The Nigeria Data Protection Act (NDPA) represents a significant turning point for data privacy in the country. For the first time, we have a clear and comprehensive legal framework that outlines how personal data should be collected, used, and protected. For organisations, it’s not just about checking compliance boxes but about building trust in how they handle personal information, giving data subjects more control over their data, and showing that Nigeria is ready to meet global standards in the digital economy.
Regulatory scrutiny around data privacy is now a reality that organisations in Nigeria, in particular, must deal with. Since the NDPA came into force in 2023, the Nigeria Data Protection Commission (NDPC) has intensified its enforcement role. According to the Commission’s 2024 Annual Report, more than 2,100 organisations across 24 sectors, from advertising and consumer goods to fintech and healthcare, were audited to assess their level of compliance.
In the same year, 213 separate cases of alleged privacy violations were opened, with healthcare, telecommunications, banking, fintech, and hospitality identified as particularly high-risk. The message is clear. Non-compliance comes with real costs, as shown by the ₦555.8 million fine imposed on Fidelity Bank in August 2024 for breaches of data protection obligations, and more recently by the ₦766 million penalty levied against MultiChoice in July 2025. These landmark fines mark a shift towards real accountability in how personal data is handled in Nigeria.
For many organisations, however, the compliance journey feels overwhelming. The NDPA is broad, the NDPC is active, and resources are often limited. Trying to fix everything at once is not a pragmatic approach. The more innovative approach is to start where the risks are highest, the areas where most organisations are currently struggling. This is where the percentages from the Data Protection Compliance Organisation (DPCO) Survey Data in the NDPC’s 2024 Annual Report come in. They don’t exist for curiosity’s sake; they reveal where organisations, across the board, are falling short. In other words, they highlight where you will get the most impact if you act first.
Strategic Move 1: Bridging the Awareness Gap (48.4%)
Almost half of the DPCOS surveyed admitted that a lack of awareness is the leading cause of insufficient documentation among data controllers and processors. And it’s not hard to see why. Many employees don’t fully grasp what counts as personal data, what their responsibilities are under the NDPA, or how ordinary actions can expose the organisation to risk. Something as simple as exporting customer records to Excel and sending them over WhatsApp might seem harmless, but under the NDPA, it’s a clear exposure point.
The first strategic move, then, is to build awareness deliberately and consistently. The quickest win is to run awareness campaigns that swap legal jargon for real-world scenarios staff can relate to. Employees respond better when they see how compliance connects to their daily work. Role-based guides are equally effective: your Finance team needs to understand the risks tied to financial records, while HR should focus on employee data and consent processes.
A particularly practical approach is to appoint “privacy champions” in each department. These are not compliance experts but first points of contact who can answer simple questions, flag risks early, and bridge the gap between central compliance functions and operational staff. Embedding NDPA awareness into onboarding for new hires also sets the right tone from day one. When privacy becomes part of the organisational DNA, compliance stops being a burden and starts becoming second nature.
Integrating Data Protection Assessments (43.1%)
The second gap, reported by 43.1% of DPCOs, is the neglect of Data Protection Impact Assessments (DPIAs). This is concerning because DPIAs are intended to identify risks before they escalate into regulatory, reputational, or financial crises. Yet many organisations avoid them, often because they believe the process is too complex or time-consuming.
The truth is, DPIAs don’t need to be complicated. A simple starting point involves four basic questions:
1. What data are we collecting?
2. Why are we collecting it?
3. What could go wrong?
4. What measures do we have in place to mitigate the likelihood and/or impact should something go wrong?
Organisations can quickly identify red flags by framing the exercise this way without drowning in paperwork. Running a DPIA pilot on a live project is a powerful way to prove its value internally. For example, if your organisation is rolling out a new HR management system or upgrading customer relationship management software, apply the DPIA process to that project. The outcome will highlight risks and show how early intervention prevents bigger issues later.
Embedding DPIA checkpoints into your project management process is another quick win. This means privacy becomes part of your standard project review cycle, not an afterthought. And if your internal capacity is limited, many DPCOs offer DPIA facilitation as part of their services, helping your team learn while delivering immediate results. In short, skipping DPIAs is a false economy; adopting them early is a strategic, cost-saving move.
Overcoming Budget Constraints (34.1%)
The third challenge organisations face, cited by 34.1% of respondents, is the perceived cost of compliance. Many leaders still see data protection as an expensive “cost centre.” But this mindset overlooks the fact that some of the most effective compliance measures require little to no financial investment.
The quick win here is to leverage what you already have. Instead of rushing to buy new software, revise existing HR, IT, and legal processes to integrate privacy checks. Policies and templates already in circulation can be updated to reflect NDPA requirements without additional cost. Assigning an internal privacy lead or data protection officer, even as a part-time responsibility, ensures accountability without needing to create a new full-time role immediately.
Phasing implementation also makes compliance manageable. For example, you could focus on awareness in Q1, complete your data inventory in Q2, and begin systematic DPIAs in Q3. Breaking the roadmap into milestones spreads both effort and cost. And finally, don’t overlook free resources. The NDPC regularly publishes guidance, FAQs, and templates. These are designed to help organisations comply without heavy consultancy bills. Compliance doesn’t have to break your budget; it requires structure, prioritisation, and intentionality.
Why These Three (3) Strategic Moves Matter
Awareness, DPIAs, and cost-smart compliance are not just “quick fixes.” They are the foundation for long-term resilience. Closing the awareness gap ensures your people don’t unintentionally put your organisation at risk. Normalising DPIAs ensures risks are caught before they escalate. Addressing the budget barrier ensures compliance becomes sustainable rather than a one-off project. Together, they reflect the spirit of the NDPA itself: embedding privacy into the fabric of how organisations operate.
Conclusion
The future of digital business in Nigeria will be defined by how organisations respond to the NDPA. The law has raised expectations, and the NDPC is enforcing those expectations with real consequences. But compliance is not just about avoiding fines. It’s about protecting people, earning trust, and strengthening your reputation in a competitive digital economy.
Focusing on these three strategic moves—closing the awareness gap, embracing DPIAs, and managing compliance costs smartly—can help organisations build a strong foundation without being overwhelmed. These moves are practical, scalable, and realistic. They help you start small but think big, creating a compliance culture that can grow with your organisation.
At pcl., we help organisations navigate this evolving landscape with confidence. From readiness assessments and DPIA facilitation to policy development, training, and regulatory alignment, we support businesses in building sustainable, risk-based data protection programmes. Whether you’re just starting your compliance journey or strengthening an existing framework, our approach is practical, industry-aware, and focused on what matters most: protecting people, enabling trust, and driving long-term value through privacy.
Written by:
Ikenna Ndukwe
Consultant