Data Protection Regimes in Africa: too far from the European 'adequacy' standard?

In 2010, the Research Centre on IT and Law, University of Namur, Belgium, also known by its French acronym as the CRID, undertook evaluation of data protection legislation in the four African jurisdictions: Burkina Faso, Mauritius, Tunisia, and Morocco. The CRID carried out the evaluation under a consultancy agreement with the European Union. None of these jurisdictions passed the ‘adequacy’ test of the European Data Protection Directive 95/46/EC. In this article, I discuss the African data protection regime in the context of the CRID's reports and assess the implications of such findings to the future development of data privacy law in Africa.