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A Comparative Analysis of Zimbabwean and South African Data Protection Systems

Data protection is a very important international trade issue and the lack of adequate data protection may be a barrier to trade. Data protection laws are also a vital part of the protection of an individual’s privacy. This paper is a descriptive analysis of Zimbabwean and South African data protection systems. It compares these two common law systems in a holistic manner taking into account each nation’s peculiar cultural, social, economic and political environments. The most striking feature of both these systems is that they are underdeveloped; Zimbabwe only protects data held and used by the public sector whilst South Africa has no specific data protection legislation at all. There is currently a concerted effort to secure data protection in South Africa spearheaded by the South African Law Commission (SALC). This paper is a contribution to this law reform process. Its objective is to give a synopsis of the two data protection systems, identify their weaknesses and make suggestions for reform drawn from stronger data protection systems. It proceeds by outlining the constitutional, common law and legislative frameworks regulating data protection in each country, and comparing these with each other and a common ideal. The paper also briefly discusses the current data protection law reform in South Africa and concludes with a forecast of probable developments in both countries.