Assignment 2 Semester 1 2026
Unique number:
Due date: 17 April 2026
DIGITAL JUSTICE SOUTH AFRICA SUBMISSION ON DIGITAL INEQUALITY AND
PLATFORM GOVERNANCE REFORM
TABLE OF CONTENTS
1. INTRODUCTION ............................................................................................................ 3
2. THE FIVE KEY STEPS FOR POLICY ANALYSIS.......................................................... 3
3. UNDERSTANDING DIGITAL INEQUALITY VERSUS THE DIGITAL DIVIDE ................ 7
4. KEY ISSUES FOR DIGITAL MEDIA POLICY AND REGULATION ...............................11
5. CONCLUSION ...............................................................................................................15
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,DIGITAL JUSTICE SOUTH AFRICA SUBMISSION ON DIGITAL INEQUALITY
AND PLATFORM GOVERNANCE REFORM
TABLE OF CONTENTS
1. INTRODUCTION ............................................................................................................. 3
2. THE FIVE KEY STEPS FOR POLICY ANALYSIS .......................................................... 3
3. UNDERSTANDING DIGITAL INEQUALITY VERSUS THE DIGITAL DIVIDE ................ 7
4. KEY ISSUES FOR DIGITAL MEDIA POLICY AND REGULATION .............................. 11
5. CONCLUSION .............................................................................................................. 15
REFERENCES .................................................................................................................. 16
, 1. INTRODUCTION
Digital Justice South Africa welcomes the opportunity to participate in the public
consultation process initiated by the Department of Communications and Digital
Technologies and ICASA. Public participation is a foundational principle of South
Africa’s constitutional democracy and ensures that policy development reflects
diverse social realities and lived experiences. The draft policy on digital platform
content moderation and the digitisation of government services raises significant
issues that directly affect fundamental rights, equality, and access to public services.
This submission analyses the draft policy from a digital rights perspective. First, it
explains the process of policy analysis and outlines the five key steps required to
critically evaluate the draft policy in a structured and methodologically sound
manner, drawing on Hanberger’s framework for policy evaluation. Second, it argues
that the draft policy adopts an overly narrow definition of the digital divide by focusing
primarily on access and connectivity, and it provides a broader understanding of
digital inequality informed by contemporary scholarship. Third, it identifies key issues
that must be addressed when regulating digital platforms and content moderation,
including governance, accountability, rights protection, and contextual relevance
within the South African environment.
Through this submission, Digital Justice South Africa aims to contribute
constructively to the development of a policy framework that promotes digital
inclusion while safeguarding constitutional rights and democratic values.
2. THE FIVE KEY STEPS FOR POLICY ANALYSIS
In preparing a formal written submission on the draft Digital Justice policy, DJSA
must apply a structured and systematic policy analysis framework. Policy analysis is
not merely a descriptive exercise. It involves interrogating the problem definition,
assessing normative assumptions, evaluating implementation feasibility, and
identifying likely impacts. Hanberger (2001) emphasises that policy evaluation must
critically examine how problems are framed and whose interests are represented. In
line with the COM3712 framework, the following five key steps guide this analysis.