General Principles
The Nigerian Data Protection Act and other relevant data protection laws set out several principles to regulate and guide data processing activities undertaken by data controllers. Nazza recognizes and respects the principles and continues to take active steps towards upholding the same. Some of the principles and steps taken to uphold them are examined below:
Data MinimisationThe data minimization principle envisages that in our capacity as data controllers, we do not collect personal data, more than is reasonably necessary to achieve the purpose for which the data is collected. We take conscious steps to ensure that we undertake a data-sifting activity to ensure that we do not collect more personal information than is necessary.
Purpose LimitationThis principle dictates that personal data should be collected for specific and explicit purposes and should not be used for any other purpose, apart from those specified. We do not use personal information for any other purposes aside from those specified to the data subject unless it is done with the consent of the data subject.
Data protection by defaultIn accordance with data protection principles and regulations, all systems, processes, and procedures at Nazza shall be designed and implemented to ensure that personal data is protected by default. This includes but is not limited to:
- Data Minimisation
Only necessary personal data shall be collected, processed, and retained for the specified purposes outlined in the organization's privacy notices.
- Access Controls
Access to personal data shall be restricted to authorized individuals on a need-to-know basis, with appropriate authentication and authorization mechanisms in place.
- Encryption
Personal data shall be encrypted both in transit and at rest, using industry-standard encryption algorithms and protocols.
- Anonymization/Pseudonymization
Wherever feasible, personal data shall be anonymized or pseudonymized to prevent identification of data subjects.
- Data Lifecycle Management
Personal data shall be retained only for the duration necessary to fulfill the purposes for which it was collected, and shall be securely deleted or anonymized thereafter.
- Regular Review and Audit
Regular reviews and audits shall be conducted to ensure compliance with this policy and to identify and address any gaps or risks in data protection practices.
- Training and Awareness
Employees shall receive regular training and awareness programs to ensure they understand their responsibilities in protecting personal data by default. This is further delineated in later sections of this Policy.
- Accountability and Governance
Accountability measures shall be in place to ensure adherence to this policy, with clear governance structures and processes for overseeing data protection practices
- Continuous Improvement
Continuous improvement efforts shall be undertaken to enhance data protection practices and adapt to evolving regulatory requirements and technological advancements.
Data protection by designFor us at Nazza, we recognize the fact that privacy and data protection factors should not be an afterthought in the design and lifecycle of our products and services. Our team of cybersecurity experts, product developers, and data protection experts, work together to ensure that data protection principles are inculcated into our products from design to the lifecycle stage.
Laws and Regulations
The goal of this policy is to facilitate compliance with relevant data protection laws, governing our data processing activities.Relevant and applicable laws relating to data protection in Nigeria may be broadly classified into primary and secondary sources. The primary sources are the most authoritative while the secondary sources nonetheless enjoy some force of law as long as they do not contradict the provisions of the primary sources.
Primary Sources- a. The Constitution
- b. The Nigeria Data Protection Act
- c. Federal Competition and Consumer Protection Act
- d. Cybercrime (Prohibition, Prevention, etc.) Act.
Secondary Sources- a. Nigeria Data Protection Regulations (NDPR)
- b. Framework for theImplementation of the NDPR
- c. ISO 27 001 Information by Security Standard
- d. Privacy by design principles