DATA PROTECTION IS RIGHT TO
AND HUMAN RIGHTS PRIVACY MORE
PROTECTION
IMPORTANT THAN
Even though information about people or data is useful for
other purposes, the fundamental reason why data protection
laws exist, is to protect the rights of a data subject as human
rights. In that regard, the preamble to the Act refers to the
Constitution’s Declaration of Rights. In addition, the judiciary
and policy makers are required in terms of the Constitution to
take into account international law when interpreting the
Declaration of Rights.
Section 46 (1) of the Constitution provides that:

When interpreting this Chapter, a court,
tribunal, forum or body
(a) must give full effect to the rights and
freedoms enshrined in this Chapter;
(b) must promote the values and
principles that underlie a democratic
society based on openness, justice,
human dignity, equality and freedom,
and in particular, the values and
principles set out in Section 3;
(c) must take into account international
law and all treaties and conventions
to which Zimbabwe is a party;
(d) must pay due regard to all the
provisions of this Constitution, in
particular the principles and objectives
set out in Chapter 2; and
(e) may consider relevant foreign law.”

4

OTHER RIGHTS?

The Constitution provides for freedom of expression under
Section 61, while Section 62 promotes access to information.
These provisions are further protected in the FOIA which
stipulates the conditions and circumstances when information
including personal information can be legally accessed.
The Act’s application must therefore take into account the
FOIA provisions. These laws must not be interpreted as
conflicting, but as reinforcing one another. For instance, POPIA’s
purpose states that this ‘includes balancing the right to privacy
against other rights, particularly the right of access to
information’.4 While this Act has no equivalent provisions, this
can be inferred as part of interpretation and enforcement of
the rights. The rights are not in hierarchy and courts are
required to balance the conflicting rights.
In the case of A v B Plc on the interpretation of Article 8 on
the right to privacy and Article 10 on the right to freedom of
expression of the Human Rights Act, the European Court of
Human Rights observed the importance of striking a balance.

POPIA section 2.

M I S A

Z I M B A B W E

•

G U I D E

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

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