The Nairobi Pilot
Building worker power through data rights
Data Safety Alliance is developing and testing a worker-centred data rights model in Nairobi.
The pilot works directly with platform workers to help them understand how their personal data is collected, used and shared—and how they can exercise their rights under data protection law.
Our work begins with practical data literacy and individual support. Over time, the lessons and evidence gathered through the pilot will help workers identify shared patterns, advocate collectively and influence how platforms and technology companies handle worker data.
Because DSA is still a young organisation, we are approaching this work as a learning pilot: starting at community level, responding to workers’ immediate needs and documenting what is required to make data rights genuinely accessible.
Who we work with
The Nairobi pilot currently engages workers whose livelihoods are managed or mediated through digital platforms.
Ride-hailing drivers
Drivers working through platforms such as Uber and Bolt.
Delivery riders
Motorcycle and bicycle riders working through digitally managed delivery platforms.
Content moderators
Workers reviewing and moderating online content, often under intensive monitoring and demanding working conditions.
AI data workers
Data annotators and data labellers whose work supports the development and operation of artificial intelligence systems.
How the pilot works in practice
Our engagement model is intentionally flexible because platform workers often have unpredictable schedules, income pressures and limited time to attend formal workshops.
Small-group sessions
Data literacy discussions with small groups, sometimes involving as few as five workers.
Community sensitisation clinics
Accessible sessions for workers interested in understanding their data rights and how those rights connect to their working conditions.
One-to-one SAR guidance
Practical support for workers preparing and submitting Subject Access Requests.
Meeting workers where they are
Informal conversations during rides, at worker meeting points and through trusted community networks.
Data rights support during an ordinary ride
In one instance, guidance on a Subject Access Request began during an ordinary ride with an Uber driver. Encounters like this demonstrate why worker-rights support cannot always depend on formal offices, fixed appointments or large public events.
Early activities and reach
Through data literacy conversations, small-group sessions and community sensitisation activities.
Practical support for workers seeking to obtain personal data held by platforms or employers.
At this stage, we do not present participation numbers as proof of large-scale impact. Instead, the pilot is helping us understand what workers need before data rights can become genuinely usable.
Core questions guiding the pilot:
- 1 What do workers already know about their data rights?
- 2 Which data practices cause the greatest concern?
- 3 What prevents workers from exercising their legal rights?
- 4 What support is needed before a worker can confidently submit and follow up on a data request?
- 5 How can individual experiences reveal wider patterns across a sector?
What workers are telling us
Workers have raised concerns about the collection of highly sensitive personal information, including selfies, facial scans, voice recordings, identity documents, location data and images captured inside their homes and communities.
Biometric and personal data
Some AI data workers have described assignments involving photographs of their bodies, surroundings or family members—including children—without receiving clear information about how those images will ultimately be used, retained or shared. Workers may be told how to complete a task, but not necessarily how their personal information contributes to a wider dataset, which organisations will receive it or what safeguards will apply after submission.
Continuous monitoring
Ride-hailing and delivery workers have raised concerns about continuous location tracking, identity-verification checks, performance monitoring and customer-rating systems.
Decisions without explanation
When an account is restricted or deactivated, workers may receive limited explanations and may not know which data, ratings or automated processes contributed to the decision.
DSA is documenting these concerns carefully. At this stage, they represent emerging themes from worker engagement rather than conclusions about every platform or employer.
What we are learning
Data protection language must connect to everyday work
Terms such as lawful processing, automated decision-making and data-subject rights can feel distant from workers’ immediate concerns. Engagement becomes more meaningful when rights are connected to practical questions: Why was my account deactivated? What information does the platform hold about me? Where are my photographs or biometric details being stored? Who has received my data? Can I correct inaccurate information? Can I challenge a decision made about my work?
Awareness alone is not enough
Many workers may understand that something is wrong but still struggle to exercise their rights. Submitting a Subject Access Request can require a worker to identify the correct organisation, locate contact details, write a clear request, verify their identity, monitor legal deadlines and follow up when a response is incomplete or delayed.
Trust is essential
Workers may be reluctant to discuss biometric data, account deactivations or workplace surveillance when they fear retaliation or loss of income. Small sessions and one-to-one conversations can create safer spaces for workers to ask questions and share experiences.
Individual cases can reveal collective problems
A single Subject Access Request may help one worker understand what information is held about them. When similar requests and experiences are examined together, they may reveal recurring practices affecting an entire group of workers.
“Our long-term aim is not only to help individual workers obtain their information. It is to explore how workers can use data rights collectively to demand transparency and accountability and greater influence over the digital systems that govern their livelihoods.”
What happens next
The next phase of the Nairobi pilot will focus on strengthening both worker support and systematic learning.
Expand worker engagement
Expand community-based data literacy and sensitisation sessions.
Strengthen practical support
Continue guiding workers who want to prepare, submit and follow up on Subject Access Requests.
Develop accessible tools
Create simple resources that workers and community organisers can use independently.
Build partnerships
Strengthen relationships with worker associations, community organisers, legal practitioners and data protection specialists.
Document recurring barriers
Record the challenges workers experience when attempting to access their personal data.
Identify sector-wide patterns
Analyse recurring themes across ride-hailing, delivery, content moderation and AI data work.
Share early learning
Publish responsible insights from the pilot without exposing or identifying participating workers.
Inform advocacy
Use the emerging evidence to support policy engagement, advocacy and future collective data-rights strategies.
An early model grounded in worker experience
The Nairobi pilot is still developing. We are learning what works, correcting what does not and building carefully from the experiences of workers themselves.
For partners and funders, this pilot offers an opportunity to support an emerging model at a formative stage—before its methods, partnerships and evidence base are expanded.
For workers, it offers a starting point for understanding a simple but important principle: