RESOURCES FOR WORKERS

Know Your Data Rights

Every time you log into a work platform, complete a task, accept a trip, upload a selfie, submit an annotation or communicate with support, information may be collected or generated about you.

This information can affect your access to work, earnings, performance ratings, task allocation, account restrictions and deactivation.

You are not only a worker within a digital system. You are also a data subject with rights.

Worker Data Sovereignty

Platform Power & Worker Data

Algorithmic Allocation

Work, ratings & automated management

Biometric & Activity Data

Selfies, location, keystrokes & audio

Enforceable Statutory Rights

Kenya DPA 2019 & International protections

Free Guidance DSA Worker Support
Legal Protections

Your data rights at a glance

Workers in Kenya have rights over personal information held or used by companies, platforms and other organisations.

Be informed

Understand how and why your personal data is being collected and used.

Right to Transparency

Access your data

Ask an organisation to confirm whether it holds your personal data and request access to it.

Right of Access (SAR)

Object to processing

Object to certain uses of your personal information.

Right to Object

Correct inaccurate data

Ask for false, incomplete or misleading information to be corrected.

Right to Rectification

Request deletion

Request deletion of false or misleading personal data where the law allows.

Right to Erasure

Section 26 of the Kenya Data Protection Act, 2019 recognises the rights to be informed, access personal data, object to processing, request correction and request deletion of false or misleading data. Where the GDPR applies, related rights include access, rectification, erasure in qualifying circumstances, restriction, objection, portability and protections concerning certain automated decisions.

The GDPR does not automatically apply to every worker or company in Kenya. Its application depends on the organisation, its location and the nature of the data processing.

Core Mechanism

What is a Subject Access Request?

A Subject Access Request, commonly called a SAR, is a request asking an organisation to:

Confirm whether it holds or uses personal data about you.
Give you access to that personal data.
Explain why it is being used.
Explain who has received it.
Explain how long it will be retained.
Provide information about certain automated decisions or profiling, where applicable.

Under Kenyan regulations, this may also be described as a data access request.

A Subject Access Request is a practical way to understand what information a platform or company holds about you.

Coming soon

Full Subject Access Request Guide

A detailed worker-friendly guide is being developed.

Resource in active development
Triggers & Scenarios

When might you submit a SAR?

Platform workers encounter various situations where requesting personal data is crucial to protecting livelihoods and ensuring accountability.

Your account was suspended or deactivated

You want to understand whether ratings, complaints, account flags, performance records or automated systems contributed to the decision.

Incorrect information may be affecting your work

This could include inaccurate identity information, ratings, location records, quality scores or performance assessments.

You provided sensitive information

This may include identity documents, facial scans, iris scans, voice recordings, fingerprints or photographs of you, your home or your family.

You do not know how your data is being used

You want to understand whether information collected for one purpose is being used for another.

Your information may have been shared

You want to identify the companies, clients, contractors or service providers that have received your data.

You want to understand an automated decision

You want information about the data and main factors used to allocate work, calculate performance, restrict an account or make another significant decision.

Section 35 of the Kenya Data Protection Act and Article 22 of the GDPR provide protections relating to certain decisions based solely on automated processing that significantly affect an individual.

Scope of Access

What information can you request?

The information available will depend on the platform and the personal data it holds.

Account and identity

  • Account and profile information.
  • Identity and verification records.
  • Photographs, selfies and biometric-verification data.
  • Login and device information.

Work and performance

  • Work history and completed tasks.
  • Trip, route or delivery records.
  • Ratings, reviews and customer feedback.
  • Productivity, quality and accuracy scores.
  • Complaints, account flags and internal notes relating to you.

Earnings and decisions

  • Earnings, payments, commissions and deductions.
  • Records connected to warnings, restrictions or deactivation.
  • Information used in automated decision-making or profiling.

How the data is used

  • The purposes for which your data is processed.
  • Who has received it.
  • Whether it has been transferred internationally.
  • How long it will be retained.
  • Where information not collected directly from you came from.

Important Scope Boundary: The right of access concerns your personal data. It does not automatically provide access to every company document, another person’s information, confidential business information or a platform’s complete source code.

Detailed Information Request Checklist
Coming soon
Action Plan

How to submit a Subject Access Request

DSA is developing step-by-step guides showing workers how to submit data-access requests to the specific platforms and companies they work through.

1

Identify the company

Find the organisation holding or using your data. Check its privacy notice, help centre, privacy team or Data Protection Officer contact.

2

Decide what you need

You may request all personal data held about you or focus on a particular account, project, decision, incident or period.

3

Submit your request

Use the organisation’s privacy portal, in-app privacy centre, online request form, privacy email address or Data Protection Officer.

4

Keep evidence

Save the request, submission date, screenshots, confirmation emails, reference numbers and responses.

5

Review & follow up

Check whether the organisation answered your questions, supplied the requested data and explained anything it refused or withheld.

Response periods

Kenya Regulation (7 Days): Under Regulation 9 of Kenya’s Data Protection (General) Regulations, a controller or processor should comply with a personal-data access request within seven days, and compliance should be free of charge.
GDPR Standard (1 Month): Where the GDPR applies, organisations generally have one month to respond, subject to the conditions for an extension under Article 12.
Step-by-Step SAR Guide
Coming soon
Downloadable SAR Template
Coming soon
Platform-Specific SAR Guides
Coming soon
Industry Breakdown

Common data concerns by sector

Different forms of digital work generate different types of personal data. Select your sector to see some of the issues that may affect you.

Mobility

Ride-hailing drivers

  • Continuous or historical location monitoring.
  • Trip, route and destination histories.
  • Driver and customer ratings.
  • Facial verification.
  • Account flags and fraud assessments.
  • Automated trip allocation.
  • Suspensions and deactivations.
Logistics

Delivery riders

  • Real-time and historical location data.
  • Delivery acceptance and completion records.
  • Customer and merchant complaints.
  • Performance and reliability scores.
  • Proof-of-delivery photographs.
  • Automated order allocation.
  • Account restrictions.
Online Trust & Safety

Content moderators

  • Productivity and handling-time monitoring.
  • Quality and accuracy assessments.
  • Screen or application activity.
  • Supervisor and reviewer feedback.
  • Wellness or health-related information.
  • Disciplinary records.
  • Removal from projects.
AI Supply Chain

Data annotators and labellers

  • Work and annotation histories.
  • Accuracy and quality scores.
  • Task eligibility assessments.
  • Device and activity monitoring.
  • Identity or webcam verification.
  • Facial, voice, hand, foot or other bodily data.
  • Photographs of workers’ homes, environments or families.
  • Personal information used to train or test AI systems.

Personal data should be processed lawfully, fairly and transparently, collected for clear purposes and limited to what is necessary.

These principles appear in Section 25 of the Kenya Data Protection Act and Article 5 of the GDPR.

Toolbox & Resources

Practical guides and tools

We are developing accessible resources that workers can use independently or with support from DSA.

Coming soon

Subject Access Request Guide

How to prepare, submit, record and follow up on a request.

Coming soon

SAR Request Template

A downloadable template workers can adapt when requesting their personal data.

Coming soon

Platform-Specific Guides

Instructions for ride-hailing, delivery, content-moderation and data-annotation platforms.

Coming soon

Complaints and Follow-Up Guide

What to do when a company does not respond or provides an incomplete answer.

Regulatory Recourse

Need to make a formal complaint?

Workers who believe their data-protection rights have been infringed may submit a complaint to Kenya’s Office of the Data Protection Commissioner.

File a complaint with the ODPC
DSA WORKER SUPPORT

Need help accessing your data?

DSA supports workers to identify the correct organisation, prepare a clear data-access request, decide which information to request, keep records, understand the response and identify appropriate follow-up or complaint options.

"Our role is to help workers exercise their data rights with greater knowledge, confidence and collective power."

Important information

The information on this page is provided for general education and worker-support purposes. It is not legal advice and does not guarantee the outcome of a request or complaint.

The law that applies may depend on the worker’s location, the organisation involved, where the data is processed and the particular circumstances of the case.