lack of consent, unlawful data disclosure, failure to prevent data breach, failure to notify data breach, unlawful processing, failure to implement security measures
The complainant, identified in the determination by the initials EFK, alleged that an employee of Quest Holdings Limited, acting in the course of employment, erroneously attached and disseminated a confidential file containing personal data of NCBA Bank customers, including names, email addresses and outstanding financial amounts, to unintended recipients through a mail merge email. The ODPC found the respondent failed to process personal data in accordance with the data protection principles and failed to put in place effective technical and organisational measures.
Orders and outcome
The respondent was found liable, an enforcement notice was issued against it, and it was ordered to compensate the complainant KES 250,000. Dated September 2025.
ODPC (Kenya), EFK v Quest Holdings Ltd, ODPC Complaint No. 0884 of 2025, determination of September 2025. African Data Protection Enforcement Tracker, Law Lab Africa Research, https://research.lawlab.africa/tracker/kenya/odpc/2025/quest-holdings-ltd/ (accessed 30 August 2026).