Authority: ODPC - Kenya
Jurisdiction: Kenya
Relevant law: Section 25, 26 of the Data Protection Act, 2019; Article 31 of the Constitution of Kenya
Type: Complaint
Outcome: No Violation
Started: 25 October 2023
Decided: 22 January 2024
Published: Yes
Fine: N/A
Parties: Nickson Mudii vs. Arrow Facilities Ltd
Case No.: 2187 of 2023
Appeal: N/A
Original Source: ODPC
Original contributor: MZIZI Africa

Contents

  1. Summary
    1. Facts
    2. Holding
  2. Comment
  3. Further resources
  4. The Decision

Summary

Arrow Facilities Limited (the “Respondent”), who used a former employee's image in promotional material was held not to have breached the Data Protection Act, 2019 when it was found that the activities the subject of the complaint occurred before the Act came into force, and that the Respondent also promptly resolved the dispute by pulling down the offensive materials.

Facts

Nickson Mudii (the Complainant”) was previously employed by Arrow Facilities Limited (the “Respondent”), a cleaning company.

The Complainant averred that on 3 August 2019 he participated in a photoshoot in the course of his employment with the Respondent, who thereafter used the images in promotional material without his consent.

The Respondent confirmed the use of the Complainant's images in the promotional material but averred that the Complainant was informed of the use of his photos before his participation in the shoot and that it promptly took the photos down when the Complainant protested its continued use.

Holding

The ODPC held that it could not apply the data protection law which was inplemented on 25 November 2019 retrogressively.

Notwithstanding this, the ODPC noted that the Respondent promptly resolved the complaint by pulling down the offending advertisement and the matter was thus resolved.

Comment

The full text of the ruling is available below.

Further resources

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The Decision