{
  "node_id": "ke-odpc-sector-guidance-notes-2024-2025",
  "title": "Kenya ODPC Sector-Specific Guidance Notes 2024-2025 - Communication, Education, Public Sector, Private Security, and Biometric Data",
  "domain": "Data Protection & Privacy",
  "version": "1.0.0",
  "last_updated": "2026-06-04",
  "bluf": "Data controllers and processors operating in Kenya should apply the sector-specific Guidance Notes issued by the Office of the Data Protection Commissioner (ODPC) during 2024 and 2025 under the Data Protection Act 2019, including the Guidance Note for the Communication Sector (2024) which addresses automated decision-making risks and recommends regular review and audit of automated decision-making systems to ensure they are fair and unbiased, the Guidance Note for the Education Sector (2024), the 2025 Guidance Notes for the Public Sector and for the Processing of Recorded Media (addressing automated individual decision making and consent as a lawful basis), the Draft Guidance Note for Private Security (2025) (defining consent as any manifestation of express, unequivocal, free, specific and informed indication of the data subject's wishes by a statement or by a clear affirmative action), and the Draft Guidance on Processing of Biometric Data (2025) (including the right not to be subject to automated decision making).",
  "paywall": {
    "status": "LOCKED",
    "unlock_cost_usd": "0.01",
    "skyfire_id": "41779894-ece2-4163-9761-b3b1b76e19b0"
  },
  "crosswalks": {
    "_available_keys": [
      "nist_framework",
      "iso_standard",
      "industry_mapping",
      "ai_overlay_2026"
    ],
    "_note": "Full crosswalk values included in vault response"
  },
  "dependencies": [
    "gdpr-article-5-data-principles"
  ],
  "primary_citations_count": 5
}