in deciding appeals be clarified and better drafted to minimise confusion about the extent of the appeal procedure. MISA Zimbabwe recommends that the appeal procedure start as an internal process. Internal appeal procedures are cheaper on the applicant and will likely be handled at a faster pace than procedures sent to either the Commission or the High Court. The Commission and the High Court must also be involved in the appeals process. The Commission will provide oversight on how entities handle information requests. Decisions of the High Court in appeals against denial of access to requested information are likely to enrich the understanding on the right to access to information, as well as how that right is exercised in Zimbabwe. Another confusing aspect of this Bill is the reference to the Zimbabwe Human Rights Commission in the Memorandum of the Bill. Reference is also made in the preliminary part of the Bill to the Zimbabwe Human Rights Commission receiving annual reports from public entities setting out the number of information requests received and dealt with. However, the definitions part of the Bill states that the word ‘Commission’ refers to the Zimbabwe Media Commission, including for purposes of hearing appeals against the refusal of information requests and overseeing the enjoyment and protection of the right to access information in terms of this law. An applicant, whose request for information is refused may lodge an appeal with the Secretary of the Zimbabwe Media Commission in terms of Section 35 of the Bill. This appeal must be sent or delivered to the Commission within 30 days of receiving notice that the request for information was denied. The Secretary of the Commission has a discretion to condone appeals submitted more than 30 days after the notice of a denial is received. If the Secretary does not accept late submissions, the Secretary must give notice of this refusal. A third party may also lodge an appeal with the Commission in relation to information relating to the third party. The appeal must identify the subject of the appeal and state the reasons for the appeal and may include any other relevant information known to the appellant and if, in addition to a written response, the appellant wishes to be informed of the decision on the appeal in any other manner, provide the necessary details to that effect. An application for appeal is only considered complete upon payment of a prescribed appeal fee – a ruling on the appeal may be deferred until full payment of the prescribed fee20. Within 10 working days, the information officer who gave the decision appealed against must supply reasons for the decision being challenged to the head of entity responsible for deciding the appeal. 20 Section 36(3) of the Bill 16