Data breach reporting under the NDPA
The main NDPA breach obligations, the risk test, and the response sequence and records to prepare.
Data protection law, sector rules, contracts and insurers expect you to protect information and prove it. We close the technical and operational gaps and prepare evidence, alongside your legal adviser; we do not give legal advice or certify compliance.
Readiness means meeting the requirements that apply to you and being able to show it. Your legal adviser decides what applies and how to read it; independent auditors and certifiers decide whether you meet a standard. We turn their requirements into systems, procedures and evidence, and flag legal questions instead of guessing.
| Requirement | What it covers |
|---|---|
| NDPA 2023, enforced by the NDPC | The main data protection law: lawful basis and consent, data subject rights, data protection officers, impact assessments for high-risk processing, transfers outside Nigeria, breach notification. |
| NDPC GAID 2025 | How the NDPA applies in practice, including registration of controllers and processors of major importance. |
| Health data | Sensitive personal data under the NDPA, plus National Health Act 2014 confidentiality duties: clinics, laboratories, hospitals, health-tech. |
| CBN, SEC Nigeria, NAICOM, PenCom | CBN cybersecurity framework and guidelines for banks and payment service providers; capital-market operators, insurers, pension operators; and their vendors. |
| Direct marketing | NDPA consent rules and the NCC's rules on unsolicited messages, where email and SMS marketing are in scope. |
| ISO/IEC 27001, SOC 2 | Often requested by enterprise and international clients; issued by independent auditors and registrars. |
| Regulated clients, insurers | Sector assessments of suppliers; insurer questions on MFA, EDR, backups, email security, training; clauses on data location, breach notification, subcontractors. |
With 72 hours to notify the NDPC, and early decisions hard to undo, the plan names who does each step; we rehearse it with you in a tabletop exercise.
Technical gaps? Security assessments measure controls in depth; cybersecurity closes them: EDR, email security, awareness training.
Identify the laws, sector rules, contracts and frameworks likely to apply; confirm them with your legal adviser.
Output: Requirements map.
Inventory what personal data you collect, why, where it lives, who sees it and for how long.
Output: Data inventory and flow diagram.
Compare your technical and organisational safeguards with the requirements, and rank gaps by risk.
Output: Gap report and remediation plan.
Update controls, procedures, contracts and training; build the breach plan and register.
Output: Updated safeguards and breach plan.
Assemble what an auditor, insurer or regulator would ask for, and rehearse a breach scenario.
Output: Evidence pack and tabletop results.
No package prices: estimates in naira from an agreed scope, taxes shown separately.
In general terms, under the Nigeria Data Protection Act 2023 a controller must notify the NDPC within 72 hours of becoming aware of a breach likely to risk individuals' rights and freedoms, and tell affected people without undue delay where the risk is high. Critical national information infrastructure operators have further duties.
Not on its own. Nigeria has no major public cloud region, so it is usually a local data centre (Lagos, Abuja) or a region abroad; either can work. NDPA transfer rules, sector rules, access controls, contracts, support access and backups matter too. We review the whole picture.
Generally yes. Data protection obligations apply regardless of size when you handle personal data, but the work scales down to a focused data inventory, a breach plan and a handful of well-run controls.
The main NDPA breach obligations, the risk test, and the response sequence and records to prepare.
Security in plain language: what could go wrong, how likely it is, what to fix first.
Assessments, endpoint protection, email security, training, incident readiness, and 24/7 monitoring for managed-service clients.
Tell us what has been asked and what information you handle. We will reply to arrange a conversation about getting ready.