Protecting Refugee Data in Uganda’s Humanitarian Response: Why It Matters More Than Ever

Protecting Refugee Data in Uganda’s Humanitarian Response: Why It Matters More Than Ever

By Rebecca Nanono

Uganda stands out globally as one of the most generous refugee-hosting nations. With over 1.5 million refugees, mostly from South Sudan, the Democratic Republic of Congo, and Burundi, Uganda's open-door policy is often praised as progressive and inclusive. Yet, as digital systems increasingly underpin humanitarian operations, from biometric registration to digital cash transfers, new risks to refugee privacy and protection are emerging. One of the most pressing yet overlooked challenges is the protection of refugee data.

Why Refugee Data Protection Matters

Refugee data, such as biometric information, personal histories, health records, and legal status, is sensitive and can expose individuals to serious risks if mishandled. In contexts where people have fled persecution, conflict, or political oppression, even a small data leak can lead to severe consequences, including targeting by hostile actors, discrimination, or re-traumatization. Moreover, the power imbalance between refugees and humanitarian actors often means refugees are unaware of how their data is collected, stored, and used, or whether they can refuse consent without jeopardizing access to services.

Uganda has made strides in digital transformation in humanitarian response. But the legal and ethical frameworks governing data protection have not kept pace. The Data Protection and Privacy Act (DPPA) of 2019 provides a useful foundation, but it lacks specific provisions for displaced populations. As a result, many humanitarian actors operate in a grey zone, where well-intentioned data practices may still violate refugees’ rights.

The Current Landscape: Gaps and Challenges

Despite the proliferation of digital tools like the Biometric Identity Management System (BIMS) and various mobile data collection platforms, Uganda's refugee response still faces several data governance challenges:

• Lack of Refugee-Specific Guidelines. Most agencies rely on general data protection laws, which may not be well-suited to the complexities of displacement and humanitarian need.
• Low Refugee Awareness. Many refugees do not understand their digital rights or the implications of data sharing.
• Weak Oversight and Accountability. There is no dedicated independent body tasked with ensuring ethical data handling specific to refugee operations.
• Fragmented Data Practices. Multiple agencies and actors collect data without standardized agreements, raising risks of duplication, misuse, or breaches.

A Call for Action: Protecting People, Not Just Information

Protecting refugee data is not just a technical or legal issue, it’s a matter of human dignity and safety. As Uganda continues to innovate in digital humanitarianism, stakeholders must ensure that data protection is embedded at every level of response. This includes:

1. Developing a Refugee Data Protection Protocol. A specialized, government-endorsed framework that aligns with humanitarian principles and Uganda’s legal obligations.
2. Training Humanitarian Workers. Frontline staff should be well-versed in ethical data handling, consent processes, and data security.
3. Investing in Digital Literacy. Refugees must be empowered to understand and exercise their data rights through accessible education materials and community engagement.
4. Establishing Independent Oversight. A monitoring body, possibly within the Personal Data Protection Office, should audit practices and offer refugees a channel to report violations.
5. Formalizing Data Sharing Agreements. Agencies must operate under transparent, legally binding agreements that uphold privacy and accountability.

Final remarks

In an age where data is power, refugee protection must extend beyond physical safety to include digital safety. Uganda’s commitment to refugee welfare is admirable, but true protection requires safeguarding not only where refugees live, but how their identities and experiences are stored, shared, and remembered. Refugees, like all people, deserve control over their information and the dignity that comes with privacy. It’s time we put their digital rights at the heart of humanitarian response.