Privacy Notice

1. Legal Framework

Our processing activities are designed to comply with Nigeria’s Data Protection Act 2023 (NDPA), the Nigeria Data Protection Regulation (NDPR 2019), and any relevant guidance issued by the Nigeria Data Protection Commission (NDPC). We also follow sectoral compliance requirements issued by the Central Bank of Nigeria (CBN), NFIU, and other competent authorities.

2. Data We Process

• Identity data (full name, known aliases, nationality)
• Location data (state, local government area, address where provided)
• Employment and public role information
• Open-source intelligence summaries and web references
• Audit trail and review activity metadata

3. Purpose of Processing

We collect and process data to support AML/CFT compliance, due diligence, and regulatory reporting obligations. Records are vetted through a multi-tier approval process and published only after supervisor and region lead review.

4. Lawful Basis

Processing is performed under legitimate interest and legal obligation bases where applicable, consistent with NDPA and NDPR requirements. Access is restricted to authorised personnel.

5. Data Sharing

Data is shared only with authorised subscribers, internal compliance teams, and regulators in line with statutory obligations. We do not sell personal data.

6. Security & Retention

We apply technical and organisational controls to prevent unauthorised access, loss, or misuse of data. Retention periods align with applicable laws and institutional compliance policies.

7. Data Subject Rights

Data subjects may have rights under NDPA/NDPR, including access and rectification, subject to legal and regulatory constraints that apply to AML/CFT compliance systems.

8. Contact

For privacy or compliance enquiries, contact your institution’s compliance lead or the PEPLens system administrator.