111. limitations in the Cybercrimes and Cybersecurity Bill permitting journalists and members of the public to be prosecuted for possessing or disclosing state information; and IV. existence oflaws criminalizing defamation Right to Freedom of Assembly and Association 36. The Commission is concerned about the: i. lack of information on the promotion of the rights of human rights defenders; and ii. lack of statistical data on the number of NGOs and CSOs in South Africa. Prohibition of Torture, Cruel, Inhumane and Degrading Treatment 37. The Commission is concerned about the: i. lack of statistical data in the Report relevant to the prohibition of torture and ill-treatment, including disaggregated data on complaints, investigations, prosecutions and convictions in cases of torture and illtreatment; 11. lack of measures to provide reparations for victims of torture irrespective of whether a successful criminal prosecution or other judicial remedy can or has been brought; and in. non-ratification of the Optional Protocol to the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (OPCAT) and the establishment of the National Preventive Mechanism as envisaged under OPCAT. Due Process and Conditions of Detention 38. The Commission is concerned about the: 20 | P a g e

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