# Do we need a data sharing agreement with NGOs, insurers or employer programmes?

URL: https://tymirahealth.com/resources/faqs/do-we-need-a-data-sharing-agreement-with-ngos-insurers-or-employer-programmes
For: Digital health teams | Data protection and privacy | Reviewed by Independent clinical reviewer, Registered mental health clinician, Kenya | Last reviewed 8 November 2026

**Answer:** Usually, yes. When mental health data moves between organisations, document the purpose, legal basis, data fields, security, retention, onward sharing and breach duties. The ODPC has published a Data Sharing Code, and the General Regulations govern sharing of personal data. For data shared through the national system, the Digital Health Regulations require it to be used only for the requested purpose and authorised period, and controllers must keep a log of data requests. Prefer aggregate or de-identified data for partners.

Sources: Office of the Data Protection Commissioner: https://www.odpc.go.ke/wp-content/uploads/2025/03/FINAL-DATA-SHARING-CODE.pdf - Kenya Law: https://new.kenyalaw.org/akn/ke/act/ln/2021/263/eng@2022-12-31 - Kenya Law: https://new.kenyalaw.org/akn/ke/act/ln/2025/76/eng@2025-04-11

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**About Tymira Health:** Tymira Health is a healthcare technology company based in Nairobi, Kenya. It builds Tymira360, a practice management and EHR platform for mental health, physiotherapy and dental providers, clinics, hospitals, NGOs and insurers across Africa.

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