Ghana Association Of Privacy Professionals (GAPP) Calls For Transparency And Compliance In Management Of Ghana’s Health Data Systems

The Ghana Association of Privacy Professionals (GAPP) has noted with grave concern recent reports suggesting that the health data of Ghanaians collected through systems deployed under the auspices of the Ministry of Health (MoH) and the Ghana Health Service (GHS) may currently be under the effective control of a private company.

As a professional body committed to advancing data protection, privacy, and responsible data governance in Ghana, GAPP emphasizes that health data constitute sensitive personal

information under the Data Protection Act, 2012 (Act 843), and must be processed strictly in

line with the law.

GAPP reaffirms that the Government of Ghana, through the MoH and GHS, remains the

rightful data controller for all national health information systems. Any arrangement that grants operational or decision-making control over citizens’ health data to a third party without a clear legal basis, oversight, or safeguards raises serious compliance, sovereignty, and ethical concerns.

In view of this, GAPP:

1. Calls on the Ministry of Health and the Ghana Health Service to provide an official

clarification on the ownership, management, and governance of the health data systems

currently in use.

2. Urges the Data Protection Commission (DPC) to launch an immediate inquiry into the

matter to ensure that the processing of health data complies fully with Act 843 and

international best practices.

3. Recommends that the MoH and GHS conduct a comprehensive Data Protection Impact

Assessment (DPIA) on all national health information systems and review existing data

processing agreements to ensure compliance with Ghana’s data protection laws.

4. Encourages that all national health data be stored securely within Ghana’s jurisdiction,

with robust access controls and accountability mechanisms in place to safeguard data

sovereignty.

GAPP remains committed to working collaboratively with the Data Protection Commission, the Ministry of Health, and all relevant stakeholders to strengthen data protection practices in Ghana’s health sector.

Ultimately, Ghanaians’ health data belong to the people, and its stewardship must reflect the

highest standards of transparency, accountability, and respect for privacy.

Signed:

Ghana Association of Privacy Professionals (GAPP)