NDPA modules · What you do with data
Nobody has ever filled in a register honestly from memory.
So Asiri writes it from your connected systems and leaves the gaps where they are. Twelve activities below. Four of them are not fit to file, and the register says which.
- Activities
- 12
- Blocking the filing
- 4
| Ref | Activity | Who decides | Sensitive data | State |
|---|---|---|---|---|
| ACT-001 | Running customer accountsOperations · 8 systems | You decide | BVN, ID numbers | |
| ACT-002 | Anti-fraud screeningRisk · 4 systems | You decide | Transaction history | Balancing test pending |
| ACT-003 | Identity checks at sign-upOperations · 5 systems | You decide | Face match, BVN, ID | Unlawful basis |
| ACT-030 | Marketing to lapsed customersGrowth · 2 systems | You decide | — | No legal reason |
| ACT-031 | Referral programmeGrowth · 2 systems | You decide | — | No deletion date |
| ACT-012 | Product analyticsProduct · 3 systems | You decide | — | |
| ACT-020 | Payroll and HR recordsPeople · 3 systems | You decide | Health, bank details | |
| ACT-021 | Recruitment and applicationsPeople · 2 systems | You decide | ID documents | No deletion date |
| ACT-040 | Processing for partner banksPartnerships · 5 systems | On their behalf | Account data | |
| ACT-050 | Agent performance scoringOperations · 2 systems | You decide | — | Still a draft |
| ACT-010 | Support conversationsSupport · 4 systems | You decide | Whatever people share | |
| ACT-011 | Call recording for qualitySupport · 2 systems | You decide | Voice recordings | No deletion date |
Written from 14 connected systems. Last read 6 minutes ago — the register is never older than the newest read.
How it knows
Every row names the system it came from
Which is the difference between a register and a spreadsheet. An auditor can follow any line back to the read that produced it, and the read carries a timestamp rather than an assurance.
- Read, not typed
9
Activities whose fields came from a connected system rather than a person filling in a form.
- Attested by a person
3
Where no system can answer — purpose and lawful reason are judgements, and the register names who made them.
- Systems feeding it
14
Core banking, identity, marketing, support, analytics, backups. Each read is dated.
- Oldest read
2h
Marketing email syncs hourly. Nothing in the register is presented as fresher than its source.
The four that block you
A gap is not a to-do. It is a reason the return will not go
Most tools let you file with a blank field. Asiri holds the filing until the blank is either filled or deliberately signed off as an accepted gap — because the NDPC reads the return, not your intentions.
- Blocks filing
ACT-030
Marketing to lapsed customers
No lawful reason recorded, and no deletion date. It has been running for nine months against a list of 40,100 people.
- Blocks filing
ACT-003
Identity checks at sign-up
Recorded as consent when the CBN requires it — which makes consent the wrong basis, not merely a weak one.
- Blocks filing
ACT-002
Anti-fraud screening
Legitimate interest claimed, balancing test never completed. Eri stopped drafting it because two facts are missing.
- Blocks filing
ACT-050
Agent performance scoring
Still a draft, but the scoring is live in production. The register shows the state, not the intention.
Review dates
A register nobody re-read is a register that is wrong
Four activities are past their review date, and one has never had one. Asiri does not quietly roll the date forward — an overdue review shows as overdue until a person looks at it and says so.
When a connected system starts reading a new field, the activity that uses it reopens for review automatically. Nothing about your processing changes silently.
Identity checks at sign-up
OverdueMarketing to lapsed customers
OverdueReferral programme
OverdueCall recording for quality
Due Jul 2026Agent performance scoring
Never reviewed
Connect one system and watch the first rows appear
Most companies find two activities nobody had written down and one they had forgotten was still running.