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All these changes affect payroll in the following ways: Payroll Systems as Data Controllers Payroll functions collect and process a wide range of personal data: salaries, bank account details, national identification numbers, tax codes, and sometimes health or disability information used for benefits calculations. Under the data protection frameworks being tightened across Africa, this makes payroll departments data controllers in their own right, subject to registration, compliance audits, and regulatory scrutiny. Practically, this means payroll teams need to ensure that: Employee consent exists for every category of data processed
Third-party payroll vendors are bound by data processor agreements Data is not kept longer than necessary after an employee leaves Breach Notification Obligations and Payroll Data Payroll systems are high-value targets for cybercriminals precisely because they hold financial and identity data. Several countries now impose strict breach notification timelines: Egypt’s executive regulation requires notification within 72 hours of a breach. South Africa’s amendments under POPIA similarly impose tight timelines. Criminal Liability for Those Managing Payroll Data Perhaps the most significant shift is the move from administrative penalties to personal criminal liability. In Uganda, two individuals were criminally convicted for data protection offences in 2025 1 . In South Africa, an employee received an eight-year prison sentence for a data-related offence. 2 For payroll managers and HR directors, this is a material risk. If a payroll administrator knowingly shares employee salary data with
Under the data protection frameworks being tightened across Africa, this makes payroll departments data controllers in their own right, subject to registration, compliance audits, and regulatory scrutiny.
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GLOBAL PAYROLL MAGAZINE ISSUE 22
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