Introduction
The proliferation of online loan apps has become a necessary
evil for many low-income Nigerians, who feel compelled to borrow to
shield against the effects of the harsh economic realities in the
country, especially since the COVID-19 pandemic. The requirements
for tangible or non-tangible collaterals including proper
documentation for any loan transaction by traditional banks are
becoming less patronised, and therefore such loans which can be
easily accessed online becomes a preferred choice for many.
However, in recent times, these digital lending platforms have
resorted to unprofessional measures of harassment, cyberbullying,
and breach of data privacy of their customers who may have
defaulted in their loan(s) repayment.1 In light of these
events, personal data protection and privacy have become issues of
great concern for a number of stakeholders. In a bid to address
this issue and tailor the legal guidelines responsible for
regulating this