It’s “a breach of international law,” Brazil’s president declared to the world. “Reminiscent of the cold war,” added Germany’s justice minister. Mexico didn’t say much.

What explains each country’s different reaction when leaked documents exposed the NSA for extending its surveillance to Brazil, Mexico and the EU? Weekly Wonk Associate Editor Elizabeth Weingarten e-gathered a group of quasi-ambassadors to discuss their nation’s response – and to tell us how the revelations could impact the future of Internet governance.

These reactions didn’t happen in a vacuum. Put your country’s response into historical context. What’s the history of surveillance there?

Paulo Sotero, Director of the Wilson Center’s Brazil Institute: Historically, surveillance has a bad name in Brazil. Early records show that surveillance activities were carried out against Brazilian citizens opposed to the dictatorial regimes that ruled from 1930-1945 and 1964-1985. In 1964, the military created the National Information Service (SNI), which gradually became a state within the state. SNI was replace by the Brazilian National Information Agency (ABIN) after the re-instatement of democracy in 1985. Over time, it developed some counter-intelligence capacity. But it does not do foreign intelligence. Surveillance has continued, however, with wiretapping – both legal and illegal of Brazilian citizens.

Geraldo Zahran, Specialist in Brazil-US relations at the Pontifical Catholic University of São Paulo: Just as government surveillance isn’t new for Brazilian people,  Brazilian officials are not naïve about US surveillance. Reports of US surveillance date back to the 1960s – when our military regime was supported by the US – through the Cardoso government in the 1990s. The difference this time is the publicity of the case. What Brazilian officials expected were better explanations about US programs, given the publicity of the leaks. They need coverage from critics at home, and to their mind the issue has still not properly been addressed.

 Stefan Heumann, Deputy Program Director of the “European Digital Agenda” at stiftung neue verantwortung: Critics of the NSA surveillance programs often compare it to the undemocratic surveillance practices in Communist Eastern Germany.

After World War II, the Communist Eastern German state built an extensive surveillance apparatus (the Stasi) to spy on its own citizens. Surveillance was a tool of oppression. This experience has made Germans (both in West and East) very sensitive about surveillance.

What was it like to live under Stasi surveillance?

The Stasi became notorious for recruiting the co-workers, friends, and even family of people they suspected of being opponents or critics of the Communist Government to become informants. These spies would write weekly or monthly reports on the target for the Stasi. The whole extent of surveillance only became apparent after the fall of The Wall when the archives of the Stasi became accessible. Any person who has been under Stasi surveillance can request to see the documents related to his/her case. People have been shocked by the betrayal from their closest friends and relatives.

Alejandro, turning to you, and to Mexico’s response to the NSA revelations. In contrast to Brazil and Germany, it was relatively tame. Why?

Alejandro Hope, Director of Security Policy at the Mexican Competitiveness Institute: This is probably a reflection of an underlying fatalism in Mexico vis a vis the US intelligence community: the working premise is that, if the NSA, the CIA, the DEA, etc., wants to know something, a) they will indeed gain that knowledge and b) there is not much Mexican counterintelligence can do to prevent it.

The tame reaction might also be a reflection of the high prevalence of electronic surveillance of Mexicans by other Mexicans. Wiretapping is a very common practice among Mexican politicians and has been so for many decades. Until 2005, intelligence and law enforcement agencies could perform wiretaps and electronic intercepts without having to obtain a legal injunction. And even now, judicial oversight on electronic surveillance is rather weak. Very few people have ever gone to jail for illegally listening in on someone else’s conversations. So if Mexicans are convinced that everyone of consequence is spying and being spied upon, why would they be surprised if the US got into that game?

Yet there did seem to be a lot of surprise – and anger – after the WikiLeaks cables revealed that the U.S. had been very critical of Mexico’s leaders. Why the stark difference?  

Alejandro: The reaction to WikiLeaks was quite fierce because: a) the leaked cables were extremely critical of President Calderón ‘s security policy, b) the Army (an institution with a strong nationalistic bent) was the object of some of the harshest criticisms, and c) even before the leaks, Calderón disliked and mistrusted Carlos Pascual, the US ambassador at the time. The NSA snafu only reveals that the US government spies on top-level Mexican politicians (big surprise there!), not what said government thinks of said politicians.

Will the NSA revelations impact relations between the U.S. and your respective countries?

Paulo: The immediate impact is very negative for both countries. Several important diplomatic and economic initiatives between the countries will now depend on whether the Obama and Rousseff administrations resolve the difficulties that led to the postponement of Rousseff’s visit.

People in Brazil, even those who do not sympathize with president, were surprised and frustrated by the NSA revelations. Context here is important. After the first NSA revelation came out about spying on meta data, Secretary John Kerry visited Brasilia and said publicly that the US needed to have an active surveillance of meta data going through Brazil “to protect American and Brazilians against terrorism.” Obviously, this explanation fell short after the revelations involving snooping on Rousseff and Petrobras. In the absence of answers from Washington to Brazilian concerns, the dialogue will remain cold, if not frozen.

Alejandro: To some extent, it will fuel the mistrust the current Mexican administration feels towards its US partners. Since coming into office last December, the Peña Nieto administration has made conscious efforts to put the lid on US intelligence agencies in Mexico – this coming after a six-year period of intense, freewheeling and somewhat disorderly collaboration between the US intelligence community and Mexican agencies. The NSA revelations might convince the most nationalistic elements of the Mexican administration of the wisdom of this new policy – the gringos are not to be trusted and Calderón (México’s president between 2006 and 2012) opened the door way too much. But, at the end of day, not much will really change for a rather simple reason: Mexican agencies are to a significant extent operationally dependent on US intelligence. In the absence of, say, Drug Enforcement Administration informants or American drones, Mexican military and law enforcement institutions would be seriously hobbled in the fight against organized crime.

Stefan: German people are generally quite concerned about their privacy and regard the scope and scale of NSA programs as excessive and illegitimate. However, the German government has not reacted strongly because, as in the case of Mexico, German intelligence agencies closely cooperate with the NSA and lack the capacities the NSA has. The German national security establishment regards the cooperation with the NSA as highly important. But at the same time, the German government has been under pressure to show it is concerned about the massive surveillance of German citizens. This pressure was particularly great during the months leading up to the national elections ( held on September 22). Now, after the election the government will feel less need to act.

These actions have certainly undermined trust  – and the broader public has become more critical of U.S. policies. This general mistrust will make it harder for German politicians to continue close cooperation with the U.S. in many policy fields.

During Brazilian President Dilma Rousseff’s speech to the UN General Assembly, she called on other countries to essentially disconnect from American Internet hegemony in response to the NSA revelations. Could ire over surveillance spark a change in Internet governance? In other words, is the tide turning on America’s Internet dominance?

Alejandro: Not sure. Indeed, some Internet behemoths (Facebook, Google, etc) might be viewed with far more suspicion in many countries, given what we know now about their collaboration with the data gathering activities of the NSA. And in authoritarian countries, suspicion might translate into increasing controls. Whether that leads to a broad and lasting change in Internet governance is a different question. My guess is that there is a large and growing constituency throughout the world in favor of an open Internet. The broad resistance to SOPA and PIPA seems to prove that point.

Geraldo: Perhaps in the long run, but we have to differentiate between espionage and Internet governance. Espionage is by definition an unlawful activity; framing Internet privacy as a human right as Brazil proposes will not stop governments’ intelligence activities. Moreover, if the US opposes international regulations on national security grounds, countries like Russia and China will also certainly oppose the human rights approach. It’s a political dead end. It is more reasonable to expect changes in Internet governance to come from big players concerned with their own security adopting different electronic patterns.

 Stefan: The United States has lost one of the most important currencies in international discussions: credibility. At the same time as countries like China, Russia, and Iran challenge the current premises of Internet governance, the U.S. is severely weakened to unite those who want to keep the Internet open and free against those who want more state control of the internet. Germany and the EU have not yet really understood that their leadership will be crucial in the coming years – especially in regard to reaching out to the countries of the global South. Reforms of Internet governance are needed to make it more inclusive. In the past we have relied on U.S. leadership. If Europe does not step up, there is a real danger that the current global Internet governance structure comes under even more pressure and might fall apart.