Saira M Iqbal v Olivia Hair

Complaint upheld; compensation ordered. ODPC, July 2025.

Record ID: ke-odpc-2025-0048
Case reference: ODPC Complaint No. 0396 of 2025
Jurisdiction: Kenya
Regulator: ODPC
Type: determination
Complainant: Saira M Iqbal
Date decided: July 2025
Respondent type: private
Sector: general
Violations: unauthorised image/photo use, lack of consent, commercial use of personal data, unlawful processing
Provisions cited: s.25 DPA 2019, s.30 DPA 2019, s.32 DPA 2019, s.37 DPA 2019, s.56 DPA 2019, s.57(1)(c) DPA 2019, s.65 DPA 2019
Outcome: complaint upheld; compensation ordered
Compensation: KES 500,000 (≈ USD 3,880 at the decision date)
Status: final
Source: Official document ↗
Source integrity: SHA-256 400d7ef0822da0a2…
Record verified: 30 July 2026

The facts

The complainant alleged that Olivia Hair, trading as Di Lorenzo Limited, processed and continued to process her image for commercial purposes without a lawful basis. The ODPC found the respondent failed to prove it had obtained her express consent and continued using her image on its public social media marketing platform, and took the period of the violation into account.

Orders and outcome

The respondent was found liable and ordered to compensate the complainant Kenya Shillings Five Hundred Thousand (KES 500,000). Dated June 2025.

CONSENT · GENERAL · UNLAWFUL-PROCESSING · UPHELD

Cite this decision

ODPC (Kenya), Saira M Iqbal v Olivia Hair, ODPC Complaint No. 0396 of 2025, determination of July 2025. African Data Protection Enforcement Tracker, Law Lab Africa Research, https://research.lawlab.africa/tracker/kenya/odpc/2025/olivia-hair/ (accessed 30 August 2026).

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