NDPA modules · Policies and notices
Your notice is a promise about a register you have since changed.
Asiri reads it line by line against your own records. Watch: it takes about eight seconds to find the two sentences that are no longer true.
How LagosPay uses your information
POL-001 · v4 · 22 Jun 2025We collect your name, phone number, date of birth and BVN when you open an account, because the Central Bank requires us to know who you are.
Who we share it with
We share information with four partners: our hosting provider, our support platform, our identity checker and our payments processor.
How decisions are made
Our team reviews applications and may ask you for more information before approving an account or a loan.
How long we keep it
We keep your records for as long as your account is open and for seven years afterwards, as our regulators require.
What it would say instead
Asiri will not publish a sentence your register contradicts
Where notice and register disagree, the notice is the thing that is wrong — the register is read from your systems, the notice was typed by a person thirteen months ago. Here is the replacement wording, drafted from the records themselves.
We share information with four partners.
Untrue since February. Precise-sounding wording that a regulator can disprove in one query is the worst kind of error.
We share information with five companies. One of them, Segment, is in the United States and receives events from our agent app.
Named, counted, and the country stated. Drawn from PRO-004 and TR-014 rather than from memory.
Our team reviews applications.
True in June 2025. A credit model now decides on loans without a person seeing the application at all.
Some loan decisions are made automatically by a computer model. You can ask for a person to look at it again, and we will tell you what the model weighed.
Section 37 requires both the disclosure and the route to a human. Held until DPIA-2026-0004 fixes what the model is permitted to do.
Five versions, and who each one binds
An old consent covers the old wording only
Which is why every version is kept exactly as published, never as edited. Eighteen thousand four hundred people agreed to v2. If v5 materially widens what you do, their agreement does not stretch to cover it — and Asiri can tell you precisely who is in that position.
Live · published 22 Jun 2025
v4 · plain-language rewrite
Cut from 2,400 words to 900. The version most of your customers have actually read to the end.
Review due Jul 2025
Thirteen months overdue
Not a formality. Two things changed in your register since, and the notice still describes the old arrangement.
Pending
v5 · automated decisions paragraph
Blocked until DPIA-2026-0004 is approved, because the wording depends on what the model is finally permitted to decide.
Superseded · Mar 2024
v3 · added the agent network
Kept as published. The consent records that reference it still point here, not at v4.
Superseded · Jan 2023
v2 · the version Halima agreed to
18,400 people consented against this wording. If v5 widens the purposes, their agreement does not carry over.
Seven things it has to tell them
Written for the person reading it, not the regulator reading it
A notice that survives legal review and defeats its reader has failed the actual test, which is whether somebody understood what they agreed to. v4 went from 2,400 words to 900 and said more, not less.
Who you are, and how to reach a human
Including your data protection officer by role, and an address that is answered. A form that goes nowhere fails this.
What you collect, specifically
“Certain information about you” is not a disclosure. BVN, date of birth, phone number — the actual fields.
Why, and on what lawful basis
Purpose by purpose. Where you rely on legitimate interest, say so and say they can object to it.
Everyone who receives it
Named, or categorised tightly enough to be meaningful. This is the failure that is easiest for anyone at all to catch.
Whether it leaves Nigeria, and how it is protected
Country and mechanism. “We may transfer data internationally” tells a reader nothing they can act on.
How long you keep it
In periods a person can picture. Seven years after closure is a real answer; “as long as necessary” is not.
Their rights, and how to use them today
Access, correction, erasure, objection, withdrawal, and a route to the NDPC — each with the link that actually starts it.
Read your own notice against your own register
It takes minutes and it usually finds one recipient nobody listed. That is the finding a regulator reaches for first, because checking it needs no expertise at all.