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WILMAP: South Africa

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SELF-REGULATIONInternet Service Provider Association (ISPA) Code of Conduct [Establishing wide-ranging obligations in terms of freedom of expression (section A), privacy and confidentiality (section B), consumer protection (section C), standard terms and conditions (section D), spam (section E), cybercrime (section F), protection of minors (section G) and removal of content (section I) In addition, the Code provides that members must “conduct themselves lawfully at all times and …co-operate with law enforcement authorities where there is a legal obligation to do so”, …”respect intellectual property rights and not willingly infringe such rights”…as well as “uphold and abide by this Code of Conduct and adhere to the associated complaints and disciplinary procedures”(section H). In this respect, the Code proscribes that ISPA members must receive and investigate complaints (provided that they are not frivolous, unreasonable, vexatious or in bad faith) and make all reasonable efforts to resolve them in accordance with the complaints procedure, and empowers ISPA to initiate investigations and institute disciplinary proceedings on its own initiative (section K)].  ISPA Takedown procedure [Detailing a specific timeline and procedure for members to respond to notices submitted in accordance with section 77 of the Electronic Communications and Transactions Act].

DECISIONS

Superior CourtsSupreme Court, Sankie Mthembi-Mahanyele v Mail & Guardian Limited, 2004 (6). SA 329 (SCA), August 2, 2004[defamation; liability; defense, reasonableness] [Clarifying that whether the publication of a potentially defamatory comment is “fair” or “reasonable” depends on the relevant circumstances, such as the interest of the public in being informed; the manner of publication; the tone of the material published; the extent of public concern in the information; the reliability of the source; the steps taken to verify the truth of the information; and whether the person defamed has been given the opportunity to comment on the statement before publication]. Constitutional Court, Khumalo and Others v Holomisa , [2002] ZACC 12; 2002 (5) SA 401; 2002 (8) BCLR 771, June 14, 2002[defamation; liability; media; negligence-based] [Recognizing that the mass media have a particular role in the protection of freedom of expression — to ensure that individual citizens are able to receive and impart information and ideas — and are thus bearers of both constitutional rights and obligations. Differentiating for this reason media defendant from ordinary members of the public, which can rely on the absence of animus injuriandi as a defense, and concluding that liability of media for defamation should not be limited to proven falsehood, but should rather be based on negligence].  Supreme Court, National Media Ltd v Bogoshi 1998 (4) SA 1196 (SCA), September 29, 1998[defamation; liability; excusable error; negligence]  [Identifying two defences from liability for defamation: (1) that defamatory comments were true and of public interest contents of a defamatory statement were true and their publication to the benefit of the public; and (2) where it can be proved that, although the statement was not true, publication was nevertheless reasonable].

High CourtsSouth Gauteng High Court, Ketler Investments CC t/a Ketler Presentations v Internet Service Providers Association, (2012/1249) [2013] ZAGPJHC 232 , September 19, 2013[defamation, liability, spam, code of conduct, truth defense]  [Finding that publication of the name of the applicant in the “Hall of Shame” list of spammers by the Internet Service Providers Association (ISPA) was justified by its true character and by the public interest served by the publication. This decision by ISPA was based on the definition of spam contained in its code of conduct, which supplements the generic notion of spam identified by section 45 of the Electronic Communication and Transactions Act and does not afford non-members an opportunity to be heard before being included in such list]. South Gauteng High Court, H v W, (12/10142) [2013 ZAGP JHC 1; 2013 (2) SA 530 (GSJ) 2013 (5) BCLR 554 (GSJ); [2013] 2 All SA 218 (GSJ), January 30, 2013[defamation; injunctive relief; no injunction against ISP] [Ordering a user to remove defamatory content, but declining to enjoin the respondent from posting any information pertaining to the applicant on Facebook or any other social media, and declining to order Facebook to remove specific material from a user’s webpage (but raising the question of whether the police would have the competence to do so upon failure to act by the user)]. South Gauteng High Court, Tschilas and Another v Touch Line media (Pty) LTD,  2004 (2) SA 112 (W), June 26, 2003 [defamation; safe harbor; information service provider] [Rejecting the safe harbor defense of section 75 of the Electronic Communications because respondent does not fall within the definition of “service provider”, as it is instead the means to obtain access to an information service provider].

Lower CourtsCape Provincial Division, Arthur E Abrahams & Gross v Cohen and others, 1991 (2) SA 301 (C) [copyright; indirect liability; requisite foreseeability] [Ruling that indirect liability arises when a copyright owner suffers an economic loss that was foreseeable by a defendant who was under a legal duty to prevent it]. Transvaal Provincial Division, Paramount Pictures Corporation v Video Parktown North (Pty) Ltd, 1986 (2) SA 623 (T)[copyright; requisite knowledge; reasonableness] [Finding sufficient to trigger liability the notice of facts that would suggest to a reasonable person that a copyright infringement was being committed].

OTHER RESOURCESAlex Comninos, Intermediary Liability in South Africa, APC Intermediary Liability in Africa Research Papers, No. 3 (2012)Nicolo Zingales, Internet Freedom in South Africa, Report for Collaboration on International ICT Policy in East and Southern Africa (CIPESA) (2014)

CONTRIBUTORSNicolo ZingalesEmail: n.zingales at uvt.nl [personal page]

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