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Oluso

NDPA and CBN-style checks

Evidence in the project, not a legal opinion.

NDPA

The NDPA checklist looks for signs of the Nigeria Data Protection Act, 2023: principles, consent, a notice, a DPIA, a data protection officer, data subject rights, security measures, a 72-hour breach note, cross-border transfers, and registration.

CBN-style controls

The CBN-style checklist is a fintech control list: ownership, incident response, vulnerability management, multi-factor access, logging, backups, vendors, encryption, an authorised testing programme, training, classification, API authentication, fraud monitoring, and change review. A gap means the words were not in the files Oluso read.