Mobile money lending and AI: The right not to be subject to automated decision making


The success of mobile money in Kenya changed lives and has created a good base for many mobile technology-based solutions. Among these solutions are mobile loan services which ride on the mobile system but also involve the use of artificial intelligence (AI).

For the purposes of this report, AI is defined broadly as computer systems designed to perform tasks in a way that is considered to be intelligent, including those that “learn” through the application of algorithms to large amounts of data.[1] Because of this, algorithmic decision making will be considered use of AI. Automated decision making is a decision made by automated means without any human involvement. Examples of this include an online decision to award a loan and a recruitment aptitude test which uses pre-programmed algorithms and criteria.[2]

In the mobile lending process, there are two instances where algorithms sift through data before making decisions. This is in the credit scoring stage and credit referencing stage. The decisions these algorithms make affect the lives of millions of Kenyans every day. In this report, I will highlight the rights enshrined in the Kenyan Bill of Rights that are being affected by the use of AI in mobile lending apps.


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