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Extension of Deadline for Compliance with Nigeria Data Protection Bureau’s NaDPAP Whitelist Requirements

As you may be aware, the Nigeria Data Protection Bureau (“NDPB”) recently published a Compliance Notice (the “Notice”), notifying the general public of the establishment of the National Data Protection Adequacy Programme (“NaDPAP”) Whitelist and the requirements for inclusion on the whitelist. In the Notice, NDPB gave organisations till November 25, 2022, to comply with the requirement for inclusion on the Whitelist. Please be informed that the deadline for compliance has been extended from November 25, 2022 to January 20, 2023.

The notice of the extension was recently announced by the National Commissioner of the NDPB, Dr. Vincent Olatunji, who explained that the need for data controllers and data processors to comply with the earlier notice on National Data Protection Adequacy Programme Whitelist caused the Federal Government to approve an extension of the deadline. The National Commissioner disclosed that all data controllers and data processors who complied with the directive before the expiration of the initial deadline of November 25, 2022, have been awarded full marks of 10 points under the Accountability Metrics and Responsiveness to Regulatory Processes, which represents 10% of the total number of scores to be awarded for eligibility for inclusion on the NaDPAP Whitelist. Other performance metrics upon which the NDPB would  evaluate data controllers and data processors include (but not limited to):

(1)    Organisation’s implementation of a NDPR Compliant Privacy Policy

(2)    Sensitisation of Data Subjects on Data Subjects Rights

(3)    Filing of Annual Compliance Audit Returns, and

(4)    Filing of Globally Acceptable Information Security Certifications.

It is therefore imperative that organisations that process personal data take steps to ensure compliance with the provisions of the Nigeria Data Protection Regulations 2018, the Nigeria Data Protection Regulations: Implementation Framework, 2019 as well as the various directives of the NDPB of the aforementioned instruments.

Note: Banwo & Ighodalo is a duly licensed Data Protection Compliance Organisation (DPCO). Kindly contact us (at for any assistance you may require regarding compliance with your data protection obligations or for further enquiries regarding our data protection compliance services.

Click here to read the initial Compliance Notice From The Nigeria Data Protection Bureau