Tools for Humanity Corporation, Tools for Humanity GmbH and Worldcoin Foundation

Suo moto investigation; enforcement notice issued. ODPC, 6 September 2023.

Record ID

ke-odpc-2023-0019

Case reference

ODPC Complaint No. 1394 of 2023

Jurisdiction

Kenya

Regulator

ODPC

Type

investigation

Date decided

6 September 2023

Respondent type

private

Sector

general

Violations

failure to register with odpc

Provisions cited

s.21 DPA 2019, s.22 DPA 2019, s.23 DPA 2019, s.25 DPA 2019, s.29 DPA 2019, s.31(5) DPA 2019, s.31 DPA 2019, s.32 DPA 2019, s.48 DPA 2019, s.49 DPA 2019, s.49(1) DPA 2019, s.56 DPA 2019

Outcome

suo moto investigation; enforcement notice issued

Status

final

Source

Official document ↗

Source integrity

SHA-256 ae2294466e5f00b7…

Record verified

21 September 2026

The facts

A suo motu investigation into the Worldcoin project's operations in Kenya, run with a multiagency team, examined the collection of iris data from Kenyans in exchange for cryptocurrency. The Office found the respondents irregularly and unlawfully continued processing sensitive personal data despite its cease-and-desist letter of 30 May 2023 and a cessation directive of 2 August 2023, with further breaches including of the data protection impact assessment obligations.

Orders and outcome

Tools for Humanity Corporation and Tools for Humanity GmbH were found liable for breach of the Act, and an enforcement notice was ordered to issue against Tools for Humanity Corporation, Tools for Humanity GmbH and Worldcoin Foundation. The bundled multiagency report recommended, among other measures, that the WorldApp be pulled from the Kenyan region pending compliance. Dated September 2023.

CONSENT · DATA-SECURITY · DISCLOSURE · GENERAL · OBSTRUCTION · RIGHT-TO-ERASURE · UNLAWFUL-PROCESSING

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