then resubmit their information request to that other entity or entities. This goes against the information officer’s duty to assist the requester of information. MISA Zimbabwe recommends that the Bill should permit an information officer in one entity to redirect a received request for information to another entity that has the requested information or that is more closely connected to the requested information. Such transfers must be made within five (5) days of receiving a request for information. When such a transfer is made, the applicant must be notified of the transfer and furnished with reasons on why the transfer has been made. This notification must be in writing. The transfer will not affect the 21-day limit, as the day when the request was received by the transferring entity marks the start of the processing period or timeline under Section 7(1). This is the position in terms of Section 17 of the Model Law. Section 10 of the Bill refers to what are referred to as “deemed refusals.” Any request for information not dealt with and finalised within the 21-day limit set out in Section 8, is considered to have been denied, if there has been no request for an extension in terms of Section 9.The section does not specifically require that reason be given in such circumstances, but it is recommended that reasons be furnished for deemed refusals. An information officer may in terms of Section18, defer the release of requested information on grounds that it will for example, be released at a parliamentary presentation or the information forms part of a report that will be presented to a public entity or public officer. This section considers the different reporting or access to information provisions of Acts. For instance, if the requests entail the reports that the Zimbabwe Human Rights Commission (ZHRC) is going to present to Parliament in terms of the Constitution and the ZHRC Act, the request can be deferred on that basis. There is no provision on what happens in instances where information was scheduled for presentation but was ultimately not presented as planned. The indefinite delay in presenting information to a public body such as Parliament causes an indefinite embargo on accessing such information. MISA Zimbabwe recommends that there be a fixed period within which such information must be turned over to a requester even if it is never presented to Parliament or any other similar body. Information requests are sometimes met with responses that such information does not exist or cannot be found. Section 12 of the Bill provides for such an eventuality. The fact that a record cannot be found might be a confirmation that such record was or is in the public body’s possession. The section, however, does not treat this as a denied request. This section can be reworded, to insert provision that, that this decision 11