How the WHO Digital Health Strategy Should Govern Data, AI and Digital Public Infrastructure

By Raylenne Kambua |

As the World Health Organization (WHO) develops the Global Digital Health Strategy for 2028–2033, the Collaboration on International ICT Policy for East and Southern Africa (CIPESA) has submitted recommendations urging that the strategy be anchored on human rights, equity, and accountability, alongside technological innovation. 

Across Africa, Artificial Intelligence (AI), telemedicine, disease surveillance systems, and automated diagnostic systems are transforming healthcare delivery. However, CIPESA pointed out in the submission to the WHO Regional Office for Africa that technological innovation without proper governance can worsen exclusion, undermine privacy protections, and reinforce inequalities in healthcare delivery.

The submission comes at a time when key global and regional digital health governance frameworks are being reshaped. Last year, the World Health Assembly extended the Global Strategy on Digital Health 2020–2025, and simultaneously mandated a successor framework to be completed in 2027. 

Furthermore, global initiatives such as the World Summit on the Information Society (WSIS) and the Global Digital Compact emphasise that digital transformation must integrate the Sustainable Development Goals and ensure inclusive development.

At the continental level, the Africa Centres for Disease Control and Prevention (Africa CDC) has rolled out the Africa CDC Digital Transformation Strategy which alongside the  African Union (AU) Data Policy Framework advances interoperability, transparency, privacy, and the ethical deployment of digital systems in the health sector. However, CIPESA notes that despite these commitments, implementation gaps remain significant, particularly regarding health data governance, accountability, and protection against algorithmic harm.

CIPESA’s work on health data governance in Uganda, patient data privacy in Ghana, Rwanda, and Uganda, and analysis of Kenya’s Digital Health Act, point to the same reality. The rules governing who controls health data, who is included in digital health systems, and who is held accountable when data is mishandled are still weak across most of the continent.

“As countries embrace AI, digital public infrastructure, and data-driven healthcare systems, the real test will be whether these technologies strengthen confidence in public health systems or deepen concerns about exclusion, surveillance, and the misuse of personal data,” said CIPESA Executive Director Dr. Wairagala Wakabi.

He added: “Trustworthy digital health systems require transparent digital infrastructure, accountable AI systems, and strong data protection safeguards. Africa has the chance to shape a digital health governance model that is innovative, inclusive, and based on the public interest and human dignity.”

CIPESA’s Core Positions and Recommendations

Digital health offers significant potential to enhance Universal Health Coverage and strengthen health systems across Africa. However, without governance anchored in rights, equity, inclusion, and accountability, this promise will remain unfulfilled. It is against this backdrop that CIPESA submitted the following recommendations:

1. Digital Public Infrastructure (DPI)

Digital health infrastructure should be open, interoperable, transparent, and rights-respecting, with safeguards to prevent exclusion and misuse of shared systems.

    2. Health Data Governance

    Most African countries lack specific laws that govern health data. Countries should therefore establish clear legal frameworks governing health data, including informed and meaningful patient consent, limits on data sharing, independent oversight mechanisms, and enforceable accountability structures.

    3. Artificial Intelligence (AI)

    CIPESA warns that most AI systems used in healthcare are trained on non-African datasets, which increases the risk of inaccurate diagnoses and exclusion. The submission recommends that AI tools and systems should be tested and validated in Africa, and include mandatory “explainability” standards so that health professionals understand how the AI reaches conclusions, and safeguards against bias in clinical decision-making tools.

    4. Interoperability

    Many digital health tools are isolated across countries and institutions, meaning they can not share data with each other. In this light, CIPESA recommends the adoption of national interoperability standards, including the WHO SMART Guidelines, to ensure secure and efficient health data exchange. Also, all digital health vendors should adhere to interoperability standards and the utilisation of shared infrastructure.

    5. Equity and Inclusion

    The digital divide continues to expand in most African countries and limits access to digital health services. CIPESA recommends conducting “equity impact assessments” before launching new systems, continued availability of offline options, and supporting digital literacy initiatives.

    6. Stronger Governance

    CIPESA holds that technology fails without clear leadership and coordination between health and technology departments. Therefore, creating clear governance structures for accountability and embracing a multi-stakeholder approach in decision-making processes are vital for resilient health systems. Other recommendations are the publication of institutional AI and digital health use policies and mandatory human rights impact assessments for high-risk systems.

    7. Sustainable Financing

    Many digital health initiatives rely on short-term donor funding, resulting in countries being dependent and unable to scale such programmes. Additionally, gaps in workforce capacity constrain implementation. CIPESA urges governments to invest in domestic financing of digital health systems and training of health and technical personnel.

    In conclusion, CIPESA’s submission emphasises that while digital technologies offer significant opportunities to strengthen health systems and improve service delivery, without strong safeguards, digital health risks reproducing and scaling existing inequalities in new, technologically mediated forms. A rights-based, inclusive, and accountable approach is therefore essential to ensure that Africa’s digital health future is not only innovative, but also equitable and just.

    Read the full submission here.

    Outpaced by Its Own Ambition: Can Kenya Bridge Its AI Regulation  Gap?

    By Raylenne Kambua |

    The raw paradox at the heart of Kenya’s Artificial Intelligence (AI) moment is that the country is simultaneously sprinting ahead in AI adoption while grappling with a shrinking space for the very digital voices that AI empowers.

    According to the Digital Global Update Report, Kenya recorded the world’s highest usage rate of AI tools in 2025, with 42.1% of internet users aged 16 and above reporting active use of AI-powered technologies. This level of usage indicates that AI is increasingly being woven into the daily life of Kenyans.

    However, the Navigating the Implications of AI on Digital Democracy in Kenya report by the Collaboration on International ICT Policy for East and Southern Africa (CIPESA) highlights that while AI empowers citizens, it also enables unprecedented surveillance and manipulation.

    A Nation Leading the Way in AI Adoption

    Kenya has made significant investments in digital services, innovation hubs, and connectivity under the National Digital Master Plan 2022–2032.

    These developments are also transforming how citizens interact with the government. Tools such as the Office of the Data Protection Commissioner’s Linda Data chatbot and platforms such as Sauti ya Bajeti have expanded access to rights information and budget tracking.

    Yet, even as AI delivered clear benefits, it also revealed its dual nature, most visibly during the 2024 #RejectFinanceBill protests, during which Gen Zs mobilised through AI-generated infographics, satire, and short-form videos. At the height of the protests on June 25, a nationwide internet disruption was enforced despite assurances from the Communications Authority. The disruption was confirmed by network monitors like Cloudflare and NetBlocks, exposing the fragility of internet freedom in Kenya.

    Civil society condemned the internet shutdown as a violation of rights, while telecoms Safaricom and Airtel attributed it to outages in their undersea cable. In the aftermath, reports of abductions and enforced disappearances of digital activists escalated, with the Kenya National Commission on Human Rights documenting at least 82 cases between June and December 2024.

    Kenya’s AI Policy Landscape

    The launch of the Kenya National AI Strategy 2025–2030 in March 2025 signalled the country’s ambition to position itself as Africa’s leading AI innovation hub. The strategy prioritises governance, ethics, investment, digital infrastructure, data ecosystem development, and support for AI research and innovation.

    Kenya has also strengthened its international profile through participation in programmes such as the United Nations High-Level Advisory Board on AI, joining the International Network of AI Safety Institutes, and assuming leadership in the World Summit on the Information Society (WSIS+20).

    At the national level, initiatives such as Digital Platforms Kenya (DigiKen) and the Kenya Bureau of Standards’ draft AI Code of Practice reflect growing momentum toward operationalising AI governance and skills building. The government is also developing an AI and Emerging Technologies Policy and a Data Governance Policy, both of which are expected to be in place by July 2026.

    However, the gap between ambition and readiness remains wide. Kenya ranks 93rd in the 2025 Government AI Readiness Index, due to persistent weaknesses in infrastructure, implementation, and institutional capacity.

    Moreover, Kenya’s legal framework for AI remains fragmented and incomplete. Currently, there is no standalone AI law in force, but a controversial Artificial Intelligence Bill, 2026, that has raised significant concerns about over-regulation and censorship  is under discussion. Additionally regulation is based on broader laws such as the Data Protection Act 2019 and the Computer Misuse and Cybercrimes Act 2018, which were not designed to address AI-specific risks such as deepfakes, automated decision-making, algorithmic discrimination, or synthetic disinformation.

    As highlighted in the CIPESA report, critical gaps remain in the use of AI. These include the absence of mandatory algorithmic impact assessments, weak safeguards against AI-driven surveillance such as facial recognition, and scant measures to address AI-generated electoral misinformation. Furthermore, regulatory authorities lack sufficient capabilities to audit and monitor sophisticated AI systems, and there are no clear licensing or accountability frameworks for AI creators and deployers.

    “Without deliberate, inclusive, and rights-centred governance, AI risks entrenching authoritarianism and exacerbating inequalities.” (Navigating the Implications of AI on Digital Democracy in Kenya, 2025)

    The Way Ahead: AI Governance Focused on Human Rights

    The CIPESA report outlines a human rights–centred approach to AI governance that is built on the following key principles:

    1. Life-Centred and Human-Centred Design and Accountability: AI should support and not replace human judgment, with strong oversight to ensure transparency and accountability.
    2. Equity and Fairness: Design AI to prevent bias and expand inclusive access, especially for underrepresented groups.
    3. Transparency and Trust: Ensure AI systems are explainable, well-documented, and open to public scrutiny and challenge.
    4. Safety, Security and Resilience: Build resilient systems with ongoing risk assessments and strong protections against misuse.
    5. International Collaboration and Ethical AI Development: Advance ethical AI through international collaboration while upholding constitutional values and human oversight.
    6. Environmental sustainability: Align AI development with climate resilience and sustainable resource use.
    7. Inclusive Participation and Cultural Relevance: Reflect local diversity and involve marginalised communities in AI design.
    8. Robust Governance and Adaptive Regulation: Maintain flexible, responsive regulation that keeps pace with technological change.

    The report calls for a coordinated, multi-stakeholder approach to AI governance. It recommends that:

    • The government should enact a comprehensive AI law aligned with constitutional and international human rights standards, establish a legally mandated National AI Advisory Council with inclusive representation and strong enforcement powers.  It should also introduce clear prohibitions on high-risk practices such as real-time biometric surveillance without judicial oversight.
    • Civil society and the media should strengthen public awareness, promote accountability, and counter AI-driven disinformation.
    • Private sector actors should uphold transparency, fairness, and ethical standards across AI systems, including fair labour practices. Labour protections must be guaranteed for gig workers and data annotators within the AI value chain.
    • Academia and research institutions should continue generating evidence that can guide context-specific policy and regulation.
    • Across all stakeholders, digital literacy must be expanded, especially in underserved and rural communities, so that citizens can understand and challenge AI systems that affect them.

    With the ongoing legislative processes on AI, this is a pivotal time for Kenya, as it has the momentum and the attention of the world. But momentum without action will not work. The country cannot afford slow, fragmented debates while technology is fast progressing. Additionally, Kenya must strike a careful balance between regulation and innovation, as overly restrictive rules could limit access, slow local innovation, and lock the country out of AI’s economic and social benefits. The goal should be a flexible, forward-looking framework that protects rights while still enabling growth and opportunity.

    Read the full report, Navigating the Implications of AI on Digital Democracy in Kenya.

    African Governments are Using “Smart City” Systems to Monitor Dissent and Consolidate State Control

    By CIVICUS |

    CIVICUS discusses the spread of AI-powered surveillance in Africa with Wairagala Wakabi, executive director of the Collaboration on International ICT Policy for East and Southern Africa (CIPESA) and co-editor of Smart City Surveillance in Africa: Mapping Chinese AI Surveillance Across 11 Countries, the latest report by the African Digital Rights Network (ADRN) and the Institute of Development Studies (IDS).
    At least 11 African governments have spent over US$2 billion on Chinese-built surveillance infrastructure that uses AI-powered cameras, biometric data collection and facial recognition to monitor public spaces. Marketed as ‘smart city’ solutions to reduce crime and manage urban growth, these systems have been rolled out with little regulation and no independent evidence of their effectiveness. This technology is instead being used to monitor activists, track protesters and silence dissent, with a chilling effect on freedoms of assembly and expression.

    How widespread is AI-powered surveillance in Africa?

    Under the guise of reducing crime and fighting terrorism, at least 11 governments have invested over US$2 billion in AI-powered ‘smart city’ surveillance infrastructure: Algeria, Egypt, Kenya, Mauritius, Mozambique, Nigeria, Rwanda, Senegal, Uganda, Zambia and Zimbabwe.

    Governments are installing thousands of CCTV cameras linked to central command centres, paired with tools such as automatic number-plate recognition, biometric ID systems and facial recognition to track people and vehicles. The largest known investments are in Nigeria (over US$470 million), Mauritius (US$456 million) and Kenya (US$219 million), though the real total is likely much higher, since surveillance spending is often secret and the report covers only 11 of Africa’s 55 countries.

    Despite being presented as tools for crime prevention, counter-terrorism, modernisation and urban management, these are not targeted security measures. They represent a broader shift toward continuous, population-level monitoring of public spaces, rolled out over the past five to ten years almost always without clear legal limits or public debate.

    Are these systems achieving their stated purpose?

    No, there is no compelling evidence that they have in any of the countries studied. Instead, the data points to a pattern of use that raises serious human rights concerns.

    In Uganda and Zimbabwe, AI-powered surveillance including facial recognition is being used to suppress dissent rather than ensure public safety. Activists, critics of the government, opposition leaders and protesters are identified and monitored through this system, even after protests have ended. In Mozambique, smart CCTV systems have reportedly been installed in areas of strong political opposition, suggesting targeted rather than neutral surveillance.

    In Senegal and Zambia, countries with relatively low terrorism threats, governments have still invested heavily, which calls into question the stated security rationale.

    Across the countries studied, the scale of surveillance far exceeds any actual or perceived security threat, and the infrastructure is consistently being used to monitor dissent and consolidate state control rather than address genuine public safety needs.

    Who’s supplying this technology?

    While firms from Israel, South Korea and the USA supply surveillance technologies, Chinese companies are the primary suppliers and financiers. They typically offer end-to-end ‘smart city’ packages that include cameras, software platforms, data analytics systems, training and ongoing technical support. Many projects are backed by loans from Chinese state-linked banks, which makes them financially accessible in the short term but creates long-term dependencies on external vendors for maintenance, system management and upgrades.

    This model undermines transparency. Procurement processes are opaque and civil society, the public and oversight institutions including parliaments rarely have information about how these systems operate, how data is stored or who has access to it. That lack of accountability is what makes abuse not just possible, but hard to detect or challenge.

    What impact is this having on civic space?

    This large-scale surveillance of public spaces is not legal, necessary or proportionate to the legitimate aim of providing security. Recording, analysing and retaining facial images of people in public without their consent interferes with their right to privacy and, over time, their willingness to move, assemble and speak freely.

    The most immediate consequence is a chilling effect, particularly where civic space is already restricted. Knowing they can be identified and tracked, activists and journalists are less willing to attend protests for fear of later arrest or reprisals, and end up self-censoring. Civil society organisations also report heightened anxiety about the risks for their members and partners.

    What should governments and civil society do?

    None of the 11 countries studied have a legal framework capable of balancing the state’s security needs with its commitments to protect fundamental human rights. That must change. Governments must adopt clear regulations on surveillance, including restrictions on facial recognition and other AI tools, require independent human rights impact assessments before introducing new systems, make procurement and deployment processes transparent and establish strong oversight mechanisms, including judicial and parliamentary scrutiny, to prevent abuse.

    Civil society should continue documenting abuses, raising public awareness and advocating for accountability, while also supporting affected people and communities through digital security support and legal assistance.

    Technology-exporting states and donors must enforce stricter controls and safeguards on the export and financing of these tools, support rights-based approaches to digital governance and help fund independent monitoring and advocacy across Africa.

    Without urgent action, these systems will continue to expand, and the rights of people across Africa will continue to shrink.

    CIVICUS interviews a wide range of civil society activists, experts and leaders to gather diverse perspectives on civil society action and current issues for publication on its CIVICUS Lens platform. The views expressed in interviews are the interviewees’ and do not necessarily reflect those of CIVICUS. Publication does not imply endorsement of interviewees or the organisations they represent.

    This article was first published on the Website of CIVICUS LENS on April 07, 2026

    India AI Impact Summit: A Missed Opportunity for Africa’s Voice in Global AI Governance

    By Lillian Nalwoga |

    The India AI Impact Summit, held on February 16-21, 2026, was themed “Sarvajan Hitaya, Sarvajan Sukhaya” (Welfare for all, Happiness for all). It was expected to be a platform for South-to-South cooperation. However, despite Africa’s growing AI ambitions and strategic participation in preparatory working groups, the summit exposed a stark representation gap, raising concerns about Africa’s ability to influence the future of global AI governance.

    Artificial Intelligence (AI) presents a transformative opportunity for Africa, with projections indicating it could contribute up to USD 1 trillion to the continent’s Gross Domestic Product (GDP) by 2035. This significant potential underscores Africa’s growing ambition to harness AI for inclusive growth while positioning itself as a key player in global AI governance.

    Many African countries are engaging with AI proactively, seeking to harness its benefits across various sectors. Countries such as Rwanda, Nigeria, Kenya, and Egypt have demonstrated strategic foresight in their AI initiatives. Rwanda, for instance, co-chaired the human-capital working group at the Summit, in line with its national AI strategy to become a global hub for AI research and innovation. Nigeria, as Africa’s largest economy, is focused on utilising AI for inclusive growth, while Kenya and Egypt are contributing to broader debates on AI ethics and digital infrastructure.

    The African Union’s Continental AI Strategy, adopted in July 2024, further solidifies this commitment. The strategy emphasises an Africa-centric, development-focused approach to AI, promoting ethical, responsible, and equitable practices. Key pillars of this strategy include data sovereignty, ethical frameworks, and inclusive governance.

    Across the continent, initiatives are emerging, such as South Africa’s establishment of AI institutes and Ghana’s investments in AI for agriculture and healthcare projects. These efforts highlight a continent actively pursuing AI integration to address its unique challenges and opportunities.

    Despite the summit’s promise of inclusivity and South-to-South cooperation, African voices were largely absent from high-level sessions and critical decision-making forums. Only two African heads of state, from Mauritius and Seychelles, and ministers from Rwanda, Kenya, Egypt and Togo, attended  the global summit. This limited presence stood in stark contrast to the dominant participation of tech giants and diplomatic delegations from the Global North, undermining the summit’s stated goal of elevating Global South perspectives.

    Despite strong enthusiasm from leading African AI startups, who showcased their innovative solutions,  the lukewarm African endorsement of the summit’s Impact Document exposed a clear disconnect. Only 11 African countries out of the 92 countries that attended endorsed the declaration that calls for “international cooperation and multistakeholder engagement.” This limited endorsement suggests either inadequate consultation with African stakeholders or a mismatch between the summit agenda and Africa’s priorities.

    Notably, African civil society voices, academic experts, and private-sector leaders – those most intimately familiar with the continent’s challenges and opportunities – were largely sidelined at an event meant to champion South-South cooperation. Their absence highlights a significant gap between the summit’s stated commitment to inclusivity and the reality of who was heard.

    The under-representation of African voices at global digital governance forums like the India AI Impact Summit has significant implications. As AI becomes increasingly central to economic competitiveness and social development, Africa’s marginalisation could impede its ability to fully harness AI’s potential while protecting its citizens’ interests.

    African initiatives, such as Nigeria’s push for data sovereignty and Egypt’s integration of AI into sustainable development, deserve a prominent seat at the global table. Without more equitable representation, Africa’s vision for an ethical and inclusive AI future risks being overshadowed by agendas primarily driven by the Global North.

    Africa still faces significant AI governance challenges, including incomplete digital policy frameworks, limited financial resources for consistent participation in global policy meetings, and weak coordination among governments, companies, and civil society. However, these constraints should not prevent it from equal representation in global digital governance forums.

    These participation challenges are not unique to Africa: members of the Global South Alliance have similarly called for more meaningful and diverse engagement in global digital governance, in their letter to the India AI Summit Organising Committee. Initiatives such as the Multistakeholder Approach to Participation to AI Governance have also stressed the need to ensure that global AI conversations are informed by the “voices and experiences of those who are most impacted by the development and diffusion of AI.”

    Africa has enormous AI potential, a clear strategic vision, and growing initiatives to harness AI for sustainable development. The representation gap evident at the India AI Summit highlights the urgent need to ensure that voices from the Global South, including Africa, are not only heard but are influential in shaping global AI governance.

    Strengthening the capacity of national regulators and policymakers to craft progressive AI policies and engage effectively in global AI negotiations is essential. Leveraging continental frameworks such as the African Union AI Strategy can help shape common negotiating positions. At the same time, empowering civil society to provide evidence-based, rights-respecting input to national and global AI frameworks will help ensure more citizen-centered policymaking and more equitable participation in national, regional, and international policy processes. As the world prepares for the upcoming UN Global Dialogue on AI Governance in July and the Global AI Summit 2027 in Geneva, the first annual report of the 40-member UN Independent International Scientific Panel on AI that is due in July 2026 will be a crucial test of whether African priorities can be adequately reflected in global AI governance processes.

    Health Apps Project International Conference

    Event |

    Date: 18-19 February, 2026

    Location: Johannesburg, South Africa

    The University of the Witwatersrand’s (Wits) School of Law, in partnership with Warwick
    University’s Law School and the University of Nairobi’s business School have jointly organized
    this final Health Apps conference in Johannesburg to showcase the project’s major scientific
    outputs and explore with stakeholders how harmonization can be achieved across the
    Subregion to improve regulations and guidelines for Health Apps.