooperation with media might play a key role in controlling the disinformation
ﬂow as well as promoting media literacy. Belgium provides an
example of an active approach from government to media. The Flemish
Ministry of Education and Training sponsors Média Animation ASBL, a
media education resource which focuses on media literacy in schools as
well as for politicians and other decision-makers (Kremlin Watch 2020;
2An example is the problem of hate speech and current German legislation, which is
trying to delegate responsibility for this issue to social media providers (Hanzelka and
Kasl 2018).
7 INSTITUTIONAL RESPONSES OF EUROPEAN COUNTRIES 203
Media Animation ASBL 2020). The Swedish government also expressed
the will to cooperation with media when the government, together with
the Swedish national television broadcaster, invested in a digital platform
providing automatic fact-checking and news in a way which crosses the
borders of ﬁlter bubbles. In Latvia, we can ﬁnd an example supporting
investigative journalism since 2017. The new programme was launched
under the auspices of the Ministry of Culture, and it has ﬁnancially
supported about 20 projects (Robinson et al. 2019). Another interesting
example of an approach to media can be found in Estonia. Its politicians
and administration ofﬁcers claim they never give interviews to Russian
state-controlled media (Sternstein 2017). Some countries must also deal
with its Russian minorities and the need for Russian-language media;
this is mostly relevant in the Baltic countries. Estonia started its own
Russian-language channel in 2015. This repression of Russian-language
sources with connections to the Russian government is also a strategy
some countries deploy to protect minorities. In Lithuania, for example,
the government pulled RTR-Planeta, run by the Russian government, off
the air (PressTV 2017; Sternstein 2017).
7.2.5 Actions with Political Parties
There are many discussions over voter education about disinformation,
but little is said about the education of political parties. Moreover, as
for example the Brexit referendum has shown,3 political parties might
have a strong role in the spread of disinformation. However, only a few
examples of this kind of political culture improvement can be found.
German political parties entered into a ‘gentlemen’s agreement’ before
the 2017 election. They stated they would not use leaked information
for political purposes, nor use social media bots (Brattberg and Maurer
2018). In Finland, the education of political parties is part of a crossdepartment
strategy.4 The electoral administration under the Ministry
3For example, the connection between the far-right United Kingdom Independent
Party (UKIP) and the company Cambridge Analytica using big data from Facebook to
produce a micro-targeted campaign (see Chapter 2) (Scott 2018).
4A so called whole-of -government approach also covers the coordination of monitoring,
evaluation, and management of hybrid threats. A special government ambassador ensures
cooperation between institutions as well as the private sector, and an inter-ministerial
group deals with inﬂuence operations (Klingová and Milo 2018).
204 J. HANZELKA AND M. PAVLÍKOVÁ
of Justice organised anti-disinformation training for political parties and
candidates. Trainings are conducted in various regions so as to be available
to everyone. Training should help candidates to recognise and report
suspected disinformation and improve their cybersecurity (France 24
2019; KennyBirch 2019).
7.2.6 Direct Countermeasures
We found it necessary to also mention real time counter-propaganda as
a governmental response. After the poisoning of double agent Sergei
Skripal, many European countries expelled their Russian diplomats. This
represents a typical example of a direct countermeasure on the state level.
No action like this was taken in connection with a hostile propaganda
campaign. However, other forms of direct reactions can be identiﬁed.
French President Macron’s IT support, in response to a leaked documents
and conversations affair inside his campaign team, fed attackers with
bogus information to degrade the value of the leaked content (Brattberg
and Maurer 2018; Mohan 2017). This reaction was prepared in advance
with campaign staff having anticipated the hacking of their computers;
different scenarios were formulated as campaigners realised the threat of
interference (EUvsDisinfo 2019).
7.3 Actions of the European Union and NATO
7.3.1 European Union
This is an evolution of the joint approach against disinformation on the
EU level; examples of task forces, special bodies countering inﬂuence
operations, new laws as well as media cooperation can be found. There
is a joint task force on the European Union level which was established
in 2015. The East StratCom Task Force addresses Russian information
campaigns and submits plans for strategic communication. The team
consists of staff recruited from EU institutions, or it is seconded by EU
member states. The task force’s budget exists within the EU budget and
those of its member states. (European Union External Action 2018).
One of the most visible activities of the task force is the project ‘EUvsDisinfo’,
which ‘identiﬁes, compiles, and exposes disinformation cases
originating in pro-Kremlin media that are spread across the EU and
7 INSTITUTIONAL RESPONSES OF EUROPEAN COUNTRIES 205
Eastern Partnership countries’. The project’s current monitoring capabilities
‘also uncover disinformation spread in the Western Balkans and the
EU’s Southern neighbourhood’. The project publishes in 15 languages,
updates every week, and distributes a weekly newsletter (EUvsDisinfo,
n.d.). In addition to the East StratCom Task Force, the High-Level
Expert Group (HLEG) on Fake News and Online Disinformation was
established.
An embodiment of these direct countermeasures is one of the Action
Plan against Disinformation’s pillars: the Rapid Alert System (RAS; European
Commission 2019a; European Union External Action 2019). In
practice, the RAS should function like an online platform where member
states and institutions share their experience and knowledge and prepare
common actions. It also aims to cooperate with NATO, the G7, and
other partners (European Commission 2019a) The ﬁrst meeting took
place on 18 March 2019, and the RAS has been operational ever since. All
member states have designated contact points and institutions (European
Parliament 2019a). However, the system needs to be better implemented
and tested. There are some critiques about its functioning. For example,
Emmott et al. (2019) cites an EU ofﬁcial who stresses that the system is
barely used. Kalenský (2019) stresses the problem might be that the RAS
is not available to journalists and researchers, so it is not transparent.
When it comes to actions with the media, there is an increasing effort
to take the cooperation seriously. Under the Action Plan against Disinformation,
the European Union External Action (2018) mobilised an
alliance of journalists and fact-checkers with governments, civil society,
and academics. The European Union invests in new technologies for
content veriﬁcation (Horizon 2020 programme) and supports the Social
Observatory for Disinformation and Social Media Analysis (SOMA),
which enables the sharing of best practices among fact-checkers (European
Commission 2019a; Emmott et al. 2019). From 18–22 March
2019, the European Commission held Media Literacy Week aiming to
‘raise awareness of the importance of media literacy across the EU’.
One of the activities was a high-level conference where best practices
were presented (European Commission 2019b). Cooperation between
the European Union and media companies has occurred with networks
such as Facebook, Twitter, and YouTube, including the Code of Practice
on Disinformation agreement, published in September 2018 to combat
disinformation and fake accounts on their platforms (Emmott et al.
2019). In accordance with the code, Facebook, for example, reported
206 J. HANZELKA AND M. PAVLÍKOVÁ
over 1.2 million actions in the European Union for violation of policies in
ads and content. The Code of Practice on Disinformation was built within
the context of previous EU initiatives at ﬁghting illegal content, hate
speech, and terrorism in the online environment. In May 2016, Facebook,
Microsoft, Twitter, and YouTube agreed with the Commission to an EU
Code of Conduct on Countering Illegal Hate Speech Online, which set
the rules of cooperation and the methodology of content evaluation for
countering the spread of illegal hate speech online. In September 2017,
the Communication on Tackling Illegal Content Online set other guidelines
and principles for collaboration between online platforms, national
authorities, member states, and other relevant stakeholders in the ﬁght
against illegal content online. In March 2018, the Recommendation on
Measures to Effectively Tackle Illegal Online Content focused on calls for
proactive measures from providers but also mentioned the importance
of human veriﬁcation. In September 2018, the European Commission
proposed the Regulation on the Prevention of the Dissemination of
Terrorist Content Online, which contains more restrictive tightening
measures against terrorist content, for example, the ‘one hour rule’ to
take terrorist content ofﬂine after an order from responsible national
authorities (European Parliamentary Research Service 2019).
7.3.2 Nato
On the NATO level, a special initiative called the Strategic Communications
Centre of Excellence (Stratcom CoE) has the most visible
activities in countering disinformation. Within the NATO structure, it has
a speciﬁc position and is a NATO-accredited international military organisation.
The Centres of Excellence are ‘international military organisations
that train and educate leaders and specialists from NATO member and
partner countries’ (NATO Strategic Communications Centre of Excellence
2020a). The institution is not a part of the NATO command
structure, nor is it subordinate to another NATO entity. The centre was
established after the 2014 Wales Summit, and it aims mostly to contribute
to the alliance’s strategic communication where research on inﬂuence
operations and disinformation are included. It also organises conferences
and seminars, publishes strategies, and supports NATO exercises (NATO
Strategic Communications Centre of Excellence 2020b). As it concerns
the cooperation of national governments, ‘the decision to join a centre is
up to each NATO country. The NATO StratCom Center of Excellence
7 INSTITUTIONAL RESPONSES OF EUROPEAN COUNTRIES 207
has fourteen Alliance members, plus the non-NATO countries Sweden
and Finland’ (Foster 2019). The centre’s senior employees consist of
Latvian, Estonian, and Polish nationals; other staff hail from the United
Kingdom, Belgium, and Germany.
Another signiﬁcant NATO organisation operating within the topic of
cyber and information defence is the NATO Cooperative Cyber Defence
Centre of Excellence (The NATO Cooperative Cyber Defence Centre
of Excellence 2020). Even though it is more focused on cyber defence,
operations in cyberspace, given its complexity, could not be considered
without the wider context, where inﬂuence operations have irreplaceable
positions.
In 2016, the European Centre of Excellence for Countering Hybrid
Threats, a joint initiative of the European Union as well as NATO,
was established. The centre consists of European Union and NATO
member states. The centre aims to be ‘an international hub for practitioners
and experts’ which will assist member states and institutions with
hybrid threats defence. It also wants to share practices between states and
be a neutral facilitator between the European Union and NATO (The
European Centre of Excellence for Countering Hybrid Threats 2019).
7.4 Case Studies
Focused through the analytical framework mentioned above, this chapter
illustrates three different approaches to dealing with disinformation and
propaganda via three case studies geographically spaced from the western
to eastern Europe. This fact is important in the context of the pro-Russian
information campaign, which is responsible for one of the biggest shares
in spreading disinformation and propaganda in all three countries.
The western case of Denmark reveals a country with a leading position
in countermeasures. In central Europe’s case, Czech Republic is an
example of a country which is ‘half-way’, with established institutions,
international cooperation, and the political will to ﬁght disinformation
and propaganda. The last case, from the south-eastern European country
of Bulgaria, represents a country which does not have efﬁcient measures.
Of course, this is not an exhaustive list of countries and possible countermeasures.
Many other cases could be covered. Nevertheless, we believe
these case studies show a wide range of approaches present even in culturally
and politically somehow similar countries (at least from a global
perspective)—all three countries are members of the European Union
208 J. HANZELKA AND M. PAVLÍKOVÁ
and NATO. However, all three have different approaches to challenging
propaganda and disinformation, and it can be seen how different political
attitudes, different histories, and different starting positions can affect the
approach to countermeasures.
7.4.1 Denmark: Ambitiously Fighting Disinformation
7.4.1.1 Current Situation
Among the threats within the cyber domain, the Danish Defence Intelligence
Service (2019) considers Russia, China, Iran, and North Korea
as the most active. In comparison to other European states, Denmark is
in strong opposition to Russian inﬂuence operations. It expelled Russian
diplomats after the Skripal affair, and the country was also strongly against
the incidents in the Kerch Strait (Scarsi 2019). In hostile disinformation
campaigns, Denmark is often framed as a typical Western country in moral
decay, especially because of its liberal state model.
In 2018, the Danish government presented 11 initiatives focused on
their elections to counter hostile foreign inﬂuence. These include a task
force, training for communication ofﬁcers, strengthening the work of
intelligence services, emergency preparedness, advising political parties
and leaders, dialogue with the media, and updates to its legislation
(Ministry of Foreign Affairs of Denmark 2018).
7.4.1.2 Institutional Responses
The Danish Defence Intelligence Service clearly mentioned in its recent
annual report, DDIS Intelligence Risk Assessment 2019, the threat of
Russian cyber and inﬂuence operations, which are deployed against
well-deﬁned targets. The report also describes China and its cyber and
espionage activities with efforts to gather information on an adversary as
a threat to Denmark. Clear warning form other state bodies or authorities
can also be found (see EUvsDisinfo 2018).
As the European Parliament (2019b) notes, the Ministry of Foreign
Affairs is the main safeguard of Danish democracy from foreign inﬂuence.
In 2019, the ministry launched a strengthened disinformation monitoring
programme as a part of the government’s new action plan (Ministry of
Foreign Affairs of Denmark 2020).
As part of its 11 initiatives, the Danish government launched an interministerial
task force to coordinate efforts against disinformation. The
ministries are to coordinate together their responses and recognition of
7 INSTITUTIONAL RESPONSES OF EUROPEAN COUNTRIES 209
threats (Baumann and Hansen 2017). Denmark considers cyber threats
not only disruptions by hostile codes but also inﬂuence operations with
stress on disinformation and propaganda. The Danish Centre for Cyber
Security is a national IT security authority, a network security service, and
a national centre for excellence, with a mission ‘to advise Danish public
authorities and private companies that support functions vital to society
on how to prevent, counter and protect against cyber attacks’ (Cyber
Security Intelligence 2020a; Baumann and Hansen 2017). The centre also
considers the role of fake news and social media and covers it in its news
analysis (Cyber Security Intelligence 2020b).
Concerning the education of employees, Denmark plans to train
communication ofﬁcers from government authorities on the ongoing
handling of disinformation (Ministry of Foreign Affairs of Denmark
2020). An interesting example of this state employee education is the
training of Danish soldiers in how to combat disinformation. The plan
was a part of NATO’s military exercise in Estonia in 2017 (EUvsDisinfo
2017a; Just and Degn 2017). The country intends, in regard to
the media, to initiate a dialogue to ﬁnd models of cooperation (European
Parliament 2019b). It is also worth mentioning the documentary
Factory of Lies, which was aired by the Danish Broadcasting Corporation,
exploring the so-called troll farms run by the Kremlin (EUvsDisinfo
2018).
Denmark does not take a strict approach with regard to the regulation
of propaganda. The country instead considers it better to strengthen
civil society (European Parliament 2019b). When it comes to direct countermeasures,
Danish embassy employees are urged to monitor media
and mock manipulative stories about Denmark. They were given a great
degree of freedom to work offensively at the local and social media level,
without the need of coordination from Copenhagen.
Denmark is an active member of the NATO Strategic Communications
Centre of Excellence. Cooperation on the supranational level is considered
part of its strategy against foreign inﬂuence campaigns (The Danish
Government 2018). Denmark was one of the actors participating in criticism
of the activities of the East StratCom Task Force, especially because
of its media categorisation. This event also contributed to questioning
Danish membership (for more, see Kulager 2017).
210 J. HANZELKA AND M. PAVLÍKOVÁ
7.4.1.3 Conclusion
Denmark outlined 11 initiatives to ﬁght inﬂuence operations covering all
aspects. Its approach is aimed more at the role of civil society rather than
repressive tools. However, Denmark is very straightforward in naming
and warning about adversarial activities. The country has established its
own task force and works on inter-ministerial cooperation. It also has a
centre focused on cyber threats; however, its approach is more complex
and also considers inﬂuence operations. Denmark has a great framework
as well as plan to deal with hostile propaganda, which could be an inspiration
for other European countries. Its implementation is still in its infancy,
so the forthcoming years will show its effectivity.
7.4.2 Czech Republic: On the Halfway Mark
7.4.2.1 Current Situation
Czech Republic is currently threatened most by Russian and Chinese
intelligence operations, including information warfare (see Security Information
Service 2019). There is a large amount of so-called disinformation
media with pro-Kremlin sentiments which take information from Russian
state sources as well as other disinformation media. Most of these Czechbased
platforms, therefore, have no link to the Russian state and instead
play the role of sympathisers. Czech Republic, as well as other European
states, has become a target of a sophisticated cyber espionage campaign
by a hacker group believed to belong to the Russian GRU. In 2019, a
cyberattack on the Czech Ministry of Foreign Affairs was revealed to have
indicators leading to this group (Lipská 2019). There is also the active
role of ‘the Castle’ in Russian as well as Chinese inﬂuence operations,
embodied by President Miloš Zeman. He publicly undermines warnings
about Russian activities by the Czech Security Information Service (BIS)
and plays an important role in disinformation campaigns himself (see
Dolejší 2019; Procházková 2018).
7.4.2.2 Institutional Responses
In March 2019, the director of the civil domestic intelligence service BIS,
Michal Koudelka, stressed that Russia might interfere, also via a disinformation
campaign, in the EU parliamentary election (Kundra 2019;
Brolík 2019). Recent annual reports from this service have warned against
7 INSTITUTIONAL RESPONSES OF EUROPEAN COUNTRIES 211
Russian secret services and its hybrid strategy to inﬂuence decisionmaking
processes as well as Chinese inﬂuence actions (Security Information
Service 2019). Warnings and statements appear across the political
sphere. Minister of the Interior Jan Hamáˇcek (of the Czech Social Democratic
Party) warned against disinformation, stressing its importance to
Russian President Vladimir Putin, and he recommended citizens check
information and discuss it with their relatives (Dragoun 2019). Some
opposition parties are also participating in the warning process, albeit with
a different discourse. The Civic Democratic Party, for example, emphasised
the role of Russia in President Zeman’s election and the future
threat5 (see ODS 2018).
The Czech Ministry of Defence also participates in warnings to the
public—mostly through individuals though, which is sometimes criticised
by the Czech Army itself. General Petr Pavel highlighted the
threat from Russia for Czech Republic (iRozhlas 2018). Brigadier General
Karel ˇRehka (2017) wrote a book called Informaˇcní válka (Information
warfare) for academics, the public, and military professionals which is, for
example, part of the recommended literature for military courses at the
University of Defence.
In 2019, the National Cyber and Information Security Agency
(NÚKIB; Národní úˇrad pro kybernetickou a informaˇcní bezpeˇcnost in
Czech) published a warning against the use of technologies from Chinese
companies Huawei and ZTE (2019a). This warning is also linked to
the threat of Chinese inﬂuence operations in Czech Republic. The most
visible state measure is the Ministry of the Interior’s establishment of
the Centre Against Terrorism and Hybrid Threats for expert and analytical
activities, including disinformation campaigns. The centre is active on
Twitter, where it focuses on actual disinformation on the Czech internet
(Ministry of the Interior of the Czech Republic 2017). As the centre’s
head, Benedikt Vangeli, stressed, disproving disinformation includes only
about 5–9 per cent of its activities (Janáková 2018). Therefore, we
suppose that many of its activities are of a secret nature for a reason.
Even though its activities are still not disclosed to public, the centre still
functions today.
5Contrarywise, the Communist Party is debunking any Russian interference (see KS ˇCM
2017).
212 J. HANZELKA AND M. PAVLÍKOVÁ
The education of employees is manifested through courses for military
personnel at the University of Defence, where courses on cyber and information
warfare are conducted. NÚKIB organises educational activities
for students at universities where it also can recruit its future employees
(especially Masaryk University). The agency also organises exercises on
cyber and information warfare (11 in 2018), for example, for Czech
military personnel, the Czech Integrated Rescue System, and the Czech
Statistical Ofﬁce. NÚKIB describes its activities as an example of wholeof-government,
stressing the importance of close cooperation between
institutions (National Cyber and Information Security Agency 2019b).
Considering direct countermeasures, it is hard to analyse whether this
predominantly covers secret service activities. It is not publicly known if
these services are participating in direct information operation activities.
However, in 2019, the Cyber and Information Operations Command was
established under the Army of the Czech Republic. On its ofﬁcial website,
it states that the command will also conduct operations in the information
space (Army of the Czech Republic 2019). Even if the description is
mostly focused on defensive activities, offensive ones are also relevant to
consider.
From interviews with authorities, we can ascertain that Czech Republic
is very sensitive to anything concerning free speech and disinformation
labelling and may be the reason why the country is careful with content
regulation.
On a supranational level, Czech Republic can be considered active
and responsible. The country is participating in the East StratCom Task
Force. The task force cooperates with the country but also directly with
ministries as well as the business sphere. Czech Republic has been a
member of the NATO Cooperative Cyber Defence Centre of Excellence
since joining in 2018. It actively participates in the centre’s activities,
achieving, for example, excellent results in cybersecurity exercises. Since
2019, the re-elected EU commissar Vˇera Jourová gained the values and
transparency portfolio also dealing with disinformation. As part of her
new mandate, she is working on a new EU action plan where Russia is
openly labelled as a threat.6
6Interview with EU ofﬁcials.
7 INSTITUTIONAL RESPONSES OF EUROPEAN COUNTRIES 213
7.4.2.3 Conclusion
Czech Republic holds a wide spectrum of counter-inﬂuence operations
activities. Secret services and military ofﬁcials as well as state authorities
emphasise these threats. It is done especially in regard to hostile Russian
actions. The country has also established a special body which deals with
hybrid threats, unique in the context of central Europe. On the education
front, NÚKIB has a role in the education of citizens; however, its focus is
mostly on cybersecurity issues. There is no close cooperation or approach
with regard to the media and social network providers. Czech Republic
actively participates in international cooperation and takes threats from
inﬂuence operations seriously. Interested state ofﬁcials often mention an
underestimation of strategic communication on the state level as well as
its coordination with supranational entities. Together with better implementation
into the state education system and amendments to its legal
framework, these are the challenges facing the country in the years to
come.
7.4.3 Bulgaria: Internal Disunity Through External Inﬂuences
7.4.3.1 Current Situation
When speaking about disinformation and propaganda in today’s Bulgaria,
it is mostly connected with Russian information strategies which try to
inﬂuence the political orientation of the country from the West to the
East, most frequently displayed via disinformation about EU bureaucrats
and ‘EU bans’ on popular food and beverage products (Cheresheva
2017). Bulgaria also suspects Russia of supporting anti-migrant vigilantes
with equipment and anti-Muslim rhetoric (Fiott and Parkes 2019). One
of the most signiﬁcant connections to the problem of disinformation was
the case of leaked documents from the Bulgarian Socialist Party (BSP)
(the successor of the Bulgarian Communist Party, see Mavrodieva 2019)
which described its strategy for the 2016 presidential election. During the
presidential elections, Leonid Reshetnikov, director of the Russian Institute
for Strategic Studies, had a meeting with BSP representatives, about
the optimisation of their election strategy, where he supposedly instructed
BSP on the distribution of fake news and the misinterpretation of election
surveys (EUvsDisinfo 2017b). The presidential election was then actually
won by BSP candidate Rumen Radev, who is known for his pro-Russian
stance (Tsolova 2016). The following section describes the context of
214 J. HANZELKA AND M. PAVLÍKOVÁ
the creation of disinformation and propaganda and the active measures
applied against it.
Bulgaria is a speciﬁc actor in the question of disinformation and propaganda.
On the one hand, it is a member of the European Union and
NATO, but it is also, on the other hand, linked to Russia. Disunity in
Bulgarian relations to Russia was present in the past and is still present
today. You can ﬁnd here strong pro-Russian tendencies from prominent
politicians as well as the presence of anti-Russian discourse. This applies
to both the political sphere and to ordinary citizens. One of the latest
cases which exacerbated relations between Russia and Europe was the
poisoning of the double agent Sergei Skripal and his daughter. Bulgaria
was one of the countries which did not expel Russian diplomats as a
reaction; the Bulgarian government considered the evidence of Russian
involvement in the attack insufﬁcient (de Carbonnel and Tsolova 2018).
Citizens also acknowledged this decision. According to a poll, 88 per cent
of respondents were against expulsion (Mediapool.bg 2018).
The pro-Russian propaganda channels and instruments are similar to
those we know from other European countries, which means using social
networks and spreading fake news but also troll farms (Colborne 2018).
The main pro-Russian propaganda discourse in Bulgaria concerns European
cultural decline under the weight of EU immigration and puppet
politics. The European Union is seen as a US-NATO construct, and
it is perceived as slowly dying. In contrast, Russia is growing stronger
despite Western aggression, especially through adherence to traditional
values. Bulgarian civic organisations, non-proﬁt organisations, and the
media are then only puppets or foreign agents of the West (Milo et al.
2017). The name George Soros is presented in the country as a sponsor
of organisations promoting Western political sentiment in Bulgaria.
7.4.3.2 Institutional Responses
In the category of action with the public and state measures, it is difﬁcult
to create countermeasures focused on disinformation coming out of the
Russian disinformation strategy because of the division among political
elites in relation to the Russian position. The parliament adopted a 2015
report on national security which mentions Russia in the context of its
growing military capabilities and the destabilisation of Eastern Ukraine
and the countries of the Caucasus, but there is no direct information
about a pro-Russian disinformation campaign (BTA 2015). The risk of
propaganda and disinformation is not mentioned either in the annual
7 INSTITUTIONAL RESPONSES OF EUROPEAN COUNTRIES 215
public reports (SANS 2020) of the State Agency for National Security
(SANS) for the years 2016, 2017, and 2018. But in all reports from 2016,
there is an unspeciﬁed risk for Bulgaria as ‘an object of a serious intelligence
interest from countries, which view the Union and the Alliance as
threats to their own security’ (SANS 2016).
There are no speciﬁc legal measures, procedures, or laws which were
speciﬁcally directed against disinformation and propaganda. However,
there are law articles connected to the election (see Bayer et al. 2019)
which could be potentially used to counter fake news, propaganda, and
disinformation as well as regulations concerning the use of campaign
ﬁnance in electoral codes/acts. For example, Articles 165, 166, and 167
of the 2014 Election Code of Bulgaria deﬁne and restrict the amount and
sources of money which can be spent on ﬁnancing election campaigns.
Article 168, for its part, states that a party, a coalition, or a nomination
committee shall not receive donations from certain sources, such
as anonymous donors, legal entities, and religious institutions (Election
Code of Bulgaria 2014).
It is additionally difﬁcult to ﬁnd a direct contribution from Bulgaria on
the supranational level. Bulgaria as an EU member state has both information
available and the possibility to cooperate in the European External
Action Service as well as in the East StratCom Task Force, but there is no
evidence that it takes these opportunities. The East StratCom Task Force
had pointed out the situation in Bulgaria in several cases. Bulgaria also
does not participate in the European Centre of Excellence for Countering
Hybrid Threats (2019).
Unfortunately, there are no signs of state activity with the media,
political parties, or in direct countermeasures.
7.4.3.3 Conclusion
Bulgaria is an example of a country which, despite having international
cooperation with the European Union and NATO and their member
states, has very limited active measures against propaganda and disinformation.
The key element of this is the relationship of some Bulgarian
political actors to Russia. This example shows that disinformation and
propaganda are highly politicised issues, and, without the support of local
political elites, efforts from the international level are inefﬁcient. In this
case, all measures targeting pro-Russian disinformation are problematic,
but there is still a place for measures focused more broadly—on election
campaigns in general, corruption, and so forth.
216 J. HANZELKA AND M. PAVLÍKOVÁ
It is possible that with stronger pressure from the Russian side, it will
be easier to ﬁnd the political will for a clear stance against disinformation.
Expelling Russian diplomats in January 2020 over espionage allegations
in October 2019 and declining to grant a visa to an incoming Russian
defence attaché may possibly cause the situation to reverse. The relationship
between Bulgaria and Russia may be worsened by the fact that
Bulgarian prosecutors charged three Russians with the attempted murder
of an arms trader and two other Bulgarians whose poisoning is being
investigated by Soﬁa for possible links with the 2018 nerve-agent attack
on Skripal (Reuters 2020).
7.5 Conclusion
The approach of European national institutions to disinformation and
propaganda covers a wide spectrum of countermeasures. Together, it is
possible to formulate a joint framework and apply it to speciﬁc actors
to evaluate its capabilities. Denmark, Czech Republic, and Bulgaria were
chosen because of their different states of countermeasure development
to disinformation and propaganda. This approach should help to better
understand the issues in the ﬁght against disinformation and present the
application of the proposed framework in practice.
Seven categories of state institutional responses against disinformation
and propaganda have been formulated. The ﬁrst group of countermeasures
are actions with the public and state measures, which cover the
most common countermeasures in Europe, and it is possible to identify
them in all our cases. The second group of countermeasures are legal
measures, actions with the media, and actions with political parties. These
are more complex and demand processed legislation and a long-term
coherent strategy. For these reasons, we can see these countermeasures
in countries which are leading the development of measures against disinformation,
such as in Finland or Denmark. The ﬁnal categories are direct
countermeasures and actions with supranational entities. They are the
most problematic due to a lack of public information concerning them.
These categories are closely connected with security services and diplomacy,
and we can only identify public acts, such as the expulsion of
diplomats or public initiatives in international organisations like NATO
or the European Union.
7 INSTITUTIONAL RESPONSES OF EUROPEAN COUNTRIES 217
All in all, this chapter introduces an analytical framework in which to
analyse a set of countermeasures against disinformation as part of inﬂuence
operations, and it has given the researcher the opportunity to depict
the issue in its complexity and, therefore, to study the strengths and
weaknesses of the system. The analytical framework and its usage were
demonstrated on a limited scale. More detailed research is recommended,
speciﬁcally in the collection of data through the use of interviews with
political campaign managers, specialists, high-level state authorities, and
experts.
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