https://zimbabwe.misa.org

Cybersecurity and Cybercrime
Laws in the SADC Region

weight of electronic messages in a court of
law. Part IV of the Act deals with liability of
online intermediaries and content editors and
protection of online users. It sets out parameters
for freedom of expression and its limits within
the broad area of online political communication.
It prohibits child pornography; incitement on
racial hatred, xenophobia or violence; unlawful
disabling a computer system, spamming, illegal
trade and commerce, offensive communication,
attempting, aiding and abetting crime and
justification for crimes against humanity.
According to the law, “a person who violates any
provision of this Act, whose penalty has not been
provided, commits an offence and shall, upon
conviction, be liable to a fine of K5,000,000 and up
to seven years imprisonment.” This section also
seeks to promote human dignity and pluralism
in the expression of thoughts and opinions;
protect public order and national security;
facilitate technical restriction to conditional
access to online communication; and enhance
compliance with the requirements of any other
written law. It also prohibits the production and
circulation of misleading advertisements. It also
outlaws unsolicited communications. It says,
“a person shall not send unsolicited electronic
communication to a consumer without obtaining
the prior consent of the consumer”.

in a way incompatible with those purposes; (c)
adequate, relevant and not excessive in relation
to the purposes for which they are collected and
processed. (e) every reasonable step shall be
taken to ensure that data which is inaccurate or
incomplete, having regard to the purposes for
which they were collected or for which they are
further processed, is erased or rectified; and (f)
kept in a form which permits identification of
data subjects for no longer than is necessary for
the purposes for which the data was collected
or for which it is further processed”.

According to the Act, “a person who provides
encr y ption ser vices shal l declare to the
Authority 7 the technical characteristics of the
encryption means as well as the source code
of the software used”. It also gives the Malawi
Communications Regulatory Authority (MACRA)
the power to appoint cyber inspectors. Part
VII deals with data protection and privacy. It
allows for the “processing of data fairly and
legally; (b) collected for specified, explicit and
legitimate purposes and not further processed

Like in Botswana, section 87(4) of the Act punishes
any person who “interferes with data in a way
which causes such data to be modified, destroyed
or otherwise rendered ineffective.” The person
must act “intentionally and without authority
to do so”. The Act has two offences relating to
system interference. Section 87(8) (b) seeks to
punish any person who “introduces or spreads a
software code that damages a computer, computer
system or network.” This code includes viruses,
worms, Trojan horses, logic bombs, bots, root
kits and back doors. Section 93 punishes “any
person who willfully or maliciously renders a
computer system incapable of providing normal
services to its legitimate users.” In practice, this
criminalisation is not limited to an interference
caused by the inputting, transmitting, damaging,
deleting, deteriorating, altering or suppressing
computer data as required under the Budapest
Convention.

Namibia
Like Malawi, Namibia first introduced a two-inone law under the title Electronic Transactions
and Cybercrime Bill in 2017. The Bill received
widespread criticism from various stakeholders,
which forced the Ministry of Information,

7The Malawi Communications Regulatory Authority as established under section 3 of the Communications Act.

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