The complainant, a former employee of Standard Chartered Bank Kenya Limited terminated over corruption allegations, alleged the bank unlawfully obtained and recorded a telephone conversation that formed the basis of his termination. The ODPC found the bank had a legal basis for the processing: consent in clause 25 of his employment contract, the necessity of enforcing that contract, a court order directing processing of the conversation, and legitimate interest.
Orders and outcome
The Office determined the respondent did not breach the complainant's rights, and that it had demonstrated the duty to notify and the legal basis relied on. The complaint failed. Dated 2023, with the day and month illegible in the scan.
BANKING · CONSENT · UNLAWFUL-PROCESSING
Cite this decision
ODPC (Kenya), Douglas Muiruri Mbugua v Standard Chartered Bank Kenya Limited, ODPC Complaint No. 0583 of 2023, determination of 14 July 2023. African Data Protection Enforcement Tracker, Law Lab Africa Research, https://research.lawlab.africa/tracker/kenya/odpc/2023/standard-chartered-bank-kenya-limited/ (accessed 30 August 2026).