Data Protection in Nigeria

Registration in Nigeria

Data controllers and data processors of major importance must register with the Commission within six months after the commencement of the Act or of becoming a data controller or data processor of major importance. Data controller or data processor of major importance is defined under the Act to mean a data controller or data processor that is resident or operating in Nigeria and processes the personal data of more than such number of data subjects who are within Nigeria as the Commission may prescribe, or such other class of data controller or data processor processing personal data of particular value or significance to the economy, society or security of Nigeria, as the Commission may designate. The Act Commission through the Guidance Notice on the Registration of Data Controllers and Data Processors of Major Importance (Notice) designated all data controllers and data processors that process the personal data of at least 200 data subjects within a six-month period as being of major importance, requiring them to register with the Commission. The Notice further categorized data controllers and data processors of major importance into three levels depending on the volume of personal data processed in a six-month period as follows:

S/N Level Number of data subjects whose personal data was processed in six-month period
  Ordinary High level Over 200
  Extra-High Level Over 1000
  Ultra-High Level Over 2000

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