DATA PROTECTION DIGEST

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The complete archive of the Digest's published coverage: analysis, data protection news, enforcement orders and regulatory developments from across Africa. 45 entries across 10 jurisdictions.

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ANALYSIS
KE · ANALYSIS

KENYA'S VASP REGIME: 121 DAYS TO THE 4 NOVEMBER DEADLINE, AND THE REGULATIONS STILL AREN'T GAZETTED

Every VASP operating in Kenya must comply with the VASP Act 2025 by 4 November 2026. The implementing regulations that define what compliance means have not been gazetted. That combination is the compliance story of the Kenyan crypto year.

UK · ANALYSIS

THE ICO'S AI GUIDANCE FOR PUBLIC AUTHORITIES, AND WHAT AFRICAN REGULATORS WILL BORROW FROM IT

The UK ICO published guidance on AI-generated freedom of information requests in May 2026. African DPAs cite ICO precedent habitually, and Nigeria's NDPC has already signed a 60-authority statement on AI imagery. Public bodies should read this as a preview.

ANALYSIS

ODPC DETERMINATIONS NOW HAVE TEETH: DIRECTORS FACE PROSECUTION AND AWARDS CONVERT TO COURT ORDERS

Two 2026 decisions close the gap between an ODPC determination and real consequences: criminal exposure for directors, and High Court execution machinery for compensation awards.

KE · ANALYSIS

SMART GLASSES, NAIROBI LABELLING FLOORS AND THE ODPC: KENYA OPENS THE WEARABLES FRONT

The ODPC opened a suo moto investigation into Ray-Ban Meta smart glasses after reporting revealed footage from the devices was being reviewed by human contractors in Nairobi to train Meta's AI. After Worldcoin, the direction is unmistakable.

SN · ANALYSIS

THE UEMOA QUESTION: BCEAO GOES FROM SILENCE TO A QUESTIONNAIRE TO A CRYPTO CONFERENCE IN TEN WEEKS

The central bank for eight West African states surveyed fintechs on crypto in February, then convened an international crypto-assets conference in Dakar in May. When the BCEAO finally regulates, one framework lands in eight countries on the same day.

NG · ANALYSIS

NIGERIA'S NDPC IS EVERYWHERE: AN ENFORCEMENT MAP FOR 2026

Investigations into Temu and the Corporate Affairs Commission, a security advisory with mandatory upgrades, MoUs reaching procurement and all 36 states: the NDPC's 2026 is a build-out of enforcement infrastructure, not a run of one-off cases.

KE · ANALYSIS

KENYA BRINGS HEALTH SOFTWARE UNDER MEDICAL-DEVICE REGULATION: WHAT THE PPB'S NEW MDSW GUIDELINE DEMANDS OF APPS, ALGORITHMS AND AI

The Pharmacy and Poisons Board now regulates software as a medical device: a four-category IMDRF risk matrix, registration through the Board's portal, cybersecurity documentation, and ten Good Machine Learning Practice principles for AI. Health apps that diagnose or treat sit in the highest categories, and the guideline orders compliance with the Data Protection Act 2019 and the Digital Health Act 2023 by name.

KE · ANALYSIS

KENYA'S ODPC BY THE NUMBERS: 9,061 COMPLAINTS, 357 DETERMINATIONS, 184 COMPENSATION ORDERS

The ODPC's own statistics, announced ahead of the 2026 Data Privacy Day Conference, describe the most active enforcement docket on the continent. The pattern in the data tells you who gets investigated.

GH · ANALYSIS

GHANA 2026: THE YEAR THE DATA PROTECTION COMMISSION STARTED ENFORCING

Fourteen years after Act 843, Ghana's DPC has moved from awareness campaigns to nationwide enforcement, with a new Data Protection Bill queued behind it. Registration is the exposed flank.

GH · ANALYSIS

GHANA'S VASP ACT AND THE WEST AFRICAN CONVERGENCE: THREE CRYPTO LAWS IN THREE MONTHS, AND A SANDBOX ALREADY LIVE

Ghana's VASP Act (Act 1154) took Africa's standalone crypto statutes to three inside a quarter, and its SEC sandbox admitted its first participant within four months of assent. The anglophone West African licensing model is converging fast.

ET · ANALYSIS

ETHIOPIA'S ENFORCEMENT GAP: A DATA PROTECTION LAW WITH NO MACHINERY, AND A CENTRAL BANK MOVING FASTER THAN THE REGULATOR

Proclamation 1321/2024 carries 4%-of-turnover penalties and prison terms, yet two years in there are no implementing directives, no registration portal and no enforcement. Meanwhile the National Bank banned birr-paired crypto P2P in one statement.

ZA · ANALYSIS

SOUTH AFRICA'S INFORMATION REGULATOR GOES TO COURT, AND KEEPS LOSING ON MATRIC RESULTS

What POPIA means is being decided in litigation the Regulator keeps initiating: matric results, telemarketing, WhatsApp, and a contested R5 million fine. The scoreboard so far favours respondents.

ZA · ANALYSIS

OFF THE GREY LIST, ONTO THE RULEBOOK: SOUTH AFRICA MOVES CRYPTO INTO EXCHANGE CONTROL

South Africa exited the FATF grey list in October 2025. What followed was not relaxation but codification: draft Capital Flow Management Regulations that classify crypto as 'capital', CARF reporting from March 2026, and 30 FSCA inspections in a year.

NG · ANALYSIS

GAID 2025: THE DIRECTIVE THAT ACTUALLY GOVERNS DATA PROTECTION COMPLIANCE IN NIGERIA

The NDPA 2023 sets the principles. The General Application and Implementation Directive is where Nigerian compliance obligations actually live. If your programme was built on the NITDA-era regulation, it is out of date.

UG · ANALYSIS

UGANDA'S GOOGLE RULING: THE EXTRATERRITORIALITY PRECEDENT AFRICAN REGULATORS WERE WAITING FOR

Uganda's data protection authority held that a company with no Ugandan office, staff or servers is still a regulated data controller. The reasoning travels.

KE · ANALYSIS

THE WORLDCOIN JUDGMENT: WHAT KENYA'S HIGH COURT DECIDED, AND THE STANDARD IT SET FOR BIOMETRIC DATA

Iris scans in exchange for about $50 in tokens, no DPIA. The High Court's Worldcoin ruling is the reference point for every biometric processing question in Kenya, and no appeal has been filed.

MAY 2026 ALL 3
APRIL 2026 ALL 17
GH · CRYPTO & DIGITAL ASSETS

Ghana's SEC admits Africoin to its VASP sandbox

8 April 2026 · Crypto & digital assets
MARCH 2026 ALL 5
FEBRUARY 2026 ALL 5
JANUARY 2026 ALL 4
DECEMBER 2025 ALL 2
NOVEMBER 2025 ALL 3
OCTOBER 2025 ALL 1
JULY 2025 ALL 2
MAY 2025 ALL 1
MARCH 2025 ALL 1
JULY 2024 ALL 1