Cybersecurity and Cybercrime
Laws in the SADC Region

https://zimbabwe.misa.org

officer8 . It is also important for the law to make
it obligatory for every data controller to appoint
a data protection officer. However, the question
that therefore arises is who polices the data
protection officer and ensures that they are
independent and exercise due diligence? The Bill
also amends the provisions in Sections 163-166 of
the Criminal Law (Codification and Reform) Act,
which speaks on offences relating to computer
systems, computer data, data storage mediums,
data codes and devices. The Bill has provisions
for dealing with offenses related to hacking,
unlawful interference and interception of data
and computer systems. It should also be noted
that the Internet has created a global village
and such hacking or unlawful interferences can
be perpetrated by persons outside Zimbabwe
and thus outside the jurisdiction of our law
enforcement authorities.

In a context of polarized politics and retribution,
such provisions can be used as political tools
and mechanisms by the state to prevent the
expression of dissenting opinions. In the end,
such a provision can contribute immensely
towards stifling citizen engagement and open
debate, which are essential building blocks for
electoral and constitutional democracy.

There are, however, other provisions that have
the potential to infringe on the exercise of media
freedom, freedom of expression and access to
information. For instance, section 164 states:
“Any person who unlawfully by means
of a computer or information system
makes available, transmits, broadcasts or
distributes a data message to any person,
group of persons or to the public with
intend to incite such persons to commit acts
of violence against any person or persons
or to cause damage to any property shall
be guilty of an offence and liable to a fine
not exceeding level ten or to imprisonment
for a period not exceeding five years or to
both such fine and such imprisonment.”
Like insult laws, the above provision can easily
be used to inhibit constructive criticism, which
is important for promoting transparency and
accountability especially from the government.

Under section 164B, the Bill criminalises not
only the production but also the communication
of offensive messages from ‘any electronic
medium accessible by any person’, which in
essence also includes social media. This relates
to cyber-bullying and harassment. Section 164C
of the Bill deals with mis-and disinformation. It
criminalises the use of a computer or information
system to avail, broadcast, distribute data
knowing it to be false and intending to cause
psychological or economic harm to someone,
also seems to be targeted against the spread of
false information on social media. This raises
a number of issues in terms of measuring
the intentional production and circulation of
false and misleading information in order to
cause harm. It also assumes that the “arbiter
of truth” can easily be identified. This clause
ignores the fact that there are multiple truths
and various regimes of truth and non-truth. Even
more important it ignores the fact that on the
internet and social media platforms it difficult
to determine the origin and authenticity of a
message. In such an environment, individuals are
exposed to communication messages voluntarily
or involuntarily. In a context, where a culture
of citizen journalism and blogging has taken
route, this provision can be abused to implicate
thousands of ordinary citizens who would have
‘received’ and communicated such messages.
Cognisant of the dangers that lurks in the woods,

8A data protection officer in terms of the Bill, refers to any individual appointed by the data controller and is charged with ensuring,
in an independent manner, compliance with the obligations provided for in this Bill.

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