Frequently Asked Questions(FAQs)

Understanding Data Protection Compliance in Nigeria

Data Protection Compliance Organisations

1. What is a Data Protection Compliance Organisation (DPCO)?

A Data Protection Compliance Organisation (DPCO) is an entity licensed by the Nigeria Data Protection Commission (“NDPC” or “Commission”). Its primary role is to help organisations achieve and maintain compliance with Nigeria’s data protection laws.

Always ask to see a DPCO’s certificate to ensure you are working with an experienced and licensed firm.

DPCOs, such as T.A.A.S Cyber Solutions Ltd, provide data protection compliance services that include auditing, advisory, Data Protection Impact Assessments (DPIAs), training, and other services required to drive compliance with the Nigeria Data Protection Act (NDP Act) 2023, General Application and Implementation Directive (GAID), and other relevant regulations or guidelines issued by the Commission.

2. Why does my organisation need a DPCO?

Every company that collects or processes personal data (also known as data controllers and data processors) must comply with the provisions of the NDP Act, which includes appointing a DPCO. Partnering with a DPCO like T.A.A.S Cyber Solutions Ltd ensures you meet all legal and regulatory obligations to comply with the Act and GAID, avoid penalties, and build trust with clients.

Maintaining this compliance, however, is a continuous and specialised task. Partnering with a licensed DPCO, such as T.A.A.S Cyber Solutions Ltd, is the most effective way to navigate these complex requirements.

As your expert partner, we:

Ensure Legal Compliance: by guiding you through the nuanced complexities of the NDP Act and GAID, helping you meet requirements under law.

Avoid Costly Penalties: through our audits and Data Protection Impact Assessments (DPIAs), which identify vulnerabilities before they become breaches, thereby significantly reducing your risk of facing fines and sanctions from the NDPC.

Build Client and Partner Trust: by demonstrating your commitment to data privacy is intentional, rather than optional. Our advisory, gap assessments, remediation, audits, red teaming, training and capacity building, help you prove to clients and stakeholders that you take the protection of their data seriously, enhancing your brand reputation.

Provide On-Demand Expertise: through a dedicated data protection team, you gain access to certified experts for audits, training, and advisory services precisely when you need them. This may be favourable to companies that prefer outsourcing to a full-time hire.

3. How is a DPCO different from a Data Protection Officer (DPO)?

A Data Protection Officer (DPO) is a mandated role by the NDP Act, responsible for ensuring the organisation’s compliance with applicable data protection legislation. A Data Protection Compliance Organisation (DPCO) like T.A.A.S Cyber Solutions Ltd serves as your licensed external expert, providing the necessary oversight and formal validation of your data privacy policies and procedures. We partner with you to audit your processes, train your DPO and staff, and officially certify your compliance status with the NDPC.

Compliance and registration as DCPMI

4. What is registration and why do companies have to register?

Registration is the process where an organisation formally notifies the regulator that it collects and processes personal data.

Under the GAID 2025, Companies are required to register as a Data Controller/Processor of Major Importance as part of their compliance requirements. This demonstrates accountability and allows the regulator to monitor organisations that handle sensitive or large volumes of data.

5. What are the registration fees for a Data Controller/Processor of Major Importance?

Under the GAID, the fee structure is tiered based on an organisation’s classification (Ultra-High, Extra-High, or Ordinary-High Level) and the volume of unique data subjects.

Category Threshold Fee
UHL Data of over 5,000 data subjects processed in 6 months ₦250,000
EHL Data of over 1,000 but less than 5,000 data subjects processed within 6 months ₦100,000
OHL Data of over 200 but less than 1,000 data subjects within 6 months ₦10,000
6. What happens if my organisation fails to comply with the NDP Act?

Non-compliance can lead to regulatory sanctions, fines, and reputational damage. T.A.A.S Cyber Solutions Ltd helps you stay compliant and protects your business.

Failing to comply with the NDP Act carries significant and costly consequences. The NDPC is empowered to enforce the NDP Act, with penalties stretching far beyond a simple warning.

The risks are threefold:

i. Tiered fine structure for violations. Upon conviction, your organisation could face:

• For Data Controllers or Processors of Major Importance: A fine of up to ₦10,000,000 or 2% of your annual gross revenue from the preceding financial year (whichever is greater)

• For other Data Controllers/Processors: A fine of up to ₦2,000,000 or 2% of your annual gross revenue from the preceding financial year (whichever is greater)

• Imprisonment for up to a year for both 

ii. In addition to fines, the NDPC can:

• Issue “Compliance Orders” forcing you to take specific actions or stop processing data

• Publish the names of non-compliant organisations in a public “name and shame” list

• Launch formal investigations into your data handling practices

iii. Business and Reputational Damage

This is often the most lasting and expensive consequence:

Loss of Trust: A public breach or sanction can instantly destroy the trust that companies work years to build

Civil Liability: The Act empowers data subjects (your clients or employees) to seek compensation in court for damages, loss, or harm caused by your non-compliance

Competitive Disadvantage: Compliant competitors can use their certified status as a marketing tool, positioning your organisation as a risk

Partnering with a licensed DPCO like T.A.A.S Cyber Solutions Ltd is a proactive investment in prevention and risk mitigation. We help you identify privacy and compliance risks, implement the necessary controls, and maintain continuous compliance, protecting your finances, industry standing, and reputation.

CDPO Training and Examination

7. Does TAAS offer CDPO training and exams?

Yes. T.A.A.S CYBER SOLUTIONS LTD is an Accredited Training Organisation (ATO) of the Institute of Information Management (IIM) Africa.

We offer a complete “end-to-end” certification package for aspiring Data Protection Officers and privacy professionals:

• Comprehensive Training: We provide the official CDPO curriculum, delivered by certified and practicing privacy experts. Our training extends beyond theory, offering tailored and practical insights into the day-to-day responsibilities of a DPO by contextualising the material to suit your specific industry.

• Exam Registration: As an accredited partner, we handle the entire examination process. We prepare you for the exam, register you with the IIM, upload your documents, and submit your candidacy for the exam.

• Certification: Upon passing, you will receive the prestigious Certified Data Protection Officer (CDPO) designation from the Institute of Information Management, a globally recognised standard for information management and data protection.

Whether you are an individual looking to upskill or an organisation needing to certify your internal DPO, we provide the necessary training and accreditation pathway.

8. What is the process for registering for CDPO training and exam?

i. Contact T.A.A.S Cyber Solutions Ltd via our website or email (info@taas-ltd.ng)

ii. Select your preferred training schedule (virtual or physical)

iii. Provide relevant documentation for submission to the IIM on your behalf for exam registration:

• Educational/Professional Certificates

• Recent passport photograph (clear image)

• Government-issued identification (e.g., Driver’s License, Voter’s Card, International Passport, NIN, etc.)

iv. Make payment (of which examination is included: ₦250,000 (Non-IIM Accredited Member) ₦200,000 (IIM Accredited Member))

v. Schedule your training in-person/virtual training and receive joining instructions

vi. Complete the training and receive participants’ pack, in addition to Certificate of Attendance 

vii. Sit the CDPO exam – scheduled at the end of every month

Please note, as of January 2026, the NDPC is mandating all DCPMIs have certified DPOs.

 

Our Services

9. What services does T.A.A.S Cyber Solutions Ltd offer?

As a licensed DPCO, we provide a comprehensive suite of services designed to meet organisations at their current level of data protection compliance, whilst driving maturity where critical gaps exist. 

• NDP Act compliance audits, with filings, remediation, and gap assessments to show your current state of data protection compliance

• Privacy advisory and problem-solving

• Data Protection Impact Assessments (DPIAs)

• Policy drafting 

• Third-Party Risk Management

• AI Governance 

• AI governance training and program development

• Data breach management and reporting support

• Staff training and capacity building

• Data Protection Officer (DPO) training

• IIM CDPO training and exam registration

• Outsourced DPO services

• Preparation for professional certifications including CIPP/E (Certified Information Privacy Professional/Europe) and CIPM (Certified Information Privacy Manager)

• Preparation for certifications and external audits (ISO 27001, ISO 27701, ISO 22301, CIPP/E, CIPM)

• Other ad hoc services upon request

10. Do you work with both large organisations and SMEs?

Yes. Data protection compliance is a legal requirement for organisations of all sizes, and our services are designed to be scalable and practical for everyone. 

Our approach is not “one size fits all”. We tailor our services to your specific size, industry, data processing activities, and risk profile to ensure you receive the exact support you need.

11. Do you help organisations prepare and file their compliance audit reports?

Yes, a fundamental part of our service involves meeting this mandatory legal requirement, which applies to many organisations.

The GAID mandates that all “Data Controllers/Processors of Major Importance” (DCPMI) must submit an annual Compliance Audit Return (CAR) to the Nigeria Data Protection Commission.

As a licensed DPCO, T.A.A.S Cyber Solutions Ltd manages this entire critical process for you, from start to finish:

1. Full-Scope Audit: We conduct a thorough and independent audit of your data processing activities, policies, and safeguards to measure your compliance against the NDP Act and GAID

2. Formal Report Preparation: We compile our findings into the official, detailed Compliance Audit Report (CAR) in the precise format required by the NDPC

3. On-Time NDPC Submission: We handle the official submission of your audit report directly to the NDPC, ensuring it is filed correctly and ahead of the annual March 31st deadline

4. Management Reports: We provide a comprehensive management audit report and a current state gap assessment report. These documents outline areas for necessary remediation and include a detailed remediation plan

Partnering with us removes the burden and guesswork from this process. We ensure your submission is accurate, professional, and filed on time, keeping you in good standing with the Commission and demonstrating your commitment to data protection. Most importantly, we meet clients at their level of maturity and assist them in their compliance journey.

12. Are there fees associated with filing the audit report?

Yes. Data Controllers and Processors of Major Importance have varying audit return filing fees depending on their tiers, as stipulated in the table below:

DCPMI

Tier

Fee

Ultra-High Level

(UHL)

A – 50,000 data subjects and above

₦1,000,000

B – 25,000-49,999 data subjects

₦750,000

C – below 25,000 data subjects

₦500,000

Extra-High Level

(EHL)

A – 10,000 data subjects and above

₦250,000

B – 2,500-5,000 data subjects

₦200,000

C – below 2,500 data subjects

₦100,000

Please note – there are penalties for late filings, which are 50% of the filing fees. 

 

Engagement Process

13. How can we engage T.A.A.S Cyber Solutions Ltd as our DPCO?

You can contact us via our website, LinkedIn, or email. We’ll schedule a consultation to understand your data processing operations, then provide a proposal tailored to your organisation’s needs.

Getting started is a straightforward, three-step process. We are ready to help you, whether you are just starting your compliance journey or preparing for another annual audit.

Step 1: Reach out to our expert team. We will schedule a complimentary consultation to understand your organisation’s unique data processing activities, industry, current maturity, and compliance goals.

• Email: info@taas-ltd.ng 

• Phone: +234-702-500-2042

• Website: https://taas-ltd.com/contact-us/ 

• LinkedIn: https://www.linkedin.com/company/t-a-a-s-cyber-solutions-ltd/ 

Step 2: Based on our initial consultation, we will conduct a high-level assessment of your needs. We will then provide you with a detailed, no-obligation proposal that outlines a clear scope of work – whether it’s for a full compliance audit, staff training, DPO services, DPIA, or a combination of our offerings.

 

Step 3: Once aligned on the proposal, we will formally onboard you as a client. This includes  signing a Letter of Engagement, submission of first invoice, holding a kick-off call, and immediately beginning the process of guiding your organisation towards data protection compliance.

You can contact us today to schedule your initial consultation.

14. What documents or information will you need from us?

We request key policies, information around staff procedures, system information, process walkthroughs and evidence of data security controls to adequately assess your compliance level.

To begin a comprehensive compliance assessment, we typically start with a discovery phase. 

This is a standard and essential part of the compliance audit. All information shared with T.A.A.S Cyber Solutions Ltd is treated with the strictest confidentiality, governed by our Non-Disclosure Agreement and Letter of Engagement, and is used solely for the purpose of assessing and improving your compliance with the NDP Act.

Our team will provide a detailed checklist, which generally includes:

• Existing policies and procedures

• Information around your data processing practices (e.g. third party vendors)

• Technical and organisational details around data security

• Examples of your consent forms

The specific information required will depend on the services you need, for instance, a full compliance audit requires more detail than a simple policy review.

15. How long does a typical compliance audit take?

The exact duration of the project will depend on the availability of necessary documentation and staff for interviews, the current maturity and existing data protection culture, identified gaps against regulatory requirements, management involvement, collaboration and timely remediation. 

Estimated timelines are agreed upon in the Letter of Engagement and can take between two to four weeks

16. What to expect during a typical compliance audit?

We follow a structured, multi-phase process: 

Phase 1: Scoping and Kick-Off (Approx. 1-2 Days) 

This initial phase involves our team meeting with yours, defining the exact scope of the audit, and providing a comprehensive checklist of the documents and access we will need.

Phase 2: Audit and Assessment (Approx. 2 Weeks) 

This is the core audit which includes:

• Reviewing your policies, procedures, and contracts

• Conducting interviews with key staff (e.g. Legal, IT, HR, Marketing, Operations)

• Assessing your technical systems and security safeguards

• Analysing your data flows and Record of Processing Activities (ROPA)

Phase 3: Analysis and Report Drafting (Approx. 1-2 Weeks) 

After the assessment, our team analyses the evidence provided, identifies any compliance gaps, and prepares the comprehensive draft audit report. This report details findings, assesses the company’s level of compliance, and provides clear and actionable remediation plans with prioritised recommendations.

Phase 4: Validation and Final Report (Approx. 1-2 Days) 

We present the draft report to your management team, giving you an opportunity to review and validate our findings. Once finalised, we submit the official Compliance Audit Report (CAR) to the NDPC. 

Confidentiality and Data Handling

17. How do you ensure our information remains confidential?

Confidentiality is not only central but also critical to our work. All information shared with T.A.A.S Cyber Solutions Ltd is treated with the strictest confidentiality, governed by our non-disclosure and duty of professional secrecy. All data is used solely for the purpose of assessing your compliance with the NDP Act.

18. Will our data be shared with anyone else?

No. We do not share client data with third parties unless required by law or with your written consent. We use Google Workspace, Enterprise as a storage solution, with data stored on servers in the European Union. 

Training and Support

19. Do you offer staff training on data protection?

Yes, we do. Staff training and awareness are a critical part of compliance. We provide tailored sessions customised to your business and the specific roles of your employees:

• General Staff Awareness: An engaging and interactive training for all employees covering the fundamentals of the NDP Act and GAID, including understanding how to identify personal data, lawful basis and principles of data protection, and staff responsibility in protecting personal data.

• Role-Specific Workshops: Specialised interactive training and workshops for high-risk departments, such as:

• Legal: Contract management and data processing agreements

• HR: Handling employee data, retention, and physical access

• Marketing: Managing consent, customer lists, and digital privacy with tracking technologies (Pixels, cookies, targeted ads etc.)

• IT and Security: Technical safeguards, access controls, breach response and simulations, vendor due diligence

• Executive and Leadership Briefings: A high-level overview for senior management focusing on legal accountability, financial risks, and the strategic importance of data governance.

Our training, available both on-site and virtually, ensures your team not only understands the rules but also knows exactly what to do – and what not to do – in their day-to-day work.

20. Do you offer ongoing compliance support?

Yes. We offer retainer-based support to monitor compliance, manage data protection risks, and keep your organisation updated on regulatory changes.

Incidents and Breaches

21. What should we do in case of a data breach?

Contact us immediately. We’ll help assess the impact, document the incident, guide you through notifying the NDPC (and affected individuals where necessary) and conduct forensic investigation and remediation.

Pricing and Administration

22. How are your services priced?

Pricing depends on your industry, the organisation’s size, scope of data processing activities, and sensitivity of data handled. We provide packages suitable for startups, SMEs, and large enterprises.

23. How often should compliance be reviewed?

The NDPC mandates annual audits and twice-yearly internal reporting to management. Periodic internal reviews are encouraged, especially when business processes change.

There are two mandatory review frequencies:

1. Annual Compliance Audit Return (CAR): 

This is the main, external audit. It must be conducted once yearly by a licensed DPCO like T.A.A.S Cyber Solutions Ltd. This applies to all Data Controllers of Major Importance (DCPMI) and is formally filed with the NDPC by the March 31st deadline.

2. Semi-Annual Internal Report: 

This is an internal report. It must be prepared twice per year by your own Data Protection Officer (DPO) and submitted to executive management. As a licensed DPCO, we are available to assist with this exercise in an advisory capacity. 

24. Do you need to visit our offices to conduct the compliance audit?

No, an on-site visit is generally not required although it could be necessary if sensitive personal data is stored in hard copies. Our fully remote and agile operational model is specifically designed to conduct comprehensive, thorough audits efficiently from a distance.

We leverage secure technology to ensure a seamless process with minimal disruption to your daily operations:

• Secure Collaboration: As part of our transparent process, we set up a dedicated, secure shared drive where your team can upload all necessary documents, policies, and evidence for our review

• Virtual Interviews: We conduct all necessary interviews with your key staff via secure video conferencing, scheduled at your convenience

• Remote System Reviews: We can assess your technical controls and platforms through guided screen-sharing sessions and remote demonstrations

Any other questions?

Feel free to contact us directly on +234-702-500-2042.

For Europe-based clients, please engage our sister company T.A.A.S Inc. Limited on +44-7817-8659-16, or Toulu@taas-ltd.com

Compliance is easy with the right specialists. Visit taas-ltd.com/contact-us to book your free consultation today

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