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Pan-African Malabo Convention baseline

Decision support, not legal advice

The africa_malabo_baseline profile is a conservative technical baseline. It does not determine whether processing is lawful, establish that an Article 14 exception applies, certify compliance, or replace review by qualified counsel and the relevant national authority.

The profile gives deployments a common local-first starting point when a more specific national profile is unavailable. It is aligned to the sensitive-data categories in Article 14(1) of the African Union Convention on Cyber Security and Personal Data Protection. It masks every canonical label, requires the deterministic safety sweep, uses high-recall arbitration, retains no replacement mapping, and creates no reversible identifier.

This is a floor for technical de-identification, not a harmonized legal rule. Applicable national law prevails wherever it is stricter or more specific. Use za_popia, ng_ndpa, ke_dpa, eg_pdpl, or ma_law_09_08 when the corresponding national law applies, and validate any additional local requirements independently.

Article 14(1) category map

The category text in the first column is reproduced verbatim from Article 14(1). The canonical labels are conservative technical anchors. OTHER is the non-keep fallback for sensitive concepts that do not yet have a dedicated canonical label.

Article 14(1) category Canonical label anchors Profile action
racial, ethnic and regional origin ETHNICITY, LOCATION, OTHER mask
parental filiation PERSON, FIRST_NAME, LAST_NAME, OTHER mask
political opinions ORGANIZATION, OTHER mask
religious or philosophical beliefs OTHER mask
trade union membership ORGANIZATION, JOB_DEPARTMENT, OTHER mask
sex life GENDER, OTHER mask
genetic information GENE_SYMBOL, VARIANT_DESCRIPTOR, PROTEIN_CHANGE, ZYGOSITY, CLINICAL_SIGNIFICANCE mask
data on the state of health of the data subject CONDITION, MEDICATION, LAB_TEST, PROCEDURE, BODY_SITE, GENE_SYMBOL, CLINICAL_SIGNIFICANCE mask

The complete machine-readable crosswalk lives in tests/unit/core/fixtures/africa_statute_coverage.json. Its data-driven test compiles every listed African profile and verifies that each declared class resolves to canonical labels with non-keep actions.

Operating limits

  • A policy action protects a correctly detected span; it does not guarantee discovery of every belief, affiliation, family relationship, genetic attribute, or health reference. Validate detector recall against approved synthetic or otherwise lawfully controlled local data.
  • OTHER is intentionally masked, but sites should add approved custom recognizers when a material sensitive class lacks a dedicated detector.
  • Article 14 contains exceptions that require a separate legal assessment. Selecting this profile does not assert consent, necessity, public interest, or any other exception.
  • Local processing reduces exposure but does not decide transfer, residency, retention, security, or disclosure obligations. Review every later network, cloud, telemetry, support, backup, and export path.
  • A zero-leakage synthetic test is release evidence, not a guarantee for production data. Re-run leakage and re-identification assessment for the actual languages, formats, models, and deployment boundary.

The African Union treaty page provides the official treaty record and language editions.