NDPA modules · How long you keep it
Some rules you cannot change. Others you never set.
Ten categories, ten different answers. Four are fixed by the CBN and by money-laundering law and will not move for anybody. Two have no answer at all — which is how 40,119 records get kept forever by accident.
Transaction records · CBN
7 years
After the transaction, not after the account closes. Asiri will refuse a deletion request against this and explain why in writing.
Marketing lists · nothing decided
Forever
40,119 records with no deletion date, including people who withdrew consent. Nobody chose this. Nobody chose anything, which is the same thing.
No end date on file
All ten, on one axis
Thirty days and seven years on the same page
The axis below is logarithmic, because camera footage and transaction records differ by a factor of eighty-five and a linear scale would render one of them invisible. Every bar carries its real rule in words.
Transaction records
CBN record-keeping rules7 years after the transactionStaff records
Employment and tax law6 years after they leaveIdentity documents and BVN
Money laundering regulations5 years after the account closesAccount and contact details
Money laundering regulations5 years after the account closesSupport tickets and call recordings
Your own choice2 yearsPaper account-opening forms
Your own choice · 2,400 overdue18 months, then shreddedDeclined applications
Your own choice12 monthsBranch and ATM camera footage
Your own choice30 daysMarketing lists and open history
Nothing decidedNo end date · 40,119 recordsAgent app events
Nothing decidedNo end date
Four legal holds, live now
A hold beats a rule, and a rule beats a request
When there is a dispute, an investigation or a court order, deletion stops — even if the retention period has expired and even if somebody has asked for erasure. Asiri holds the record and writes down which hold is doing it.
The dangerous version is a hold nobody lifts. Each of these carries the person who placed it and the condition that ends it, so it cannot quietly become permanent.
Two transaction records under dispute
A merchant chargeback is open. The seven-year rule already covers these, so the hold changes nothing yet — but it survives the rule expiring.
Ends when the chargeback closes · placed by Tunde Adeyemi
One identity file, fraud investigation
Held past the five-year point at the request of the risk team. This is the one to watch, because the rule has already run out.
Ends on the investigation’s conclusion · placed by Segun Okoro
Camera footage from one branch
Thirty days would have deleted it last week. A personal injury claim means it stays until the claim resolves.
Ends when the claim resolves · placed by Ngozi Eze
One erasure request, partly refused
Adaeze Nwosu asked for deletion. Most of what you hold is under the CBN rule, so the refusal is lawful — and has to be explained to her in writing.
Explanation sent · request DSR-2026-0131
What deletion actually reaches
Deleting the row is the easy part
A record lives in more places than the system that owns it. Asiri lists every one of them for each category, including the ones it cannot reach — because a deletion that misses the backup is a deletion you cannot honestly claim.
The system of record
Core banking, deleted on schedule with the deletion itself written to the audit trail.
Connected processors
Support, marketing and analytics tools receive the deletion through their own APIs and confirm it.
Backups, with a lag
S3 copies roll off after 90 days. Asiri states the lag rather than claiming the data is gone the same afternoon.
The collections agency spreadsheet
A third party with no integration. Deletion there is a manual task with a named owner and a due date, tracked like any other.
Paper in branch filing cabinets
2,400 account-opening forms are past their shred date. Asiri counts them as still held, because they are.
Find the category nobody set a date for
There is almost always one, it is almost always marketing, and it is almost always the largest table you own.