Africa needs to follow the EU's example in laying common law that will help countries protect public and private data, as more governments are moving to offer services online.

A Liquid Telecom report, Cybersecutrity and Data Protection from Liquid Telecom, highlighted Uganda, Kenya, Tanzania, Ghana, Zimbabwe and South Africa as countries that are in the process of initiating data protection laws in Africa.

In Kenya, the Data Protection Bill of 2013 aims to make it difficult for third parties to mine personal information without consent of the owner, while in Ghana the adoption of The Data Protection Act that was passed in 2012 is facing slow enforcement.

South Africa has passed its legislation by September 2016 and in Zimbabwe privacy is enriched in the constitution.

The only initiative to encompass most of Africa in a common legislation was taken in June 2014 with African Union's Convention on Cyber Security and Personal Data Protection, but this is still in its infancy and remains unratified by countries.

"Some 53 African states came together to agree a legal framework to regulate various fields of ICT activity, ranging from e-transactions and personal data protection to cyber security. The convention is not however any kind of legally binding instrument, and requires that individual countries put its principles into their own statute book," the report said.

The importance of data protection laws for development cannot be underestimated. The report said that such legislation could be a deciding factor for companies that wish to expand across Africa. They would "aim to avoid places where the integrity of data is set at a low premium, or where they might get hit hard by protectionist and maverick data laws designed to seal borders and favour indigenous enterprises."

Even though the efforts around the continent are still fragmented and immature, the report believes that for some countries it is becoming progressive and moving in the right direction.

"There still needs to be more consensus on the meaning of key terms like 'consent', 'public interest' and 'legitimate grounds'. But there is hope that such details can be thrashed out and enshrined in a binding framework that both protects citizens and allows for healthy economic development," the report suggests.