2. As such, the CFCR welcomes the opportunity to make a concise submission to the Department of Justice and Constitutional Development (the Department) regarding the Draft Cybercrimes and Cybersecurity Bill [B‐2015] (the Bill) in response to your call for submissions as published on www.justice.gov.za on 28 August 2015.
3. It is not the purpose or intention of this submission to provide comprehensive legal analysis or technical assessment of the Bill, but rather to draw attention to key concerns in relation to the Bill ‐ particularly insofar as it relates to the aforementioned constitutional values, rights and principles.
Key concerns regarding the Bill
4. In principle, the CFCR welcomes the Bill to the extent that it seeks to prevent, suppress and criminalise cybercrimes and related cybersecurity matters. However, some provisions of the Bill ‐ especially regarding the right to freedom of expression, as well as powers of security services ‐ do raise legitimate and serious concerns.