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HUMANIST

Party of Kenya
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Humanist Party of Kenya

Privacy & Data Protection Statement

Raia Ndio Nguvu — The People Are The Power
Version: 1.0  |  Effective Date: 23 August 2026  |  Review Date: 23 August 2027
Section 1

Introduction

The Humanist Party of Kenya ("Humanist", "the Party") is committed to protecting the privacy, confidentiality, security and lawful use of personal data entrusted to the Party by its members, prospective members, supporters, officials, employees, volunteers, applicants, suppliers, visitors, website users and other persons who interact with the Party.

This Privacy and Data Protection Statement explains how Humanist collects, receives, uses, stores, protects, discloses, transfers and otherwise processes personal data.

The Party recognizes the constitutional right to privacy under Article 31 of the Constitution of Kenya, 2010, and is committed to ensuring that personal data is processed lawfully, fairly, transparently and responsibly.

Legal Framework: This Statement is made pursuant to and shall be interpreted consistently with applicable Kenyan law, including:

  • The Constitution of Kenya, 2010
  • The Data Protection Act, 2019 (No. 24 of 2019)
  • The Data Protection (General) Regulations, 2021
  • The Data Protection (Registration of Data Controllers and Data Processors) Regulations, 2021
  • The Data Protection (Complaints Handling and Enforcement Procedures) Regulations, 2021
  • The Political Parties Act, 2011, as amended
  • The Political Parties (Membership) Regulations, 2021
  • The Access to Information Act, 2016, where applicable
  • Applicable electoral and political-party laws and regulations
  • Applicable directions, guidance, standards and requirements issued by the Office of the Data Protection Commissioner (ODPC) and the Office of the Registrar of Political Parties (ORPP)
Section 2

Purpose of This Statement

This Statement is intended to:

  • Explain what personal data Humanist collects and processes
  • Explain why the Party collects and processes personal data
  • Explain the legal basis for processing
  • Protect members and other data subjects against unlawful or excessive processing
  • Explain how membership information is managed and submitted to the ORPP
  • Explain the rights of data subjects
  • Establish safeguards for political, membership and other sensitive information
  • Explain the circumstances in which information may be disclosed to third parties
  • Explain how data breaches are handled
  • Establish accountability for Party officials, agents, volunteers, contractors and service providers who handle personal data
  • Provide a mechanism through which data subjects may exercise their rights or raise privacy concerns
Section 3

Who Is Responsible for Your Personal Data?

For purposes of applicable data-protection law, Humanist shall act as a data controller where it determines the purposes and means of processing personal data.

Where Humanist engages another organisation or person to process personal data on its behalf, that organisation or person may act as a data processor and shall be required to process personal data only in accordance with applicable law and the Party's instructions and contractual safeguards.

Humanist shall maintain appropriate internal responsibility for data protection and shall designate an appropriate officer or responsible person to coordinate privacy and data-protection compliance.

Section 4

Personal Data the Party May Collect

Depending on the relationship between the individual and the Party, Humanist may collect and process:

4.1 Identification Information

  • Full name
  • National identification number
  • Passport number
  • Date of birth
  • Nationality/citizenship information
  • Membership number
  • Signature
  • Photograph, where lawfully required or voluntarily provided

4.2 Contact Information

  • Telephone number
  • Email address
  • Postal address
  • Physical address
  • County
  • Constituency
  • Ward
  • Polling-station or community information where necessary for lawful political-party administration

4.3 Membership Information

The Party may process information necessary for:

  • Membership application
  • Verification of eligibility
  • Membership registration
  • Membership confirmation
  • Issuance of membership identification
  • Maintenance of the Party membership register
  • Resignation
  • Transfer of membership
  • Expulsion or other lawful cessation of membership
  • Statutory reporting to the ORPP
  • Administration of members' rights and obligations

4.4 Political Affiliation and Related Information

Membership of a political party necessarily involves information concerning political affiliation or adherence. Humanist recognizes that such information requires particular care and shall not process, disclose or publish it beyond what is legally authorized, reasonably necessary for legitimate Party functions, or otherwise lawfully permitted.

4.5 Digital Information

When individuals interact with the Party electronically, we may collect:

  • IP address
  • Device information
  • Browser information
  • Login information
  • Website interaction data
  • Cookies and similar technologies
  • Communication records
  • Information voluntarily submitted through online forms
Section 5

Sensitive Personal Data

Humanist recognizes that certain categories of information constitute sensitive personal data under Kenyan law.

Enhanced Safeguards: Where the Party processes sensitive personal data, it shall apply enhanced safeguards and shall process such information only where a lawful basis exists and where the processing is necessary, proportionate and compatible with the purpose for which the information was collected.

The Party shall apply the principle of data minimization, meaning that only information reasonably necessary for the relevant purpose shall be collected.

The ODPC's registration framework specifically identifies categories including political opinion or adherence, religious or philosophical beliefs, health information, biometric information, marital and family information and other sensitive categories as requiring appropriate consideration.

Section 6

How the Party Collect Personal Data

Humanist may collect personal data:

  1. Directly from the individual
  2. Through membership application forms
  3. Through the prescribed ORPP membership forms
  4. Through the Party's website
  5. Through approved electronic membership platforms
  6. Through Party offices and officials
  7. During Party events and activities
  8. Through correspondence
  9. Through surveys and consultations
  10. Through lawful referrals
  11. From authorized service providers
  12. From the ORPP or other lawful public authorities
  13. From other lawful sources where permitted by applicable law

Important: The Party shall not knowingly collect personal data through deception, unlawful coercion or fraudulent representation.

Section 7

Purposes for Which Personal Data Is Processed

Humanist may process personal data for the following legitimate purposes:

A. Party Membership

  • Receiving and processing membership applications
  • Verifying membership information
  • Maintaining membership records
  • Communicating with members
  • Issuing membership identification
  • Administering membership rights and obligations
  • Processing resignations and changes in membership status

B. Statutory and Regulatory Compliance

The Party may process and submit information where required by law or by a competent regulatory authority, including the ORPP.

C. Political Participation

  • Civic engagement
  • Policy consultations
  • Political education
  • Lawful mobilisation
  • Public participation
  • Communication with members and supporters
  • Organising Party meetings and events
  • Other legitimate Party activities

D. Administration

  • Human-resource administration
  • Financial administration
  • Procurement
  • Accounting
  • Auditing
  • Legal compliance
  • Security
  • Internal governance
  • Risk management
  • Dispute resolution
  • Protection of Party property and systems

E. Communications

  • Party notices
  • Membership information
  • Meetings
  • Policy consultations
  • Civic education
  • Party programmes
  • Newsletters
  • Electoral information
  • Fundraising information
  • Other legitimate Party communications

Where consent is required, the Party shall obtain appropriate consent before sending direct electronic marketing or other communications requiring consent.

Section 8

Legal Bases for Processing

Humanist shall process personal data only where there is a lawful basis. Depending on the circumstances, this may include:

  • Consent of the data subject
  • Performance of a contract or steps requested by the data subject
  • Compliance with a legal obligation
  • Protection of vital interests
  • Performance of a task carried out in the public interest or in accordance with applicable law
  • Legitimate interests, where permitted by law and where such interests are not overridden by the rights and freedoms of the data subject

The Party shall not rely on consent where another lawful basis is more appropriate.

Section 9

Membership Data and ORPP

Humanist recognizes that political-party membership information is subject to both political-party regulation and data-protection law.

The Party shall:

  • Collect membership information through authorized processes
  • Use the prescribed ORPP membership documentation where applicable
  • Verify membership information
  • Maintain accurate and up-to-date membership records
  • Restrict access to authorized officials
  • Securely transmit information to the ORPP where required
  • Cooperate with lawful verification by the ORPP
  • Correct inaccurate information
  • Process resignations and changes in membership status lawfully
  • Ensure that membership information is not unlawfully disclosed or misused

ORPP Integration: The ORPP states that party membership information is maintained through its Integrated Political Parties Management Information System (IPPMS), and that consent processes are incorporated into membership administration.

Humanist shall therefore treat the Party membership register as a controlled information resource and shall not make the complete membership register publicly available except where disclosure is expressly authorized or required by law.

Section 10

Data Minimisation

Humanist shall collect only personal data that is:

  • Adequate
  • Relevant
  • Necessary
  • Proportionate
  • Reasonably required for the identified lawful purpose

The Party shall not request personal information merely because it may be useful in the future.

Section 11

Accuracy of Personal Data

Humanist shall take reasonable steps to ensure that personal data is:

  • Accurate
  • Complete where necessary
  • Current
  • Corrected where it is inaccurate or misleading

Members may request correction of inaccurate information.

Section 12

Data Retention

Humanist shall retain personal data only for as long as reasonably necessary for:

  • The purpose for which it was collected
  • Membership administration
  • Statutory obligations
  • Accounting and audit requirements
  • Legal claims
  • Dispute resolution
  • Historical or archival purposes where lawfully justified
  • Other lawful purposes

At the expiry of the applicable retention period, personal data shall be securely deleted, anonymised or otherwise disposed of in accordance with the Party's records-retention procedures and applicable law.

Section 13

Data Security

Humanist shall implement appropriate technical and organizational measures to protect personal data against:

  • Unauthorized access
  • Accidental loss
  • Destruction
  • Alteration
  • Unlawful disclosure
  • Unauthorized copying
  • Misuse
  • Cyberattack
  • Other unlawful processing

Security measures may include:

  • Access controls
  • Passwords and authentication
  • Encryption where appropriate
  • Secure databases
  • Role-based access
  • Physical security
  • Secure document storage
  • Staff confidentiality obligations
  • Backups
  • Cybersecurity controls
  • Secure disposal
  • Staff training
  • Periodic security reviews

Access to sensitive membership information shall be restricted according to official responsibility and legitimate need.

Section 14

Confidentiality

Every Party official, employee, volunteer, agent, consultant, contractor and service provider who has access to personal data shall maintain confidentiality and shall use such information only for authorized purposes.

Unauthorized access, copying, disclosure, sale, transfer, publication or misuse of personal data may constitute a disciplinary matter and may also constitute a breach of applicable law.

Section 15

Disclosure to Third Parties

Humanist shall not sell personal data.

Personal data may be disclosed to third parties only where legally permitted or required, including where disclosure is:

  • Required by law
  • Required by a competent public authority
  • Necessary for compliance with the Political Parties Act
  • Necessary for lawful ORPP functions
  • Necessary for legal proceedings
  • Necessary for service provision by an authorised data processor
  • Authorised by the data subject
  • Otherwise permitted under applicable data-protection law

Where processors are engaged, Humanist shall require appropriate contractual and security safeguards.

Section 16

Transfer of Data Outside Kenya

Humanist shall not transfer personal data outside Kenya unless the transfer is permitted under applicable Kenyan law and appropriate safeguards are in place.

Where required, the Party shall ensure that appropriate safeguards, contractual arrangements, adequacy requirements or valid consent are in place before transferring personal data outside Kenya.

Note: The Data Protection Act contains specific requirements governing transfers of personal data outside Kenya.

Section 17

Cookies and Website Technologies

Humanist may use cookies and similar technologies to:

  • Operate its website
  • Improve website functionality
  • Understand website usage
  • Maintain security
  • Remember preferences
  • Improve user experience

Where cookies involve personal data or require consent under applicable law, appropriate notice and consent mechanisms shall be provided.

The Party shall not use cookies to collect excessive personal information.

Section 18

Children's Data

Humanist shall exercise particular care when processing personal data relating to children.

Where processing children's data requires parental or guardian consent or other safeguards under applicable law, the Party shall implement the appropriate measures.

The Party shall not knowingly use children's personal information for political communication or targeted political purposes except where lawful, necessary and appropriately safeguarded.

Section 19

Political Communication and Direct Marketing

Humanist recognizes the distinction between legitimate political communication and direct marketing.

The Party shall ensure that electronic communications and political communications involving personal data are undertaken in accordance with applicable law.

Where consent is required, the Party shall provide an appropriate consent mechanism.

Individuals shall be provided with a reasonable means of opting out of communications where applicable.

Section 20

Automated Decision-Making and Profiling

Humanist shall not subject a data subject to a decision based solely on automated processing where such decision produces legal or similarly significant effects, except where permitted by law and subject to applicable safeguards.

Where profiling or automated decision-making is undertaken, the Party shall provide appropriate information and safeguards required by law.

Section 21

Data Breaches

Humanist shall maintain procedures for identifying, investigating, containing and responding to personal-data breaches.

Where a breach occurs, the Party shall:

  • Promptly assess the nature and extent of the breach
  • Contain and mitigate the breach
  • Document the incident
  • Investigate the cause
  • Take corrective measures
  • Notify the appropriate authority where legally required
  • Notify affected data subjects where required by law

The Party shall maintain an internal data-breach register and incident-response procedure.

Section 22

Rights of Data Subjects

Subject to applicable legal limitations, a data subject has rights including:

  1. The right to be informed about the processing of personal data
  2. The right of access to personal data
  3. The right to object to processing
  4. The right to correction of inaccurate or misleading data
  5. The right to deletion or erasure where legally applicable
  6. The right to data portability where applicable
  7. The right to restriction of processing where applicable
  8. The right to withdraw consent where processing is based on consent
  9. The right to lodge a complaint with the ODPC

ODPC Recognition: The ODPC expressly recognises these data-subject rights under the Kenyan data-protection framework.

Section 23

Right to Access Personal Data

A data subject may request confirmation as to whether Humanist holds personal data concerning them and, where applicable, request access to such information.

The Party shall respond within the timelines prescribed by applicable law.

Requests may be subject to reasonable verification of the identity of the requester to prevent unauthorised disclosure.

Section 24

Right to Correction

Where a member or other data subject believes that personal data held by Humanist is inaccurate, incomplete or misleading, they may request correction.

The Party shall take reasonable steps to verify and correct the information where the request is justified.

Section 25

Right to Object

A data subject may object to certain processing of their personal data where permitted by law.

Humanist shall assess the objection and determine whether the processing may lawfully continue.

Where the objection relates to direct marketing, the Party shall respect the objection where required by law.

Section 26

Right to Erasure

A data subject may request deletion of personal data where the law permits such deletion.

Important: The right to erasure is not absolute. Humanist may retain information where retention is required or permitted by law, including information necessary for:

  • Statutory compliance
  • Legal claims
  • Regulatory obligations
  • Legitimate archival purposes
  • Other lawful purposes
Section 27

Data Portability

Where applicable under Kenyan law, a data subject may request personal data in a structured, commonly used and machine-readable format and may request its transmission to another controller where the statutory conditions are satisfied.

Section 28

Withdrawal of Consent

Where processing is based on consent, the data subject may withdraw consent.

Withdrawal of consent shall not affect the lawfulness of processing undertaken before withdrawal.

Where withdrawal affects the Party's ability to provide a service or maintain a membership relationship, Humanist shall explain the consequences to the data subject.

Section 29

How to Exercise Your Rights

A data subject may submit a privacy request to Humanist through the Party's designated data-protection contact.

A request should, where reasonably possible, contain:

  • Full name
  • Contact details
  • Nature of the request
  • Relevant membership or reference number, where applicable
  • Identification sufficient to verify the requester
  • Any information reasonably necessary to process the request

The Party may request additional information where necessary to verify identity and protect against fraudulent requests.

Section 30

Complaints

Any person who believes that Humanist has unlawfully processed their personal data may first submit a complaint to the Party through its designated privacy contact.

The Party shall investigate and respond in accordance with its internal complaints procedure and applicable law.

A data subject retains the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) where permitted by law.

Section 31

Data Protection Impact Assessments

Where Humanist intends to undertake processing that is likely to result in a high risk to the rights and freedoms of individuals, the Party shall undertake an appropriate Data Protection Impact Assessment where required by law.

Particular attention shall be given to:

  • Political membership databases
  • Large-scale processing
  • Sensitive personal data
  • Biometric information
  • Surveillance technologies
  • Profiling
  • Automated decision-making
  • Large-scale digital recruitment
  • Significant changes to information systems
  • Other processing presenting substantial privacy risks
Section 32

Third-Party Service Providers

Where Humanist uses third parties for services such as:

  • Website hosting
  • Information technology
  • Cloud storage
  • Communications
  • Membership systems
  • Accounting
  • Auditing
  • Legal services
  • Printing
  • Event management
  • Other administrative functions

The Party shall undertake reasonable due diligence and shall require appropriate confidentiality, security and data-protection safeguards.

Section 33

Records Management

Humanist shall maintain appropriate records concerning:

  • Categories of personal data processed
  • Purposes of processing
  • Data subjects
  • Data recipients
  • Retention periods
  • Security measures
  • Consent where applicable
  • Data-processing agreements
  • Data breaches
  • Privacy requests
  • Other compliance matters required by law
Section 34

Accountability

Humanist shall adopt a privacy-by-design and privacy-by-default approach.

Privacy and data protection shall be incorporated into the design and implementation of:

  • Membership systems
  • Websites
  • Mobile applications
  • Recruitment platforms
  • Databases
  • Communication systems
  • Party research systems
  • Voter or supporter engagement systems
  • Other systems that process personal information

Party officials responsible for processing personal data shall receive appropriate data-protection training.

Section 35

Prohibited Uses of Personal Data

Party officials, members, agents and contractors shall not:

  • Sell membership information
  • Use membership information for personal commercial purposes
  • Disclose membership information to unauthorised persons
  • Copy membership databases without authority
  • Transfer membership information to unauthorised devices or platforms
  • Use personal data to intimidate or harass individuals
  • Manipulate membership records
  • Register a person without lawful authority or appropriate consent
  • Use another person's identity to recruit them
  • Disclose sensitive information for political retaliation
  • Otherwise misuse personal data
Section 36

Relationship with ORPP and Other Authorities

Humanist shall cooperate with the ORPP and other competent public authorities where required by law.

Such cooperation shall not remove the Party's responsibility to apply appropriate data-protection safeguards.

ORPP Access: The Party recognises that the ORPP membership register is subject to statutory access arrangements. ORPP states that members of the public may seek confirmation of their own membership status subject to the applicable legal framework.

Section 37

Publication of Information

Humanist may publish information about Party officials, candidates, spokespersons, activities and programmes where there is a lawful basis for doing so.

Before publication of photographs, videos, names, biographies or other personal information, the Party shall consider:

  • The purpose of publication
  • The individual's reasonable expectation of privacy
  • Whether consent is required
  • Whether publication is necessary and proportionate
  • Whether sensitive information is involved
  • Whether the publication could cause unjustified harm
Section 38

Social Media

Where Humanist operates social-media accounts, personal information received through such platforms shall be handled responsibly.

The Party shall not intentionally publish personal information of members, supporters or members of the public without a lawful basis.

Individuals should also understand that social-media platforms operate under their own privacy policies and terms.

Section 39

Data Protection Compliance

Humanist shall maintain appropriate evidence of compliance, including where applicable:

  • ODPC registration
  • Privacy policies and notices
  • Data-processing records
  • Consent records
  • Data-processing agreements
  • Security policies
  • Retention schedules
  • Data-breach procedures
  • Staff confidentiality undertakings
  • Training records
  • Data-subject request records
  • Data Protection Impact Assessments
  • Internal compliance reviews

ODPC Registration: The ODPC states that registration of data controllers and processors is a statutory compliance requirement for applicable entities processing personal data in Kenya.

Section 40

Changes to This Privacy Statement

Humanist may amend this Statement from time to time to reflect:

  • Changes in legislation
  • Regulatory requirements
  • ORPP requirements
  • ODPC guidance
  • Technological developments
  • Changes in Party operations
  • Improvements to privacy practices

The latest version shall be published through the Party's official communication channels.

Material changes shall be communicated to affected persons where required by law.

Section 41

Governing Law

This Privacy and Data Protection Statement shall be governed by the laws of the Republic of Kenya.

Nothing in this Statement shall be interpreted as limiting a right or protection granted to a data subject under the Constitution, the Data Protection Act or any other applicable law.

Section 42

Privacy Contact

For privacy, data-protection, access, correction, objection, deletion, consent or other data-related requests, please contact:

Humanist Party of Kenya

Data Protection / Privacy Office

Email: dataprotection@humanistpartykenya.co.ke

Telephone: +254 729 261 243

Postal Address: 17136-00100, Nairobi, Kenya

Physical Address: Kaka House - Right Wing, 6th Floor, Off Parkland Road, Westlands

Where the Party appoints a Data Protection Officer, the relevant DPO contact details shall be published here.

Section 43

Regulatory Contact

Data subjects may also contact the:

Office of the Data Protection Commissioner (ODPC)

Nairobi, Kenya

The ODPC is responsible for regulating the processing of personal data and protecting the privacy rights of individuals in Kenya.

Section 44

Declaration of Commitment

Humanist Party of Kenya is committed to protecting the dignity, privacy and personal information of every person whose data comes into its possession.

The Party shall process personal data responsibly, lawfully, fairly, transparently and securely and shall continually improve its privacy and information-security practices.

Approved by: National Executive Committee

Humanist Party of Kenya

Effective Date: 23 August 2026  |  Review Date: 23 August 2027

Document Status: Approved Institutional Privacy and Data Protection Statement