individual has committed an offense under the Act, he must report          this to police  as soon as possible.107   If the person  does not          do so, he may be imprisoned for up to one year.               B.   Analysis               The Israeli computer  crime bill is more  comprehensive then          the America bill.  By creating a law which will apply not only to          government computers, but  also to those of  "business, industry,          agriculture, health  services  or  for  scientific  purposes,"108          the  law  essentially  covers all  computers  in  the country.109          By creating such broad coverage, the law will be able to make the          users of computers in Israel  more secure in their knowledge that          their systems are safe.                 B.   Analysis               The Israeli computer  crime bill is more  comprehensive then          the America bill.  By creating a law which will apply not only to          government computers, but  also to those of  "business, industry,          agriculture,  health  services  or  for scientific  purposes,"110          the  law  essentially  covers all  computers  in  the country.111          By creating such broad coverage, the law will be able to make the          users of computers in Israel  more secure in their knowledge that          their systems are safe.               The  most controversial provision in the act is the proposal          requiring  that individuals that may  know of computer crime must          report the  crime or  face fines themself.   As  Levenfeld points          out112,  this  will  mean  that  employers  will have  to  impose          internal  spy rings  to be  able  to tract  down the  "reasonable          suspicions" that  individuals have  concerning illegal  activity.          Shalgi, however, believes  that this is a good  provision in that          it will allow  computer crime to  come more  to the forefront  so          that the crime can be more easily combatted.113               This provision is necessary for the government to understand          exactly how  large of a problem  computer crime is.   At present,          statistics on computer  crime are difficult to  determine because          of the  lack of reporting.114   By  making all persons  who would          be responsible for  computer security, i.e.  all persons who  use          computer systems, the  problem will be brought into  the open and          can be addressed.               The  proposed law  also sets  out  a defense  for those  who          violate the  law.  Under   11, if a  person who violates  the law          makes another know that he did disrupt or alter the data, he will          not be convicted of the crime. This will allow  those who perform          such acts to avoid  the punishment of  the law.  Individuals  who          wish to destroy or alter  such information will have an incentive          to bring forth their mischievous acts so that when brought before          the  court they  could say  that  they took  precautions so  that          individuals would  not rely on  the information.   This provision          will encourage those who do  such activity to come  forth without          fear of conviction.               The ability  of a  court to  not impose  a  punishment on  a          person  is contained  in section  12.115   This allows  the court          to abstain from  punishment if the offense  is not grave and  was          not committed with  malice.  This section, in  effect, will allow          those who commit computer crime to be able to forgo punishment if          their acts  were not serious.   This will be  beneficial to those          who  are  hackers in  the  original  sense  of the  word,116  yet          still allow for punishment of those individuals who enter systems          to do harm to it.               The law  also creates  standards for how  a computer  may be          seized.  Neither  a computer, nor any  part of it, may  be seized          without a  court order.117   Although  this seems  to  be a  good          provision in  its effects  on individual  rights118, the  section          is not focused  enough.  The  law does not  address the issue  of          whether  a floppy,  as  opposed to  a  hard disk,  is  part of  a          computer.  The hard disk  is located inside of a  computer, while          floppy  disks may be removed from the  computer.  This law should          address this issue by stating that the floppy disk is also a part          of a computer in its definitions.119               This section also does not address what standard may be used          for the  court order.   Must the officer  only have a  reasonable          suspicion or  probable cause to  seize the computer?   By stating          explicitly  in the  statute that the  officer must  have probable          cause to seize the  computer, an overzealous police officer  will          not be able to as easily seize the computer.               C.   The Great Britain Computer Misuse Act               In response  to computer  program concerning  AIDS that  was          distributed to doctors in Great Britain and Europe that contained          a  virus,120  Michael   Colvin,  a  British  MP   introduced  the          Computer  Misuse  Bill.121   On  August  29, 1990,  the  Computer          Misuse  Act122  came  into  effect.123    It was  estimated  that          the losses to  British industry and  government were one  billion          pounds.124     This  Act   is  designed  to   not  to   create  a          confidential information  right, but  to rather  protect computer          system integrity125.               Prior to enactment,  the English Law Commission  studied the          problem and laws  regarding computer crime. It stated  that there          should be three new offenses  to deal with computer misuse:   (1)          Unauthorized access  to a  computer, (2)  Hacking with  intent to          commit  a serious crime,  and (3)  Intentional destruction  of or          alteration  to  computer  programs  or  data.126    The  Computer          Misuse Act states that  unauthorized access occurs if the  person          is unauthorized to access the computer, he causes the computer to          perform any function with intent to  gain access to a program  or          data  in the  computer and  he knows  that this  is the  case.127          He does not have to be directed to any particular program or data          in the computer  he attempted to get on or the data or program he          wishes to  access.128   If a  person commits  unauthorized access          with   the  intent  to  commit129  or  help  another  offense,130          the  person can  be sentenced  on summary  conviction, up  to six          months  in  prison  and  a   fine,131    or  if  convicted  after          indictment,  to imprisonment  of  up  to five  years,  a fine  or          both.132               If a  person modifies  computer material,133  the person  is          subject  to  a  fine of  up  to  5 years,  an  unlimited  fine or          both.134   The  person must  knowingly modify  a  program without          authorization and must have done so with the intent to impair the          operation of the computer, to prevent or hinder access, or impair          the  operation  of  the  program  or  resulting  data.135     The          modification does  not have to  be permanent.136   A modification          may be done by  either altering, erasing or adding onto a program          or data.   By stating  modification broadly, the act  attempts to          combat  the  placing  of  viruses,   worms  and  logic  bombs  on          computers.137               The Act  also  extends  the scope  of  jurisdiction.138    A          person does  not have  to actually  be in  Great  Britain at  the          commission  of  the crime.    The  crime  itself must  have  some          relation   to   Great    Britain.139      The   link    must   be          "significant".140               D.   Analysis               As opposed to  the other statutes,  the Computer Misuse  Act          does not  attempt to define computer.   This was done  because of          the fear that any definition given for a  computer may become out          of date  in a  short period  of time.141   Program  and data  are          also not defined within the Act.               Great  Britain's courts are granted large jurisdiction.  The          act allows for anyone who attempt to commit a crime under the act          to be punished in  Great Britain.  The act, although  setting out          that  the  link  must  be significant,142  does  not  attempt  to          define this word.   By this omission, the  Great Britain's courts          can expand this  to any act that occurs in a foreign country that          uses  a British computer  for even a  short period of  time.  The          defining of the word would  clear up some misconceptions that may          result from the act.               Of interest  to note, the Act would  not punish a person who          distributes disks  tat contain  viruses  on them.   Although  the          drafter of the  bill said that this was his goal, the law ignores          this possibility.  An amendment should  be added to the law which          will punish those who damage data even  if they do not access the          system.               E.   Ghana               In response to the belief  that their existing laws were not          adequate,  a draft  law  was  proposed by  the  Ghana Law  Reform          Commission.143   The  bill is  rather  simple as  opposed to  the          other laws.   It has definitions  for access, computer,  computer          network,  computer program  and  data.144    To  commit  computer          related  fraud, the  person must  have an  intent to  defraud and          either alters, damages destroys data or program stored in or used          by the computer or obtains information to his own advantage or to          the  disadvantage  of another  or  uses  a  computer commits  and          offense.145    The  Act  Also  sets  out  alternatives  for  some          sections that  may be adopted.   The alternative states  that any          person  who obtains  access to  a  computer program  or data  and          attempts to erase  or alter  the program or  data with intent  to          help his  own interests or damage other person's interest commits          a crime.146               Damaging computer data occurs  if any person, by  any means,          without  authority, willfully  does  damage  to  data  commits  a          crime.147    The crime  of  unauthorized  use  of a  computer  is          simply  defined as anyone who knowingly without authority commits          an  offence.148   Similarly, unauthorized  access  is anyone  who          knowingly gains access  to a computer, network or  any part there          of, without authority to  do so.149   The Ghana law also  creates          a crime for the  knowingly and dishonestly introduction of  false          data  and the  omission to  introduce, record  or store  data.150          An  authorized  person  who  willfully  or  intentionally  allows          information to get  into the hands of an  unauthorized person and          that person uses the information  to his advantage also commits a          crime.151               The penalties  for the  crimes are similar  to those  of the          Great Britain  law.152  On  summary convictions, a jail  term may          be given of  up to  two years  or the statutory  maximum fine  or          both.153   On  conviction  on  indictment, a  prison  term of  no          more  then  ten  years  or an  unlimited  fine,  or  both may  be          given.154               The  jurisdiction that the Ghana courts  have in accord with          this  jurisdiction is as  large as their  British counterpart.155          The courts can hear  any case if the accused person  was in Ghana          at the time  of the act.156   Also,  if the program  or data  was          stored in or  used with a computer  or computer network  in Ghana          the person may be tried under the law.157               F.   Analysis               The Ghana proposed Computer Crime  Law is in accord with the          United States, Great  Britain and the proposed Israeli  laws.  By          setting  out  definitions  for  the  various  terms  used in  the          law158,  the law  clearly defines  which acts  may be  subject to          prosecution  under the  law.   Although  simple, the  definitions          attempt to capture  within the law's grasp  the various different          acts which could be done with a computer that should be outlawed.               The most  original section  of  the act  concerns the  newly          created  crime  of   omission  to  introduce,  record   or  store          data.159   This  section, however,  will end  up punishing  those          who work in corporations that are at the lowest level skill-wise.          The government should, if the  law is enacted, force companies to          give each employee a sufficient  amount of training on a computer          so that the  person will be  able to act  in accordance with  the          law.   The act does provide a safeguard by making the mens rea of          the crime "negligently or dishonestly"160               The act also sets out  a crime for an individual who  allows          information  to get  into the  hands of  another.161   As opposed          to the other laws, this  section specifically address the problem          of  where  an  authorized  individual  gives  information  to  an          outsider.  By  specifically regulating this behavior,  anyone who          wishes to act according will know that the act is illegal.               The   crime   of    computer-related   fraud   is    defined          broadly.162    This  law  effectively makes  any  type  of  fraud          committed either with a computer or information within a computer          a crime.   The law  adequately addresses the problems  that might          occur with a computer in fraud.  A broad definition, however, may          still let some act seem as though they are not covered  since the          act is not specific in the area of what constitutes a crime.               Most significantly,  the act does  not state which  types of          computers are covered  by the act.163   By not giving a  limit on          which computers are  covered, the act extends its jurisdiction to          all  "computer"164  and  "computer  network"165 in  the  country.          If the  definition of  computer changes, due  in part  to advance          technology, the law may have to change this section.          V.   Proposed Solutions               Computer Crime laws  have come a long way  in addressing the          problem  of  computer  crime.166   The  ability  to regulate  the          activity will  decrease the amount  of crime  that is  committed.          Those who use the computers of the world, however, must  not rely          totally   on  there   respective  governments   to   combat  this          problem.167               The best way to combat computer crime is to not let it occur          at  all.   Many  computer  systems  have  not been  given  enough          security by  their system  managers.168  It  is possible  to have          a totally  secure computer system169,  but it is  impractical and          slows the  free flow  of information.170   By creating  laws that          will  protect  the  integrity  of  computer  systems  while  also          allowing for the ability of our best and brightest to develop and          learn about computer systems will the nation be able to  keep our          technological lead in the world.               In order to combat the problem of unauthorized access, users          of computer systems must be taught to respect each others privacy          within the various  systems.  Creating an standard  of ethics for          those who are  users of computers will  be the best way  since it          will hold the users to standards that must be met.  Although some          organizations have attempted to promogate standards regarding the          ethical   use  of  computer   systems171  no  one   standard  has          emerged.   Proposed rules  of ethics should  balance the  need of          individuals to  be able to  learn and discover about  the various          types of  computer systems, while  at the same time  allowing for          those  who use those systems  to be secure  in the knowledge that          the information stored  on the computer will not be read by those          other then person who should have access to it.               If  computer crime  laws are  enacted,  industries that  use          computers should not use the new laws as a  replacement for using          adequate  security  measures.172    Individuals  or  corporations          that use computer  have several ways  to protect themselves  from          unauthorized access.  If the computer can be accessed by a modem,          the computer  can have a  dial back  feature placed on  the phone          line so that one a  computer is accessed, the computer will  then          call back to make sure that the call  is coming from a line which          is  supposed  to access  the  computer.173    The proper  use  of          passwords174 are also  an effective  way to  address the  problem          of unauthorized access. A recent study  has shown that out of 100          passwords  files, approximately 30 percent were guessed by either          using the  account name  or a  variation of  it.175    A  program