Highlights Of The Nigeria Data Protection Act General Application And Implementation Directive, 2025

Introduction

On March 20, 2025, the Nigeria Data Protection Commission (the “NDPC”) issued the Nigeria Data Protection Act General Application and Implementation Directive, 2025 (“GAID”), pursuant to its powers under section 61 of the Nigeria Data Protection Act, 2023 (“NDPA”). The GAID is aimed at providing clarity and practical guidance on the implementation of the NDPA. However, where any inconsistency arises between the NDPA and the GAID, the provisions of the NDPA will prevail.¹

Regulatory oversight of the NDPC has intensified, with the NDPC actively sanctioning companies that consistently violate the NDPA.² Enforcement efforts are also gaining momentum, with private citizens instituting suits to enforce their rights under the NDPA. ³