NDPA modules · Requests
Without undue delay. Counted from when they asked, not when you noticed.
The Act names no number of days, which is harder rather than easier — a schedule is not a defence, and answering inside one is not proof of anything. The queue below is drawn against itself. Two of them have had nothing sent at all, and one of those because the person who owned it was on leave.
- Still open
- 10
- Nothing sent yet
- 2
- Median close
- 11d
Chinedu Okafor
Wants to see it · by email
Day 36 · nothing sentHalima Sani
Wants us to stop · from the website form
Day 33 · nothing sentOlumide Balogun
Wants it paused · in the app
Day 15Zainab Yusuf
Objects to a machine deciding · by email
Day 13Ibrahim Bello
Wants it deleted · by phone
Day 11Funmilayo Adeyemi
Wants a copy to take · by email
Day 8Emeka Obi
Wants it corrected · in the app
Day 4Adaeze Nwosu
Wants it deleted · by email
Day 1Grace Nnamdi
Taking back permission · from the website form
Arrived todayMusa Danjuma
Wants to see it · by email
Arrived todayBlessing Uche
Wants to see it · by email
Answered on day 14Tobi Ajayi
Wants it corrected · in the app
Answered on day 11Kemi Alabi
Wants it deleted · by email
Day 9 · partly refused
Bars are drawn from the date the request arrived, in whichever channel it arrived — email, the app, the website form, or a phone call a support agent wrote down. A request made badly is still a request.
Eight things people can ask for
Not every request is a request for data
Two of the eight are refusals of something you are doing — objecting, or objecting to a machine deciding. Those are the ones support teams file as complaints and lose, and they are held to the same standard as the rest.
§34
Wants to see it
Everything you hold, and where it came from. The most common, and the one that exposes systems nobody listed.
§34
Wants it corrected
And the correction has to reach every system that copied the wrong value.
§34
Wants it deleted
Usually a partial refusal, because the CBN makes you keep account records for seven years.
§38
Wants a copy to take
Machine-readable, portable to a competitor. Not the same as a printout.
§36
Wants us to stop
An objection. Processing pauses while you decide whether your grounds override theirs.
§35
Wants it paused
Restriction — you keep it but stop using it, usually while a dispute is open.
§37
Objects to a machine deciding
They are entitled to a person. If your appeal route is only planned, you cannot honour this.
§26
Taking back permission
Withdrawal. It must reach the system that acts on it, not just the consent record.
Before you answer
Handing the file to the wrong person is the breach, not the delay
Checking who is asking is a step, and the clock does not stop while you do it. Asiri records what you checked and what you accepted, so a later complaint can be answered with the record rather than a recollection.
It also refuses to let you ask for more identification than you need. Demanding a passport scan to confirm an email address is its own violation.
The request arrives, wherever it arrives
Email, app, web form, or a phone call written down by support. Asiri timestamps the arrival, not the triage.
Match it to a person in the register
One identity, every system they appear in. If no match is found, that is recorded too — you cannot answer for someone you do not hold.
Check who is asking, proportionately
Enough to be sure, no more. Asiri warns when the identification asked for exceeds what the request needs.
Gather from every system that holds them
Including the ones with no API, which are listed as manual rather than skipped.
Answer, and record the refusals in writing
What you gave, what you withheld, and the statutory reason for each. That record is the defence if they complain.
DSR-2026-0114 · day 36
An export is not an answer
Chinedu Okafor asked for everything you hold. Six systems answer instantly. The seventh is a spreadsheet at a collections agency, and no export would ever have reached it — which is why Asiri lists the places it cannot reach instead of quietly omitting them.
Core banking
AnsweredName, account reference, stated date of birth, last transaction date. Read in four seconds.
Support conversations
Answered31 tickets, including two where he shared health information nobody asked for.
Marketing email
AnsweredAudience membership and open history — which he did not know you held.
Collections agency spreadsheet
Cannot reachAn arrears file held by a third party with no integration. Asiri names it as a manual gather with a named owner and a date, rather than leaving it out of the answer.
Every request answered from the register, with the refusals explained
Including the partial refusals — where the CBN makes you keep what somebody has asked you to delete, and you have to say so in writing.