NDPA modules · Why you hold data
A balancing test you cannot finish is an answer too.
Eri began drafting the one for fraud screening and stopped after three minutes, because two facts nobody holds decide the outcome. Most tools would have written the paragraph anyway.
- Activities
- 12
- Wrong basis
- 1
- No basis at all
- 2
All twelve, sorted by the reason you gave
Choosing consent when the law already requires it is not a safe choice
It is the wrong one. Asking permission for something you must do anyway implies a choice that does not exist — and the moment somebody says no, you either ignore them or break the CBN’s rule.
Contract4
Legal duty1
Legitimate interest3
Consent2
Nothing recorded2
Vital or public interest0
Empty, and it should be. These are for emergencies and statutory functions — a register that uses them casually is a register nobody checked.
Six bases, six prices
Every reason you can give costs you something later
Which is the part nobody explains when they hand you a dropdown. Consent can be taken back tomorrow. Legitimate interest owes a test. A legal duty owes the section number of the law you are obeying.
Asiri writes the price next to the choice, and then holds you to it — a legitimate interest with no completed test does not count as recorded.
Consent
A real choice, freely given, and provable. If saying no changes nothing about the service, it was never consent.
Can be withdrawn tomorrow, and withdrawal must reach every system
Contract
Necessary to deliver what somebody signed up for. Necessary, not merely convenient or commercially sensible.
Ends when the contract does
Legal duty
A law obliges you. The CBN’s identity rules, the seven-year retention, tax records.
You must cite the instrument and the section
Legitimate interest
Your interest, weighed against what the person would reasonably expect. The most flexible and the most audited.
Owes a completed balancing test, or it does not count
Vital interest
Someone’s life or physical safety. Genuinely rare, and never a fallback for convenience.
Expect to justify the emergency
Public interest
A statutory function or task carried out in the public interest — usually where a regulator has assigned it.
Needs the mandate, in writing
ACT-002 · owned by Ngozi Eze · draft halted 26 Jul 15:40
Three minutes in, Eri put the pen down
A balancing test that cannot say what the processing costs the customer is not a test, it is a paragraph. So the draft stops, the two unknowns are named, and each one is assigned to somebody who can answer it.
If the answer to the first is “a flag can stop a payment with no person involved”, this stops being a balancing test at all and becomes an impact assessment — a different obligation, with the NDPC to consult.
What the screening actually does when it flags someone
The register says “transaction history”. Whether a flag blocks a payment, delays it, or only alerts a person decides whether this is a balancing test or an impact assessment.
Assigned to Segun Okoro · answer needed before the test resumes
Whether anyone has ever been refused because of it
No outcome data is connected. Without it, the cost to the customer is a guess, and a guess cannot be weighed against anything.
Assigned to Ngozi Eze · needs the decline log
Whether a flag can stop a payment without a human
If it can, the customer has a right to contest it, and an impact assessment comes before the balancing test rather than after.
Blocks the test outright
Who owns the screening logic itself
The register names an owner for the activity, but nobody is named for the rules inside it. An unowned rule cannot be defended.
Unassigned — raised as a finding
Find out which of your reasons would survive being read aloud
Most companies have one activity on the wrong basis and two with none at all. Knowing which is a morning's work, not a project.