Black Sash Submissions

As documented in the South African Constitution, any individual or organisation have the right to involvement in law-making and the processes of Parliament. A submission is the presentation of opinions on a matter or piece of legislation which is under consideration by a Parliamentary committee. Through a submission, members of the public can propose changes or suggest possible actions to ensure that the laws being implemented serve their purpose.

This is a collection of the submissions put forward by The Black Sash.


Black Sash Submission to amend aspects of the Amendment to the Direction Issued in terms of the Regulation 4(5) of the Regulations made under section 27(2) of the Disaster Management Act, 2002 (Act No 57 of 2002): Measures to prevent and combat the Spread of COVID-19 for consideration by Minister Zulu. 




In this Submission Black Sash requests that, in light of the COVID-19 Pandemic,  government prioritises plans to ensure the full implementation of the recommendations of the Committee on Economic, Social and Cultural Rights (CESCR) before October 2020. In this regard, we request that the government convey a meeting with relevant stakeholders with a view of addressing the recommendations of the CESCR.

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This submission is made in response to an invitation for making written submissions on the 2020 Appropriation Bill, the purpose of which is to appropriate money from the National Revenue Fund for the requirements of the State for the 2020/21. Our submission is made at a time when the lockdown in response to the COVID-19 pandemic has had far-reaching consequences for the economy which is heavily impacted by the public health imperative to slow down the spreading of the coronavirus by curtailing business activities, residents’ movement and the ability to secure a livelihood.

Our analysis therefore focuses on both the appropriations put forward in February 2020 when the 2020/2021 budget was tabled and the implications COVID-19 has in the interim brought to the fore for public spending. Due to Black Sash’s sectoral focus on social development, our submission largely offers analysis of social spending rather than an exhaustive analysis across all areas of spending. We conclude with recommendations for adjustments to spending plans when the special adjusted budget is tabled. 

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The Black Sash welcomes the opportunity to respond to the invitation of the Special Rapporteur to make submission(s) on the human rights impact of the introduction of digital technologies in the implementation of national social protection.

 The Black Sash works towards the realisation of socio-economic rights, as outlined in the South African Constitution (1996), with emphasis on social security and social protection for the most vulnerable particularly women and children. It also works towards exploring options to significantly reduce poverty and inequality The Black Sash implements three programmes: namely 1) advocacy in partnership; 2) Community Based Monitoring; and 3) education, training and research.

Our submission will focus on the impact of digital technologies on the national social assistance programme with reference to the collection, storage and use of biometric information of social grant beneficiaries. We will do this in part by referring to our experiences of the national implementation of biometric digital technologies from 2012.

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Thursday, 7 May 2020


President Cyril Ramaphosa

His Excellency, President Cyril Ramaphosa,                            

President of the Republic of South Africa

Copied to:


Ms Lindiwe Zulu

c/o Ms Zama Kumalo; Ms Monica Zabo; Ms Lumka Olifant



Minister Maite Nkoana-Mashabane

Private Secretary: Ms Mantikwe Ramokgopa

Ms Millie Ramoraswi Chief of Staff

Acting Director General (ADG): MS. W.R. (Shoki) Tshabalala



Minister Thembelani Thulas Nxesi


UIF Chief Operations Officer: Ms Judith Kumbi



Minister Tito Mboweni

Office of the Director General Dondo Mogajane

DDG: Public Finance

Acting DDG: Budget Office

DDG: Public Finance Mampho Modise


Dear President Ramaphosa,




We note government’s emergency economic and social relief measures to alleviate the impact of the COVID-19 pandemic and the resulting nationwide lockdown on individuals and households. While the relief measures are a small step in the right direction, they are insufficient to meet the current humanitarian crisis under lockdown conditions. Many poor families are going hungry. The situation remains desperate with many queueing for food parcels. The threat of starvation or even the possibility of death from hunger, rather than from the coronavirus, for many people is real.[1]  It is within this context that we argue that the social grant relief measures remain inadequate.

COVID-19 has underscored the critical role of adequate investments in public health, comprehensive social protection programmes, dignified and decent work, and access to food, water, sanitations systems and housing.  The coronavirus has also intensified the intersecting forms of inequality including income and wealth within our country, and gender inequality, for which measures have to be put in place.

We note the recommendations of United Nations (UN) Committee on Economic, Social and Cultural Rights in its statement on the coronavirus disease (COVID-19) pandemic and economic, social and cultural rights. The COVID-19 pandemic has inflicted “devastating impacts across the world on all spheres of life – health, the economy, social security, education and food production”.  The lockdowns to curb transmissions of the virus have caused jobs losses, endangered livelihoods and heightened exposure to violence. States are under an obligation to take measures to prevent or mitigate negative impacts. However, these must be implemented within a human rights framework to mitigate against violations of economic, social and cultural rights and to reduce the suffering of the most marginalised groups. Social relief and income-support programmes must be provided to ensure food and income security to all those in need.

The global COVID-19 pandemic has encouraged innovative economic and social relief programme interventions by many countries, including Brazil and Namibia, and has accelerated the implementation of such programmes in South Africa.

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12 February 2018

The Black Sash generally supports the amendment to make provision for debt intervention to accommodate those who are grant recipients who are considered as a vulnerable group for unsecured debt- taking into account their vulnerability exploiting their struggle to make ends meet while having secure income. The adverse impact of loans on recipients, especially where the loans are provided fraudulently, illegally and unlawfully by reckless lenders must be considered to protect recipients and impose harsh penalties on credit providers who are reckless lenders. The application process for debt intervention must be simplified to be user friendly with prescribed forms.

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Black Sash submits that the protection of social grants from unlawful deductions is a seminal element of the right to social security/assistance as set out in the Constitution and International Law. 

We therefore take the view that tightening the provisions pertaining to deductions from social grants is necessary for the protection of social grants. Any failure to do so, by the state, constitutes a failure to protect the right and therefore an independent human rights violation. Black Sash is also of the view that Draft Amendment should be further tightened. 

In summation, Black Sash submits that the DSD should amend the Draft Amendment for better alignment to South Africa’s Constitution and jurisprudential law which requires the state respect, protect, promote and fulfil the right to social security and to take account the demands of International law on a state. 

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