unauthorised image/photo use, lack of consent, unlawful data disclosure, failure to respond to erasure request, obstruction of data commissioner, failure to conduct dpia, unlawful processing, failure to register with odpc, failure to implement security measures
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.
ODPC (Kenya), Tools for Humanity Corporation, Tools for Humanity GmbH and Worldcoin Foundation, ODPC Complaint No. 1394 of 2023, investigation of 6 September 2023. African Data Protection Enforcement Tracker, Law Lab Africa Research, https://research.lawlab.africa/tracker/kenya/odpc/2023/suo-motu-worldcoin-foundation-tools-for-humanity-tools-for-h/ (accessed 30 August 2026).