Establishes the lawful bases for processing, data-subject rights and the registration regime with the Data Protection Commission.
Data Protection Act, 2012 and the Do-Not-Disturb register: lawful basis for transactional and commercial delivery in Ghana
The Data Protection Commission enforces the Data Protection Act, 2012 (Act 843), which governs the processing of personal data of Ghanaian data subjects. The NCA additionally maintains a Do-Not-Disturb (DND) register that lets subscribers opt out of unsolicited commercial calls and SMS. 4notify records the lawful basis at envelope level and screens consent at the API edge on every dispatch.
Whereas, in exercise of the powers conferred by section 56 of the Data Protection Act, 2012 (Act 843) and the Do-Not-Disturb directive of the National Communications Authority, this Proclamation is issued concerning the management of consent in electronic delivery.
Registration of data controllers, mandatory breach notification and the Commissioner's enforcement powers.
Establishes the DND register and the duty of every messaging provider to screen against it.
Lawful basis stamped per envelope
Each envelope carries one of the Act 843 lawful bases (consent, contract, legal duty, legitimate interest); the bound basis is fixed in the template register.
Commercial-consent screening
On commercial messages, consent is screened at envelope level; dispatches without permission are blocked at the API edge. The NCA DND list is screened in parallel.
30-day right-to-erasure
Erasure requests propagate inside 24 hours across 4notify; the suppression list is pushed to MTN, Telecel and AT and to the email gateway.
Incident webhook
Any envelope-level event raises a webhook to the data controller within 1 hour, supporting the breach-notification duty under Act 843.
json
{
"event": "dispatch.consent_envelope",
"controller_id": "GH-CTRL-DPC-00481923",
"lawful_basis": "consent",
"consent": {
"register": "DPC-2026-001234",
"consent_date": "2025-09-14",
"unsubscribe_link_present": true
},
"dnd_screened": true,
"dispatch": { "channel": "email", "template": "promo_v2" },
"suppression_check": "passed"
}Dear customer, From today your marketing permission is revoked. You will no longer receive promotional emails, but you will still receive transactional notices (order confirmations, delivery alerts). To exercise your other rights under the Data Protection Act, 2012 (Act 843): [email protected]
- Data Protection Commission registration current
- Data controller configured at envelope level
- Consent retained for every commercial dispatch
- NCA Do-Not-Disturb register screened on every send
4notify is the only A2P provider that pins the Act 843 lawful basis on every envelope, propagates erasure across MTN, Telecel and AT within 24 hours and raises a Data Protection Commission incident webhook on every envelope event.
Does consent apply to SMS too?
Yes — Act 843 covers any commercial communication that touches personal data, including SMS, email and instant messaging. Each route requires a valid lawful basis.
What if the controller has not registered with the Data Protection Commission?
4notify blocks commercial dispatch at the API edge until the controller registration is verified. Transactional dispatch on a contractual basis remains available.
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