•

a directory of its employees including their designation and functions

•

a statement of the composition and functions of the boards or other bodies consisting of or
constituted as part of or for the purpose of the functions of the public entity;

•

detailed budget, revenue, expenditure and liabilities for the current financial year, including all
related estimates, plans, projections, reports and audit reports;

•

annual reports and any other information required by or in terms of any the law.

Furthermore, it is recommended that public entities must draft policies, manuals and other documentation
that detail the handling of information requests and how to resolve complaints about access to information.
The manuals must also include advice to members of the public with respect to their rights, privileges or
benefits, and with respect to associated obligations.
Section 18 of the Bill places a duty on statutory entities to annually publish and submit reports to the
Zimbabwe Media Commission (hereinafter the Commission). These annual reports must state the
following:
(a) requests for access to information received
(b) requests for access granted in full
(c) requests for access refused in full or partially and the number of times a specified provision of this Act
was relied on to refuse access in full or partially
(d) cases in which the periods stipulated in Section 8 (1) were extended in terms of Section 9
(e) the number of times that a request for access was regarded as having been refused in terms of Section 10
(f) such other matters as may be prescribed.

Given the amount of information they now control and process, there should be a mandate for private
entities to publish reports that inform the public about the kind of information they respectively hold and
process. Globally, organisations such as Google, and Facebook, publish annual transparency reports that
provide statistics about information requests, including requests by government entities that they receive
within a specified period.
Section 6 (a) exempts information on deliberations and functions of Cabinet and its committees from being
requested by any person or entity in terms of this law. This exemption is in perpetuity, ideally, there should
be a declassification clause that sets out the circumstances under which information on Cabinet activities
can be declassified.
An example, of such a declassification is illustrated in South African case law. In Centre for Social

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