Document Governance for Nigeria Data Protection Compliance
Confidential — For Authorized Distribution Only
The Nigeria Data Protection Act 2023 and the Nigeria Data Protection Commission (NDPC) regulations represent Africa's most comprehensive data protection framework. Compliance requires systematic document governance—proper classification of personal data documents, defined retention periods, controlled access, and documented disposal. This guide provides a practical implementation roadmap using Doc-Assure's document governance capabilities.
The NDP Act 2023 establishes comprehensive data protection requirements for organizations processing personal data of Nigerian residents. Key requirements include:
Every NDPC requirement has a document governance component. You cannot demonstrate compliance without proper documentation—and you cannot manage that documentation without systematic governance: file plans, retention schedules, access controls, and audit trails.
| Category | Annual Revenue | Data Subjects | Requirements |
|---|---|---|---|
| Major Data Controller | > ₦100M | > 500,000 | Full compliance, DPO, annual audit |
| Data Controller | ₦10M - ₦100M | 10,000 - 500,000 | Registration, policies, breach notification |
| Small Data Controller | < ₦10M | < 10,000 | Basic compliance, simplified registration |
NDPC compliance is fundamentally about documentation:
Without systematic document governance—file plans, retention schedules, access controls— this documentation becomes chaotic and compliance becomes impossible to demonstrate.
Doc-Assure provides the document governance infrastructure for NDPC compliance:
| NDPC Requirement | Document Governance Control | Doc-Assure Feature |
|---|---|---|
| Records of Processing | Document classification | Personal data file plan categories |
| Storage Limitation | Retention schedules | Automated retention policies |
| Access Control | Permission management | Role-based access, audit trails |
| Data Subject Rights | Request tracking | DSR workflow with documentation |
| Breach Documentation | Incident records | Breach documentation templates |
The first step in NDPC compliance is knowing what personal data you hold. Doc-Assure's file plan for NDPC compliance includes:
| Category | Examples | Classification Level |
|---|---|---|
| Basic Personal Data | Name, contact details, ID numbers | Confidential |
| Financial Data | Bank details, salary, tax records | Highly Confidential |
| Sensitive Personal Data | Health, biometric, ethnic origin | Restricted |
| Children's Data | Data of persons under 18 | Restricted |
| Employee Data | HR records, performance, disciplinary | Confidential |
| Customer Data | Transaction history, preferences | Confidential |
Doc-Assure's AI analyzes documents to identify personal data content:
Proper classification is the foundation of NDPC compliance. It determines retention periods, access controls, transfer restrictions, and DSR scope. Invest time in getting classification right.
The NDP Act requires a valid legal basis for processing personal data:
| Lawful Basis | Documentation Required |
|---|---|
| Consent | Consent form, date, scope, withdrawal mechanism |
| Contract | Contract document, data processing provisions |
| Legal Obligation | Reference to specific law/regulation |
| Vital Interests | Emergency documentation, medical necessity |
| Public Interest | Public authority mandate, task specification |
| Legitimate Interest | LIA assessment document, balancing test |
Doc-Assure links processing activities to lawful basis documentation:
The NDP Act requires that personal data be kept "no longer than is necessary for the purposes for which it was collected." This requires:
| Document Category | Retention Period | Trigger | Justification |
|---|---|---|---|
| Customer KYC | Account closure + 7 years | Account closure | CBN AML requirements |
| Employee Records | Employment end + 7 years | Employment termination | Labour law, pension |
| Transaction Records | 7 years | Transaction date | Tax, audit requirements |
| Marketing Consent | Consent withdrawal + 1 year | Withdrawal date | Proof of consent/withdrawal |
| DSR Records | 3 years | Request completion | Regulatory evidence |
Doc-Assure manages NDPC-compliant disposal:
The NDP Act grants data subjects several rights that require documented responses:
| Right | Timeline | Documentation Required |
|---|---|---|
| Access | 30 days | Request record, identity verification, data extract |
| Rectification | 30 days | Request record, original vs. corrected data |
| Erasure | 30 days | Request record, legal basis review, deletion certificate |
| Restriction | 30 days | Request record, restriction flags on documents |
| Portability | 30 days | Request record, data export in machine-readable format |
| Objection | 30 days | Request record, legitimate interest re-assessment |
Doc-Assure provides complete DSR documentation workflow:
Transfers of personal data outside Nigeria require documented safeguards:
| Transfer Mechanism | Required Documentation |
|---|---|
| Adequacy | Reference to NDPC adequacy list |
| BCRs | Approved BCR document, intragroup agreement |
| SCCs | Executed SCC agreement, supplementary measures |
| Consent | Specific consent form with transfer details |
Doc-Assure's federation capability is particularly valuable for BRICS+ transfers:
As Nigeria increases economic ties with BRICS+ nations, federation enables compliant document sharing without triggering complex transfer mechanisms. The data stays in Nigeria; only controlled access is provided.
NDPC compliance is fundamentally about document governance—knowing what personal data you hold, why you hold it, how long you keep it, and demonstrating this through systematic documentation.
Doc-Assure provides the governance infrastructure Nigerian organizations need: file plans for personal data classification, retention schedules aligned with NDPC requirements, access controls with complete audit trails, and federation capabilities for compliant cross-border collaboration.
Compliance is achievable in 90 days with the right approach and tools.
Contact us for a demonstration of Doc-Assure's NDPC compliance capabilities.
Email: compliance@doc-assure.africa
Web: www.doc-assure.africa/compliance/ndpc
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