Hilda Musimbi Anyama, suing on behalf of a minor LK v Friends School Keveye Girls High School

Complaint upheld; enforcement notice issued. ODPC, 9 December 2024.

Record ID

ke-odpc-2024-0106

Case reference

ODPC Complaint No. 1349 of 2024

Jurisdiction

Kenya

Regulator

ODPC

Type

determination

Complainant

Hilda Musimbi Anyama, suing on behalf of a minor LK

Date decided

9 December 2024

Respondent type

private

Sector

education

Violations

unauthorised image/photo use, lack of consent, unlawful data disclosure, unlawful processing, failure to implement security measures

Provisions cited

s.25(a) DPA 2019, s.25 DPA 2019, s.26 DPA 2019, s.29 DPA 2019, s.33(1) DPA 2019, s.33 DPA 2019, s.41 DPA 2019, s.56 DPA 2019, s.58 DPA 2019

Outcome

complaint upheld; enforcement notice issued

Status

final

Source

Official document ↗

Source integrity

SHA-256 b4777fd64a5b3570…

Record verified

30 July 2026

The facts

The complainant, guardian of her minor niece, alleged that Friends School Keveye Girls High School unlawfully processed the minor's personal data, resulting in unauthorised disclosure to third parties without her knowledge, consent or lawful justification and against the original purpose of collection. The ODPC found the school failed to fulfil its obligations as a data controller and processor in processing the minor's personal data.

Orders and outcome

The respondent was found liable and an enforcement notice was issued against it as the most appropriate remedy in the circumstances. Dated December 2024.

CONSENT · DATA-SECURITY · DISCLOSURE · EDUCATION · UNLAWFUL-PROCESSING · UPHELD

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