Cybersecurity and Cybercrime
Laws in the SADC Region

https://zimbabwe.misa.org

Communication and Technology to withdraw the
Bill from the public consultation processes. Media
reports suggest that the revised Cybersecurity and
Cybercrimes Bill will be presented to parliament
towards the end of 2020. These reports suggest
that unlike the two-in-one Bill presented in 2017,
various separate laws dealing with a number of
interconnected issues such as data protection,
electronic transactions, cybersecurity and
cybercrimes will be tabled before the House of
Assembly. At the time of its presentation in 2017,
the Electronic Transactions and Cybercrime Bill
was criticized for failing to define key terms
such as cybercrime, cybersecurity, functionary,
forensic tools, access, data, privacy, seize and
so forth. Concepts such as ‘computer system’
were under-defined despite the specialized
and technical nature of their usage in the field
of cybersecurity and data protection. The Bill
also received criticism for failing to deal in a
structured and substantially consequential
way with the necessary aspects of combatting
cybercriminal activities (IPPR and Action
Namibia, 2017). Generally, it lacked coherence.

and all of section 72, allow for a system of secret
warrants while vaguely defining the conditions
under which such secret warrants can be sought.
These provisions open the door to pervasive
communications surveillance and interception
without appropriate oversight mechanisms to
monitor the conduct of those carrying out such
surveillance or interception activities (IPPR and
Action Namibia, 2017). It was drafted in such a
way that unauthorised access by state agents
and interception of communications was under
regulated.

Building on part 6 of the Communications Act
of 2009, the proposed Bill sought to enable
warrantless search and seizure operations,
while other sections seem to allow for a system
of secret warrants and unauthorised access by
state agents. For instance, chapter 5, in sections
43 (2) and (3), seems to enable unauthorised
access and access without notification by the
Communications Regulatory Authority of
Namibia (CRAN) and others to computer systems,
which in actual fact amounted to government
hacking of private computer systems. Another
questionable provision is chapter 7, in section
61 (6), (7) and (8), which grants a ‘Computer
Security Inspector’ the power to access computer
systems without giving notification or seeking
legal authorisation. This raises the question of
legality. Sections of chapter 8, in sections 70 (2)

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The proposed Bill made no provision for
a ‘designated judge’ to hear interception
applications. This kind of an oversight mechanism
has the potential to foster transparency and
accountability in the state security value chain.
Thus, a system of secret warrants and warrantless
accessing of private data and communications
and computer systems, which the Bill wanted
to smuggle into the public domain violates the
necessary and proportionate principles. In order
to curb the excesses of part 6 of the Communication
Act of 2019, the proposed Bill must endeavor to
establish an independent oversight mechanism
to ensure transparency and accountability of
communications surveillance. Concerns are rife
amongst human rights defenders that Namibia
engages in illegal communications surveillance
even though part 6 of the Communication Act
has not yet been operationalised.
Another borne of contention was the lack of data
and privacy protections. The proposed law did not
adequately provide for personal data protection
or proscribe the rights of data subjects, in line
with necessary and proportionate principles.
The Bill was also silent on procedures to be
followed by state officials when examining,
copying, sharing, sorting through, using,
destroying and/or storing the data obtained
from the interceptions. Given that the right to
privacy is explicitly enshrined in the Namibian

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