ProductsData PrivacyMaker-Checker Approvals
Kenya DPA 2019 - s.25 - Accountability & Technical Measures

Four-eyes on every data action - without the bottleneck

Enforce four-eyes approval on sensitive data processing actions. Per-action opt-out, delegated approval chains, escalation paths, and an immutable audit trail - governance without grinding operations to a halt.

Why this matters

Built for your compliance outcomes

Four-eyes enforcement

No single person can act alone

  • Configurable per action type
  • Approval required before execution
  • Reject with mandatory reason
  • Re-submission workflow on rejection

Per-action opt-out

Governance without grinding ops

  • Enable only where risk justifies
  • Exclude routine low-risk actions
  • Risk-based configuration by role
  • Audited single-owner bypass

Risk-based approval policies

Right scrutiny on the right actions

  • Policies by action type and risk
  • Pending approvals queue with badge
  • Approval SLA with escalation
  • Rejected items return with notes

Immutable audit trail

Every action, logged forever

  • Who made the request
  • Who approved or rejected
  • Timestamp and IP logged
  • Cannot be altered or deleted

Features

Everything you need, nothing you don't

Four-Eyes Enforcement

Configurable approval requirement per action type. No action executes without the required approver sign-off.

Action Configuration

Enable maker-checker per action type. Exclude low-risk routine actions. Risk-based opt-in rather than blanket requirement.

Approval Policies

Approval requirements configured per action type and risk. Pending approvals queue with badge counts. Rejections return to the submitter with notes.

Approval SLAs

Set time limits on approvals. Automatic escalation to next level if approval SLA is missed. No action left pending indefinitely.

Immutable Audit Log

Every maker, checker, approval, rejection, and override logged immutably. Full action history for ODPC inspection.

Single-Owner Mode

Sole-operator organisations proceed with an audited bypass note. Once a second member joins, four-eyes enforcement applies automatically.

DPA alignment

Every feature maps to a DPA section

Dira is built from the Act, not retrofitted to it. Here's exactly how each capability addresses your Kenya DPA 2019 obligations.

Product FeatureDPA 2019 SectionWhat it fulfils
Four-eyes enforcements.25Implements technical and organisational measure demonstrating accountability for processing decisions
Immutable audit trails.25(1)(e)Maintains documented record of processing decisions and their authorisation chain
Access controlss.41Ensures appropriate technical controls restrict who can initiate and who can approve sensitive processing actions
Approval chainss.25Demonstrates that processing decisions go through appropriate governance before execution
Emergency override loggings.25Documents exception circumstances with enhanced audit evidence for accountability
Rejection workflows.25Captures and records instances where processing actions were reviewed and refused

How it works

Step-by-step workflow

01

Configure action types

Choose which actions require maker-checker. Enable for high-risk actions: bulk erasure, consent withdrawal overrides, sensitive data exports.

02

Set approval chains

Define who can approve each action type. Configure single or multi-level chains. Set up delegation rules for absences.

03

Enable and communicate

Activate maker-checker. Notify teams of actions that now require approval. Dira generates a summary of all affected workflows.

04

Monitor and refine

Review approval metrics - approval times, rejection rates, bottlenecks. Adjust configuration to balance governance and operational speed.

FAQ

Common questions

What types of actions should require maker-checker?
High-risk actions warranting four-eyes review include: bulk data deletion, exports of sensitive data categories, consent withdrawal overrides, ROPA deletions, breach record amendments, and privileged access grants. Dira provides a recommended action configuration based on DPA risk level.
Won't maker-checker slow everything down?
Not with Dira's per-action opt-in model. You enable maker-checker only where the risk justifies it. Routine low-risk actions continue unimpeded. Approval SLAs ensure approvers respond quickly. The result is governance where it matters without operational drag.
What if my organisation has only one user?
A single-owner organisation can proceed without a second reviewer - each governed action is recorded with an audited bypass note. The moment another active member joins your workspace, four-eyes enforcement applies automatically and a different user must review every governed action.
Can I configure approvals differently per action type?
Yes. Approval requirements are set per action type, so high-risk actions like bulk erasure or sensitive data exports get mandatory review while routine work flows freely. The reviewer must always be a different user from the submitter - that rule is enforced server-side and cannot be switched off.

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