Bold Decisive Digital Lab Equity Afia

Complaint dismissed; enforcement notice issued; prosecution recommended. ODPC, 6 January 2024.

Record ID

ke-odpc-2024-0005

Case reference

ODPC COMPLAINT NO. 1973

Jurisdiction

Kenya

Regulator

ODPC

Type

determination

Date decided

6 January 2024

Respondent type

private

Sector

banking

Violations

unauthorised image/photo use, lack of consent, commercial use of personal data, unlawful data disclosure, failure to prevent data breach, failure to respond to erasure request, unlawful processing, failure to implement security measures

Provisions cited

s.25 DPA 2019, s.26 DPA 2019, s.27(a) DPA 2019, s.28(2) DPA 2019, s.28(1) DPA 2019, s.30 DPA 2019, s.30(a) DPA 2019, s.30(2) DPA 2019, s.32 DPA 2019, s.33 DPA 2019, s.37 DPA 2019, s.41(4) DPA 2019, s.41(2) DPA 2019, s.41(1) DPA 2019, s.56 DPA 2019

Outcome

complaint dismissed; enforcement notice issued; prosecution recommended

Status

final

Source

Official document ↗

Record verified

12 March 2026

Summary

The ODPC dismissed a complaint against Bold Decisive Digital Lab Equity Afia in the banking sector alleging unauthorised image/photo use, lack of consent, commercial use of personal data. The determination considers s.25 DPA 2019, s.26 DPA 2019, s.27(a) DPA 2019, s.28(2) DPA 2019. An enforcement notice was issued against the respondent. A recommendation for prosecution was made.

BANKING · CONSENT · DATA-BREACH · DATA-SECURITY · DISCLOSURE · DISMISSED · RIGHT-TO-ERASURE · UNLAWFUL-PROCESSING

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