Unworkable Privacy Framework Stifles Digital Platforms

Section 47 creates an unworkable compliance framework for digital platforms and content creators by establishing that republishing information is a violation even if it was already publicly available (47.3's "immateriality" clause). This eliminates standard defenses used by news aggregators, social media platforms, and content curation services. Combined with 48's prohibition on using private facts in entertainment, this severely restricts digital creative content including satire, parody, and commentary—key drivers of Ghana's digital creative economy. The provision provides no practical mechanism for platforms to verify consent status (which can be revoked at any time), creating impossible compliance burdens for user-generated content services and making Ghana's framework incompatible with international digital business practices.