Introduction

Kenya’s remarkable journey towards a digitized community healthcare system, led by the Ministry of Health, is bolstered by the electronic Community Health Information System (eCHIS). Since its launch, eCHIS has integrated real-time data from Kenya’s community health workforce services into the national health management information systems.

This digital health transformation initiative covers Kenyans across several counties, transforming data visibility and strengthening the country’s response to health challenges, from prenatal care, immunization, nutrition education, treatment of common illnesses, COVID-19 vaccination campaigns to robust malaria surveillance.

The Importance and Relevance of Data Protection in Digital Health

In the context of digitalization in the community health ecosystem, the importance of data protection cannot be overstated. Community health workers – now called Community Health Promoters (CHPs) in Kenya are the central cog in driving the community health digitization agenda.

As Kenya undertakes rapid digitization, spanning administrative and clinical data on citizens, Data Protection Impact Assessments (DPIAs) should be a critical component with Kenya Data Protection laws playing a pivotal role in ensuring the responsible use of personal sensitive health data and resultant information. They are essential in addressing emergent risks and mitigation measures related to unauthorized access, exclusion, or unintended analysis, which could inhibit the data subject’s rights.

The Role of Living Goods and Our Commitment to Data Protection

Living Goods is a fully compliant entity and is registered with the Office of Data Protection Commissioner (ODPC) as both data controller and processor and now actively engaged in supporting the Ministry of Health (MoH) in Kenya in its data protection alignment journey. As lead collaborators on Kenya’s eCHIS initiative, Living Goods provides thought leadership and contributes to global best practices in responsible data use for public health decision-making.

We have worked closely with the MoH in the implementation of the DPIA regulations tailored to community-based processes and workflows and are actively contributing to the institutionalization of the assessment tools. Our team supported the inaugural eCHIS data protection impact assessment exercise prior to the national launch by His Excellency President William Ruto in October 2023.

Our teams are continually involved in building capacities for the implementation of DPIAs, ensuring that they are effectively carried out. Critically, the CHPs we support facilitate participatory audits, ensuring that the voices of rural communities, who are often the backbone of community health efforts, are heard and integrated into the implementation process. We are committed to tracking the effectiveness of data protection controls and support continuous updates in response to evolving technology landscapes and changing dynamics in community health services delivery in Kenya.

Safeguarding Data Rights in Motion

DPIAs exemplifies a dynamic approach to transparency through iterative optimization. As technologies and health priorities evolve, DPIA provides a robust framework for identifying and addressing risks to data subject rights including mitigation measures. It includes requirements that define the permissible disclosures and use of data, empowering data subject’s communities to exercise explicit discretion over their consent preferences. DPIA also opens channels for promoting participative digital literacy programs, ensuring that individuals understand the risks, channels for feedback, and collective responsibilities in preserving this invaluable public good.

Trust Anchored in Ethics and Inclusion

The promise of Kenya’s community-based digital health transformation to enhance community health outcomes is dependent upon sustaining trust built on the foundation of ethics and inclusion to ensure stronger and more resilient relationships. Indeed, responsible innovation mandates the assessment and mitigation of risks to individuals’ rights and dignity. Kenya’s eCHIS initiative sets exemplary standards by prioritizing impact through the lens of those it serves. It demands enduring partnerships, where health policymakers, innovators, and local communities converge to strengthen health equity through the ethical deployment of technology at scale.

In this ever-evolving digital landscape, safeguarding health data subjects’ rights exceeds being a mere requirement; it is a commitment to a healthier, more equitable future for all Kenyans and a learning model for others.