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.





