Data Protection in Nigeria: A Practical Compliance Checklist for Growing Businesses
Customer data is now a regulated asset. Here is how to map what you collect, document a lawful basis and stay ready for regulatory scrutiny.
Every business that collects names, phone numbers, payment details or location data is processing personal data. With the Nigeria Data Protection Act 2023 and the oversight of the Nigeria Data Protection Commission, that processing now carries clear legal obligations — and real consequences when they are ignored.
Start with a data map
You cannot protect what you have not identified. Before drafting a single policy, document what personal data you collect, why you collect it, where it is stored, who can access it and who you share it with.
- List every touchpoint: website forms, apps, CRM, payroll, CCTV and vendors.
- Record the purpose for each category of data and how long you keep it.
- Identify third parties and cross-border transfers.
Document a lawful basis
Processing must rest on a lawful basis — consent, contract, legal obligation, vital interest, public interest or legitimate interest. Consent should be specific, informed and as easy to withdraw as it was to give.
Put the essentials in writing
- A clear, accessible privacy notice.
- Internal data protection and retention policies.
- Data processing agreements with vendors.
- A breach-response plan with named owners and timelines.
Compliance is not a document you file away — it is a habit your organisation practises.
Our team helps businesses carry out data audits, draft policies, assess risk and engage with regulators. If you are launching a product, raising capital or onboarding enterprise clients, a compliance review is time well spent.
This article is for general information only and does not constitute legal advice. For advice on your specific circumstances, please contact us.
