this protection from liability if they do not respond to take-down requests. ISPs often err on the side of caution by taking down content to avoid litigation since there is no incentive for providers to defend the rights of the original content creator, even if they believe the take-down notice was requested in bad faith. There is no existing appeal mechanism for content creators or providers. During May 2010 the Christian advocacy group Justice Alliance of South Africa (JASA) authored a document titled "Internet and Cell Phone Pornography Bill". Their document proposes to make it illegal for Internet service providers in South Africa to distribute or permit the distribution of pornography. The document was presented to the Deputy Home Affairs Minister Malusi Gigaba. Malusi Gigaba then asked the Law Reform Commission whether a change in the law was possible. In July 2010 Malusi Gigaba then called for the fast-tracking of new regulation that would compel Internet service providers to filter content provided to users to ensure it does not contain any pornography. In September 2012, the Constitutional Court upheld a ruling that prescreening publications (including Internet content) as required by the 2009 amendments to the Films and Publications Act of 1996 was an unconstitutional limitation on freedom of expression. In September 2013 President Jacob Zuma refused to sign the Protection of State Information Bill (POSIB) into law and instead sent it back to the National Assembly for reconsideration. The bill provided for heavy penalties for journalists who reveal "State secrets", including a prison sentence of up to 25 years for "divulging classified information". The bill was criticized because of the danger it posed to investigative journalism. In November 2013, the Protection of Personal Information Act was signed into law, enacting measures to protect users’ online security, privacy, and data. No law ensuring the constitutional right to privacy existed previous to POPI, which allows an individual to bring civil claims against those who contravene the act. 35 Penalties for contravening the law are stiff, including prison terms and fines of up to ZAR 10 million (over US$900,000). Sections 2 to 38; sections 55 to 109; section 111, and section 114 (1), (2) and (3) shall commence on 1 July 2020 Sections 110 and 114(4) shall commence on 30 June 2021 01 July 2021: Section 58(2) of the Act shall commence on this date. Refer to GG44383 01 February 2022: Section 58(2)