Robinah Nyambusi v Platinum Credit Limited

Complaint dismissed. ODPC, 16 February 2024.

Record ID: ke-odpc-2024-0024
Case reference: ODPC Complaint No. 2396 of 2023
Jurisdiction: Kenya
Regulator: ODPC
Type: determination
Complainant: Robinah Nyambusi
Date decided: 16 February 2024
Respondent type: private
Sector: digital lending
Violations: unauthorised image/photo use, lack of consent, commercial use of personal data, unlawful processing
Provisions cited: s.25 DPA 2019, s.32(1) DPA 2019, s.37(1) DPA 2019, s.56 DPA 2019
Outcome: complaint dismissed
Status: final
Source: Official document ↗
Source integrity: SHA-256 53c3f7bd490779b7…
Record verified: 30 July 2026

The facts

The complainant alleged Platinum Credit Limited used her image in a marketing campaign without her consent. The Office found her image had been used on a flyer without prior informed consent, but that the flyer was shared internally rather than used commercially, and the respondent permanently deleted her image from its database once the matter was raised.

Orders and outcome

The complaint was dismissed and compensation declined because commercial use was not proved. The respondent was directed to have all current employees sign a media consent and release form to prevent a recurrence. Dated 16 February 2024.

CONSENT · DISMISSED · FINTECH · MOBILE-LENDING · UNLAWFUL-PROCESSING

Cite this decision

ODPC (Kenya), Robinah Nyambusi v Platinum Credit Limited, ODPC Complaint No. 2396 of 2023, determination of 16 February 2024. African Data Protection Enforcement Tracker, Law Lab Africa Research, https://research.lawlab.africa/tracker/kenya/odpc/2024/platinum-credit-limited/ (accessed 30 August 2026).

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