Processing

The harms can be in the following form:
• physical harms

The definition of processing is

• economic harms
• reputational harms
• psychological harms
• autonomy harms
• discrimination harms
• relationship harms19
These harms are not confined to disclosure of sensitive data
but even to general personal data.
The disclosure of sensitive personal information might
lead one or more harms, and even harming others
associated with the data subject. Sensitive personal
information or data means information that presents
a major risk to the data subject if the information
is processed without satisfying certain requirements
at law.

“Any operation or set of operations
which are performed upon data,
whether or not by automatic means
such as obtaining recording or
holding the data or carrying out any
operation or set of operations on
data, including-(a) organisation,
adaptation or alteration of the data;
(b) retrieval, consultation or use of
the data; or (c) alignment,
combination, blocking, erasure or
destruction of the data”.

CLASSIFICATION OF SENSITIVE DATA
Data Type

Specific harms

Racial or ethnic

Relationship, physical, economic or psychological

Political opinions

Discrimination, relationships

Political party membership

Disclosure that you support a party

Religious beliefs/affiliations

Relationship, economic, relationship harms

Philosophical beliefs

Discriminated or harmed based on ideas

Trade union or professional

physical or discrimination, economic harms

Sex life

Discrimination, relationships, and psychological

Criminal records, education

Discrimination, relationships, and psychological

Financial employment history

Discrimination, relationships, and psychological

Gender, age, family status

Relationship, discrimination

Health or genetic information

Discrimination, economic harms and relationship harms

19

In comparison, POPIA under Section 3(4) defines automatic
to mean that there is equipment that is capable of operating
automatically in responses to instructions given for purposes
of processing information.

Danielle Keats Citron & Daniel J. Solove (2022).

12

M I S A

Z I M B A B W E

•

G U I D E

This definition means that when data
is collected from an individual, there
are means and ways that are used
to make that data relevant or usable.
For instance, it can be recording of
your cell phone number in a
database; or it can be correction of
your home address with the local
council who are not sending bills or
are sending erroneous readings of
bills; it can be the destroying of
COVID-19 test results and associated
diagnosis used for travelling purposes
by a medical laboratory. The Act
doesn’t define what automatic
processing is but mentions automatic
data processing in several sections
including Section 25.

T O

T H E

Z I M B A B W E A N

C Y B E R

A N D

D A T A

P R O T E C T I O N

A C T

-

2 0 2 2

Select target paragraph3