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exist, the transfer itself is a violation, regardless of how routine the payroll processing might seem. The rapid expansion of data protection laws across Africa reinforces that payroll is not merely an administrative function. It is a critical data governance responsibility. Payroll systems hold highly sensitive data, making them prime targets for misuse and cyber threats. As regulators tighten breach notification timelines, strengthen enforcement, and introduce stricter cross-border data rules, organisations must ensure payroll processes are fully aligned with evolving data protection and compliance frameworks across the continent. Main source: The Year of the Teeth: Data Protection in Africa Roundup , 2025, Projections for 2026 by Digital Policy Alert in collaboration with Tech Hive Advisory. 1 DPO Secures First Criminal Conviction Under the Data Protection and Privacy Act 2 Landmark conviction under the Cybercrimes Act 3 Kenyan court suspends ‘landmark’ US health aid deal over data privacy concerns
an unauthorised third party, that individual could face personal prosecution. The same applies to a finance manager who ignores known vulnerabilities in a payroll system, and a breach subsequently occurs. Third-Party Payroll Providers and Cross- Border Data Transfers Egypt now requires specific regulatory licences for cross-border data processing. Kenya’s courts suspended a major data-sharing agreement with the United States on the grounds that it lacked adequate safeguards. 3 Nigeria is considering data localisation requirements for certain categories of personal data. For payroll, this means that an organisation in Nigeria using a payroll platform hosted in Europe, or a Kenyan business using a South African payroll bureau, may need to ensure that a lawful transfer mechanism is in place, whether that is a: Data processing agreement Regulatory authorisation Alignment with an adequacy framework Where those mechanisms do not
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GLOBAL PAYROLL MAGAZINE ISSUE 22
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