Ibrahim Limo v Seneca East Africa Limited

Complaint upheld; compensation ordered. ODPC, 23 April 2025.

Record ID: ke-odpc-2025-0030
Case reference: ODPC Complaint No. 0119 of 2025
Jurisdiction: Kenya
Regulator: ODPC
Type: determination
Complainant: Ibrahim Limo
Date decided: 23 April 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.37 DPA 2019, s.37(1) DPA 2019, s.56(1) DPA 2019, s.56 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 c4127851a0e8e2b8…
Record verified: 30 July 2026

The facts

The complainant, a former employee of Seneca East Africa Limited, alleged the respondent continued using his photos on its website and social media pages to market its services long after his employment ended. The ODPC found the respondent used his personal data for commercial purposes without consent.

Orders and outcome

The respondent was found liable and ordered to pay the complainant Kenya Shillings Five Hundred Thousand (KES 500,000) as compensation. Dated 23 April 2025.

CONSENT · GENERAL · UNLAWFUL-PROCESSING · UPHELD

Cite this decision

ODPC (Kenya), Ibrahim Limo v Seneca East Africa Limited, ODPC Complaint No. 0119 of 2025, determination of 23 April 2025. African Data Protection Enforcement Tracker, Law Lab Africa Research, https://research.lawlab.africa/tracker/kenya/odpc/2025/seneca-east-africa-limited/ (accessed 30 August 2026).

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