Douglas Muiruri Mbugua v Standard Chartered Bank Kenya Limited

Complaint dismissed. ODPC, 14 July 2023.

Record ID

ke-odpc-2023-0007

Case reference

ODPC Complaint No. 0583 of 2023

Jurisdiction

Kenya

Regulator

ODPC

Type

determination

Complainant

Douglas Muiruri Mbugua

Date decided

14 July 2023

Respondent type

private

Sector

banking

Alleged violations

lack of consent, unlawful processing

Provisions cited

s.20 DPA 2019, s.25 DPA 2019, s.26 DPA 2019, s.29 DPA 2019, s.30 DPA 2019, s.36 DPA 2019, s.56 DPA 2019

Outcome

complaint dismissed

Status

final

Source

Official document ↗

Source integrity

SHA-256 eef672714b3f74a5…

Record verified

30 July 2026

The facts

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

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