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ARTICLE · 09 JANUARY 2026

Moving Personal Data Across Borders? What Your Startup Needs To Know

Tope Adebayo LP
Tope Adebayo LP
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For many Nigerian tech startups, the use of offshore cloud infrastructure and foreign service providers is unavoidable.

NigeriaPrivacy
Mosun Oke
Mosun Oke
Tolulope Oguntade
Tolulope Oguntade
Eyitayo Ajisafe
Eyitayo Ajisafe
Author LinkedIn connections

For many Nigerian tech startups, the use of offshore cloud infrastructure and foreign service providers is unavoidable. From hosting customer databases on overseas servers to using global SaaS tools for analytics, payments, and customer relationship management, cross-border data transfers are embedded in everyday operations.

What is often overlooked, however, is that under Nigerian law, transferring personal data outside Nigeria is not automatically lawful. The Nigeria Data Protection Act 2023 ("NDPA") and its General Application and Implementation Directive 2025 ("GAID") impose strict conditions that must be satisfied before such transfers can legally occur.

Historically, many startups transferred data offshore with limited scrutiny and little visible enforcement. That position has now changed. In 2024, the Nigeria Data Protection Commission ("NDPC") imposed an administrative fine of N766,242,500 on MultiChoice Nigeria for, among other violations, unlawful

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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