Salome Achieng first noticed her face on a billboard along Ngong Road in early March. She had posed for a photograph two years earlier for a Mukuru kwa Njenga community health outreach run by a local NGO. The billboard, advertising a mobile money product she had never heard of, used the same image. Nobody had called. Nobody had paid. Nobody had asked.
Her experience is far from isolated. Across Nairobi's informal settlements — from Mathare to Kawangware to Korogocho — residents are describing a pattern of photographs taken during government programmes, NGO interventions and tech platform pilots being repurposed, sold or reused in contexts they never authorised. The issue has sharpened in 2026 as the Ruto administration's Affordable Housing Programme and ongoing informal settlement upgrading works have brought dozens of documentation teams into densely populated neighbourhoods, cameras in hand.
A city full of cameras, a community short on contracts
The scale of the problem is hard to pin down precisely, but the digital footprint is visible. A review of stock image platforms in June found dozens of photographs tagged with Nairobi neighbourhood names — Kibera, Eastleigh, Dandora — uploaded without identifiable attribution to the original subjects. Reverse image searches by community paralegals working with the Nairobi-based Haki Yetu Organisation have identified at least 34 cases since January 2026 where images of residents appeared on materials for programmes or commercial products they had no connection to.
The Kenya National Commission on Human Rights published guidelines on data and image consent as part of its broader 2024 digital rights framework, but enforcement remains thin on the ground. Under Kenya's Data Protection Act of 2019, personal data — which regulators have confirmed includes photographs of identifiable individuals — cannot be processed without informed consent. Penalties for violations run up to five million shillings or one percent of annual turnover, whichever is higher. Few affected residents know either figure exists.
At the Mukuru Integrated Development Programme office on Haile Selassie Avenue, paralegals say residents arrive weekly with printouts from Facebook, WhatsApp forwards or physical flyers showing their faces on materials ranging from political campaign posters to health ministry bulletins. Most do not know where to file a complaint. The Office of the Data Protection Commissioner, which sits under the State Department for ICT, received 1,140 complaints in the financial year ending June 2025, according to its annual report — but the commissioner's office has not publicly broken down how many related specifically to image misuse.
What residents want, and what the law allows
The demands coming from affected communities are specific. Several residents spoken to in Kibera's Laini Saba area over the past two weeks said they want retroactive written records of consent forms signed during government-linked surveys, including the 2022 Kenya Population and Housing Census and subsequent settlement mapping exercises. They also want to know which third parties received those images. Under the Data Protection Act, data subjects have the right to access that information — but exercising the right requires filing a formal request, a process most residents say they were never told about.
Local advocacy organisations including Pollicy East Africa and the Kenya ICT Action Network have pushed for plain-language consent processes as a minimum standard for any programme operating in informal settlements. Neither government ministries nor major NGOs have issued public responses to the specific concerns raised this year.
For residents, the practical path forward involves three steps: documenting the unauthorised use with screenshots or photographs, filing a complaint directly with the Office of the Data Protection Commissioner through its online portal at odpc.go.ke, and seeking legal aid through organisations like Kituo cha Sheria on Muranga Road, which handles digital rights cases on a pro bono basis. The commissioner's office has a 21-day initial response window under the act.
Achieng says she filed her complaint in April. She is still waiting. The billboard, she says, came down in May — but she has no idea whether that was coincidence or consequence.