DATA PRIVACY & PROTECTION POLICY

PREAMBLE

This Privacy Policy governs the data protection standards by which The Integrity Group of Nigeria (hereinafter “The Organization“) processes the personal information of our data subjects, which specifically includes: members, certification candidates, programme participants, conference delegates corporate clients, and website visitors etc. This policy comprehensively covers data processing activities across our portals, programs, client projects, and during our industry events, such as Conference/Workshop/Training.

In strict compliance with the Nigeria Data Protection Act (NDPA) 2023, the General Data Protection Regulation (EU) 2016/679 (GDPR), and other applicable global data privacy laws, we uphold the fundamental privacy principles. These principles mandate how we collect, use, record, organize, structure, store, adapt, retrieve, encrypt, disclose, and securely destroy your personal data to ensure the highest level of confidentiality and integrity.

ARTICLE 1: DEFINITIONS & INTERPRETATION

For the purpose of this Policy, the following terms have the meanings ascribed to them under Section 65 of the NDPA and Article 4 of the GDPR:

• “Personal Data”: Any information relating to an identified or identifiable natural person (Data Subject).
• “Data Subject”: You (our Member, Student, or Website Visitor).
• “Processing”: Any operation performed on personal data (collection, storage, use, etc.).
• “Data Controller”: The Organization (We determine why and how your data is used).
• “Processor”: An entity that processes personal data on behalf of the Controller (e.g., our third-party cloud hosts).

ARTICLE 2: OUR PRINCIPLES OF DATA PROCESSING

In processing your personal data, we adhere strictly to the principles set out in Section 24 of the NDPA and Article 5 of the GDPR. We ensure your data is:

1. Processed lawfully, fairly, and transparently.
2. Collected for specified, explicit, and legitimate purposes.
3. Limited to what is necessary (Data Minimization).
4. Accurate and kept up to date.
5. Retained only for as long as necessary (Storage Limitation).
6. Secured against unauthorized access or loss.

ARTICLE 3: LAWFUL BASIS FOR PROCESSING

We only process your data when we have a valid legal ground as required by Section 25 of the NDPA:

3.1. Performance of Contract 

• Used when you register for membership, or pay for services. We need your data to deliver the service you paid for.

3.2. Legal Obligation 

• Used for tax reporting, audit trails, and compliance with governmental regulatory bodies.

3.3. Legitimate Interest 

• Used for securing our website, preventing fraud, and maintaining our registry.

3.4. Consent 

• Used for newsletters, marketing, and non-essential cookies. You have given clear, affirmative consent. You have the right to withdraw this consent at any time.

ARTICLE 4: SCOPE OF DATA COLLECTED

We collect different data depending on your relationship with us:

4.1. For Members & Fellows

• Bio-data (Name, DOB, Gender), Passport Photographs or Government ID copies, Membership ID, Professional Qualifications, CPD Records, and Dues Payment History etc..

4.2. For Website Visitors

• IP Address, Browser Type, and Device Information (collected via Cookies for analytics and security), Pages visited, duration of session etc.

 

ARTICLE 5: CAVEAT ON WEBSITE LINKS

This website may contain links to other websites. Save and except as otherwise expressly stated by us, any link to another website is not covered by our privacy policy. We strongly advise that you should satisfy yourself with the details of any privacy policy provided on other websites or links.

ARTICLE 6: SENSITIVE PERSONAL DATA & CHILDREN

5.1. Sensitive Data We do not collect sensitive data (biometrics, health, religious beliefs) unless explicitly required for a specific purpose (e.g., biometric attendance for exams) and only with your explicit consent pursuant to Section 30 of the NDPA.

5.2. Children’s Privacy If a learner is under 18, we require consent from a parent or guardian in compliance with Section 31 of the NDPA.

ARTICLE 7: DATA TRANSFERS & THIRD PARTIES

We do not sell your data. As an establishment, third parties may wish to provide essential services to you (through our platforms) while relying on the relevant lawful bases for processing your personal data in this regard. The type of data usually processed for this may be your contact details. Where such services depend on consent, you have the right to decline and further restrict the processing of your personal data. You can simply unsubscribe to the notices sent for the purpose of such services

However, we may share data with third parties:

• Payment Processors: (e.g., Paystack, Flutterwave) for secure transactions.
• Cloud Hosting: (e.g., AWS, Azure) where our database resides.
• Partners/Accreditation Bodies: If our programs are certified by external global bodies, members’ results may be shared for certification generation or as needed.
• Data analytics,
• Data security, and
• Software development.

ARTICLE 8: DATA RETENTION

We retain data only as long as the purpose requires:

• Member Records: Perpetually (for verification and service offerings).
• Financial Records: Perpetually (for tax audit purposes).

ARTICLE 9: RIGHTS OF THE DATA SUBJECT

Under Part VI of the NDPA (Sections 34-38) and GDPR Chapter III, you have the right to:

1. Request Access to your personal data.
2. Request Correction of inaccurate data.
3. Request Deletion (“Right to be Forgotten”) where applicable.
4. Withdraw Consent at any time.
5. Object to processing for direct marketing.
6. Data Portability (receive your data in a usable format).

ARTICLE 10: DATA SECURITY

We employ technical and organizational measures as mandated by Section 39 of the NDPA, including:

• SSL Encryption for all website traffic.
• Restricted access to all databases (Staff only).
• Regular security audits.

ARTICLE 11: COOKIES POLICY

Customarily, websites are designed to collect certain information from the visitor. This website is also designed to collect your IP address and other information that your web browser typically shares with the websites that you visit. Our websites use cookies to enhance user experience.

• Essential Cookies: Necessary for the site to function (e.g., logging into the membership portal).
• Analytics Cookies: Help us understand how visitors use our site (e.g., Google Analytics).
• Marketing Cookies: Used to deliver relevant ads (only with your consent).
• You can manage your cookie preferences via your browser settings.

ARTICLE 12: DISPUTE RESOLUTION & CONTACT

10.1. If you have concerns regarding your data, please contact us at:

• Phone: 0803 846 1603

10.2. Right to Lodge a Complaint If you are dissatisfied with our handling of your data, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC):

• Website: https://ndpc.gov.ng

ARTICLE 13: ALTERATION OF PRIVACY POLICY

The Data Controller (The Organization) reserves the right to update or amend the foregoing policy for the purposes of advancing data privacy rights, public interest or complying with lawful directives of the Federal Government – in line with the safeguards under the NDP Act, GDPR and the 1999 Constitution of the Federal Republic of Nigeria.