A borrower’s right to data privacy is not negotiable

  1. Article 2.5 and 3.1(7) of the NDPR: Use of non-conforming privacy notice
  2. Articles 2.2 and 2.3 of the NDPR: Insufficient lawful basis for processing personal data
  3. Article 2.2 of the NDPR: Illegal data sharing without appropriate lawful basis
  1. In the case of a Data Controller dealing with more than 10,000 Data Subjects: a fine of 2% of Annual Gross Revenue of the preceding year or payment of the sum of 10 million Naira is payable; whichever is greater.
  2. In the case of a Data Controller dealing with less than 10,000 Data Subjects: a fine of 1% of the Annual Gross Revenue of the preceding year or payment of the sum of 2 million Naira is payable, whichever is greater.
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