Employee Privacy Policy - Template, Sample Form Pro · NG-law
✓ Valid in Nigeria · drafted to comply with local law
Create your Employee Privacy Policy - Template, Sample Form for use in Nigeria. Answer a few plain-English questions and the document fills in automatically as you go — then download it in Word and PDF, ready to sign or share. This version has been professionally rewritten to comply with local law.
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EMPLOYEE DATA PROTECTION AND PRIVACY POLICY
________
Effective Date: ________
This Employee Data Protection and Privacy Policy (the “Policy”) is issued by ________, a company duly incorporated under the laws of the Federal Republic of Nigeria, with registration number ________ and registered office at ________ (the “Employer”, “Company”, “We”, “Us” or “Our”).
§ 1. INTRODUCTION AND LEGAL BASIS
1.1 This Policy sets out the rules, practices and procedures relating to the personal data that the Employer, its affiliates and other related entities collect about you (the “Employee”, “You” or “Your”), and how such data is processed.
1.2 This Policy is issued in compliance with the Nigeria Data Protection Act, 2023, the Nigeria Data Protection Regulation, 2019 (as amended) and any subsidiary legislation, directives, frameworks or guidelines issued by the Nigeria Data Protection Commission, together with the Constitution of the Federal Republic of Nigeria, 1999 (as amended), the Labour Act (Cap L1, Laws of the Federation of Nigeria 2004) and all other applicable laws.
1.3 The Company recognises the confidential nature of the Personal Data it collects and is committed to ensuring the protection of all Personal Data and Sensitive Personal Data collected from You, in accordance with the principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity and confidentiality and accountability.
1.4 This Policy informs You of the Personal Data We collect, how We collect it, the lawful bases and purposes for which it is processed, Your rights, and Our commitment to protect Your Personal Data during and after Your employment with Us.
1.5 By signing this document, You acknowledge that You have read and reviewed this Policy and that You understand its terms and the applicable disclosures.
§ 2. DEFINITIONS
2.1 “Personal Data” means any information relating to an identified or identifiable natural person, such as a name, address, telephone number, bank details, email address, photograph, an identification number, location data, or any factor specific to the physical, physiological, genetic, psychological, cultural, social or economic identity of that person.
2.2 “Sensitive Personal Data” means Personal Data relating to a person’s genetic and biometric data, race or ethnic origin, religious or similar beliefs, health status, sexual orientation, political opinions or affiliations, trade union membership, and such other data as may be designated as sensitive under the Nigeria Data Protection Act, 2023.
2.3 “Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.
2.4 “Data Processor” or “Third Party Service Provider” means any party other than the Company or the Employee that processes the Employee’s Personal Data on behalf of, and on the instructions of, the Company.
2.5 “Processing” means any operation performed on Personal Data, whether or not by automated means, including collection, recording, organisation, storage, use, disclosure, transmission, erasure or destruction.
2.6 “Data Subject” means the Employee to whom the Personal Data relates.
§ 3. DATA PROTECTION OFFICER AND CONTACT
3.1 You may contact Us in relation to this Policy through Our Data Protection Officer, ________, whose contact details are as follows:
________
§ 4. COLLECTION OF PERSONAL DATA
4.1 As part of Your employment, We collect different categories of Personal Data from You, including but not limited to Your:
- contact details, such as address, telephone number and email address;
- date of birth;
- gender;
- marital status;
- curriculum vitae and qualifications;
- bank details, such as account name, account number, bank, Tax Identification Number and passport photographs;
- documents relating to Your employee benefits, insurance, allowances and pension;
- performance reviews, evaluations, appraisals, assessments and training records;
- warning or grievance complaints, notices or letters;
- details of guarantors, such as their names, contact details, passport photographs and means of identification;
- resignation or termination letters;
- any other Personal Data You provide.
4.2 You may also be required to provide certain Sensitive Personal Data, which includes but is not limited to Your:
- medical records or certificates;
- sexual orientation;
- religious or other beliefs, philosophical or political ideologies;
- criminal records;
- racial or ethnic origin;
- other Sensitive Personal Data We may lawfully request from time to time.
4.3 Sensitive Personal Data will only be processed where You have given explicit consent, or where the processing is necessary for the performance of obligations or the exercise of rights under employment law, or where otherwise permitted under the Nigeria Data Protection Act, 2023.
§ 5. LAWFUL BASES AND PURPOSES OF PROCESSING
5.1 We process Your Personal Data on one or more of the following lawful bases: (a) Your consent; (b) the performance of Your contract of employment; (c) compliance with a legal obligation; (d) the protection of vital interests; and (e) Our legitimate interests, where not overridden by Your rights and freedoms.
5.2 We collect and process Your Personal Data for purposes connected with Your employment, including but not limited to:
- processing Your recruitment, employment and onboarding;
- administering payment of salaries, allowances, benefits, pension and other entitlements;
- managing and maintaining accurate employment records;
- conducting performance reviews, evaluations, appraisals and training programmes;
- complying with applicable laws, regulations and statutory obligations;
- remitting and processing taxes, pension and other statutory contributions;
- enforcing disciplinary measures and addressing grievances;
- providing employment references where necessary;
- ensuring workplace health and safety;
- any other purpose reasonably necessary in relation to Your employment with Us.
§ 6. CONSENT
6.1 By signing this Policy, You consent to the collection, processing, use, storage and disclosure of Your Personal Data and Sensitive Personal Data in accordance with the terms of this Policy.
6.2 You acknowledge that such consent is given freely, specifically and voluntarily, and that You have the right to withdraw Your consent at any time by giving written notice to the Data Protection Officer, subject to any legal or contractual restrictions and reasonable notice. The withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal.
6.3 Where You withdraw Your consent, the Company may be unable to continue to provide certain employment benefits or fulfil certain obligations relating to Your employment.
§ 7. DISCLOSURE AND SHARING OF PERSONAL DATA
7.2 The Company will not share Your Personal Data with any Data Processor unless that Data Processor is bound by a written data processing agreement requiring it to comply with this Policy and the Nigeria Data Protection Act, 2023, and to maintain adequate security measures.
7.3 In certain circumstances, We may disclose Your Personal Data:
(I) where You grant Your unequivocal consent or permission to disclose Your Personal Data;
(II) in the case of a business transfer, merger or acquisition, or the sale and transfer of the Company’s assets or shares;
(III) to protect Our legal rights;
(IV) where We are legally required to do so, in which case disclosure may be limited to:
- fulfilling or complying with any applicable law, regulation or legal process such as subpoenas, court orders or requests from any administrative or government body;
- cooperating with any lawful investigation concerning any past or present Employee;
- detecting, preventing or addressing fraud, security or technical issues;
- bringing legal actions against any Employee who has violated the law;
(V) where disclosure is necessary to provide employment references;
(VI) where disclosure is necessary for the processing of the Personal Data;
(VII) in an emergency, to safeguard the physical safety of any person;
(VIII) for any other reason necessary in relation to Your employment with Us.
§ 8. CROSS-BORDER TRANSFER OF PERSONAL DATA
8.1 Where it is necessary to transfer Your Personal Data outside Nigeria, We will only do so in accordance with the Nigeria Data Protection Act, 2023, and where the recipient jurisdiction provides an adequate level of protection, or where an appropriate safeguard or a lawful basis for transfer exists.
§ 9. YOUR RIGHTS
9.1 As a Data Subject, Your rights in relation to Your Personal Data include:
(I) the right to be informed about the processing of Your Personal Data;
(II) the right of access to Your Personal Data;
(III) the right to correct or rectify any inaccurate or incomplete Personal Data;
(IV) the right to request the erasure of Your Personal Data, subject to legal limitations;
(V) the right to restrict the processing of Your Personal Data;
(VI) the right to object to the processing of Your Personal Data, including processing in violation of any law;
(VII) the right to data portability;
(VIII) the right to withdraw consent at any time;
(IX) the right to be informed of any rectification, erasure or restriction of processing carried out; and
(X) the right to lodge a complaint with the Nigeria Data Protection Commission.
9.2 You may exercise any of these rights by submitting a written request to the Data Protection Officer, and We will respond within the timeframe prescribed by law.
§ 10. DATA SECURITY
10.1 The Company takes the security of Your Personal Data seriously and implements appropriate technical and organisational measures to safeguard Your Personal Data and Sensitive Personal Data against unauthorised access, theft, alteration, destruction or unlawful processing.
10.2 The security measures taken by the Company include but are not limited to:
- technical security, such as limiting access through secure networks, passwords and encryption on computers containing Personal Data;
- physical security measures over cabinets, premises and other systems;
- restricting access strictly on a “need-to-know” basis.
§ 11. STORAGE AND DISPOSAL OF PERSONAL DATA
11.1 The Company will retain Your Personal Data for the duration of Your employment and thereafter for a period of ________ or for such longer period as may be required to comply with legal, regulatory, accounting or record-keeping obligations.
11.2 Upon expiry of the applicable retention period, Personal Data will be securely deleted, destroyed or anonymised.
§ 12. COMPLIANCE AND ENFORCEMENT
12.1 Every employee who has authorised access to an Employee’s Personal Data must comply with all provisions of this Policy. Non-compliance shall attract disciplinary measures, up to and including dismissal, depending on the circumstances of each case.
12.2 If any Employee wishes to make a formal complaint about any Data Breach or to challenge compliance with this Policy, such matters should be reported in the following manner:
________
§ 13. MODIFICATION OF THIS POLICY
13.1 We reserve the right to review and modify this Policy from time to time. Where We make any material change, We will notify You and, where required by law, obtain Your consent to the revised version.
§ 14. GOVERNING LAW
14.1 This Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria.
§ 15. DISPUTE RESOLUTION
15.1 Where any dispute arises from or in connection with this Policy, the parties shall first attempt to resolve it amicably through good faith negotiation.
15.2 Any dispute which cannot be amicably resolved shall be referred to arbitration in accordance with the Arbitration and Mediation Act, 2023, or any statutory re-enactment or modification thereof.
15.3 The arbitral tribunal shall consist of ________ arbitrator(s), who shall be appointed in the following manner:
________
15.4 The seat and venue of the arbitration shall be ________ and the proceedings shall be conducted in the English language.
15.5 Each party shall bear its own costs and expenses in relation to the arbitration, save where the tribunal awards costs against a particular party. The award of the tribunal shall be final and binding on the parties and may be enforced by any court of competent jurisdiction.
§ 16. ACKNOWLEDGEMENT AND CONSENT
16.1 I acknowledge that I have read, understood and agree to the terms of this Employee Data Protection and Privacy Policy, and I freely consent to the collection, processing and use of my Personal Data and Sensitive Personal Data in accordance with its terms.
EMPLOYEE:
Name: ________
Signature: ________
Date: ________
FOR AND ON BEHALF OF THE EMPLOYER:
Name: ________
Designation: ________
Signature: ________
Date: ________
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