right under AIPPA to request for information in Zimbabwe.5 These are just some of the problematic areas around access to information provisions in AIPPA. MISA Zimbabwe, however, notes that the gazetted Bill tries to rectify some of the access to information shortcomings under AIPPA. 4. Analysis of Sections of the Bill 4.1 General Provisions Section 2 of the Bill defines information to include “…any original or copy of documentary material irrespective of its physical characteristics…” This is wide enough to include tangible and intangible material. This definition is similar to information as defined in the Model Law, and this is welcome. Currently, AIPPA only defines personal information without giving a definition for other, general, nonpersonal data. This is an important development because it will easily cover access to electronic data or information. This is welcome since some public data holders such as the office of the Deeds Registrar are working on digitising their records and processes.6 The Bill however, is not the primary law7 on access to information. This means any other laws that conflict or are otherwise inconsistent with this Act [Bill] in relation to access to information, those laws, for example, the Official Secrets Act, shall prevail. Based on experience in Zimbabwe and other parts of the continent, laws such as national security and other laws that restrict access to information will be relied on to thwart proposed Freedom of Information law. The South African courts have ruled on this point in the case of My Votes Count vs. Speaker of National Assembly and Others and observed: That there is out there a plethora of other pieces of legislation providing for access to information does not mean all those pieces of legislation are the legislation envisaged in Section 32 (2) of the Constitution 9. 5 (3) Nothing contained in this Act shall confer any rights to information or to a record to— (a) a person who is not a citizen of Zimbabwe, or is not regarded as permanently resident in Zimbabwe by virtue of the Immigration Act [Chapter 4:02], or is not the holder of a temporary employment or residence permit or students permit issued in terms of that Act; (b) any mass media service which is not registered in terms of this Act, or to a broadcaster who is not registered in terms of the Broadcasting Services Act [Chapter 12:06]; and (c) any foreign state or agency thereof. 6 Deeds Registry Amendment Act 8 of 2017 7 Primacy of the Act, same AIPPA provisions and ACHPR Model law 9 2016 (1) SA 132 (CC) para 149 5