A.     INTRODUCTION

The Nigeria Data Protection Commission (NDPC or “the Commission”) on February 14, 2024 issued the Guidance Notice (Notice) for the Registration Of Data Controllers and Data Processors Of Major Importance (DCMI and DPMI) pursuant to Sections 5d, 6(c), 44, 45 and 65 of the Nigeria Data Protection Act 2023 (NDPA).
This Guidance Notice serves to provide clarity on the designation of DCMI and DPMI, and their subsequent registration. The Notice outlines the criteria for the designation of businesses, entities and organizations as DCMI and DPMI, and registration with the NDPC. In this Alert, we summarize the key points from the Notice.

B.     DESIGNATION CRITERIA AS DCMI AND DPMI

Section 65 of the NDPA defines a DCMI and DPMI as a data controller or data processor that is domiciled, resident in, or operating in Nigeria and processes or intends to process personal data of more than such number of data subjects who are within Nigeria, as the Commission may prescribe, or such other class of data controller or data processor that is processing personal data of particular value or significance to the economy, society or security of Nigeria as the Commission may designate.
By Paragraph 1(1) of the Notice, Data controllers or processors are deemed to have “particular value or significance to the economy, society or security of Nigeria” and designated as DCMI and DPMI if they maintain a filing system (analog or digital) for processing personal data, AND:…..

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