NDPA modules · Data leaving Nigeria
3,100 agents leave the country every night.
Nine transfers out of Nigeria. Eight have a mechanism on file. The ninth carries app events for every agent you have to a company in the United States — nothing on file at all, and not one of them has been told.
- Transfers
- 9
- Nothing on file
- 1
- People in it
- 3,100
- Mechanism on file
- Draft only
- Nothing on file
- Ireland: AWS EMEA. Mechanism on file.
- United States: Zendesk · Mailchimp · Segment. Nothing on file.
- United Kingdom: Checkout · Holdings. Mechanism on file.
- Germany: Sentry. Mechanism on file.
- Kenya: Fraud consortium. Draft only.
The register, as it stands
Every line carries an expiry, because mechanisms lapse
Standard contract clauses signed in 2024 are not permanent. Asiri counts down each one and reopens the transfer for review before it dies, rather than after somebody notices in an audit.
| Ref | What leaves | Where it goes | Mechanism | State |
|---|---|---|---|---|
| TR-014 | Agent app analytics | Segment · United States | Nothing on file | No mechanism |
| TR-012 | Fraud consortium feed | Regional consortium · Kenya | A one-off exception | Draft |
| TR-004 | Core database hosting | AWS EMEA · Ireland | Standard contract clauses | 63 days left |
| TR-011 | Error monitoring | Sentry · Germany | Standard contract clauses | 81 days left |
| TR-009 | Marketing automation | Mailchimp · United States | Standard contract clauses | Assessment open |
| TR-007 | Customer support platform | Zendesk · United States | Standard contract clauses | 200 days left |
| TR-002 | Card processing | Checkout Ltd · United Kingdom | Adequate country | No expiry |
| TR-013 | Group reporting to parent | LagosPay Holdings · United Kingdom | Group-wide rules | No expiry |
| TR-001 | Old analytics vendor | Mixpanel · United States | Standard contract clauses | Ended Feb 2026 |
The retired line stays visible. A transfer that ended in February still processed data for two years, and an auditor asking about 2025 needs to find it.
Five ways to move data lawfully
Only one of them survives without paperwork
And it is the one you do not choose — whether the NDPC considers the destination adequate. Everything else is a document you sign, keep current, and have to produce.
A one-off exception is exactly that. Using a derogation as your standing arrangement for a recurring feed is the mistake the fraud consortium draft is currently making.
Adequate country
The NDPC has decided the destination protects data comparably. No paperwork, and not your decision to make.
Used for 2 transfers · United Kingdom
Standard contract clauses
The recipient signs binding terms. Signed once, then reviewed — clauses referencing a superseded framework are worth nothing.
Used for 5 transfers · expiries tracked
Group-wide rules
Binding rules across a corporate group, approved rather than merely written. Slow to obtain, durable once held.
Used for 1 transfer · parent company
A one-off exception
A derogation for a specific, non-repeating transfer. Explicit consent, a contract necessity, a legal claim.
Claimed for 1 draft · wrongly, if it recurs
Nothing on file
Not a mechanism. It is the state of a transfer that started before anyone asked, which is how most of them start.
Currently 1 transfer · 3,100 people
TR-014 · Segment · nothing on file
A contract is not a transfer impact assessment
Signing standard clauses says what the recipient promises. The assessment asks a harder question: whether the law where the data lands would let a government take it anyway, and whether your clauses would survive that.
For the agent analytics feed there is neither. Asiri has it as the single most exposed thing in your register, and it does not soften that with a colour.
What law applies where it lands
Whether a public authority there can compel disclosure, and whether the recipient would be permitted to tell you if it happened.
How sensitive the data actually is
Agent app events sound harmless until you notice they include location, device and working hours for 3,100 named people.
What extra protection you added
Encryption you hold the keys to, pseudonymisation, or a shorter retention. Something beyond the recipient’s promise.
Whether you would still do it
The honest conclusion, written down and signed. An assessment that always concludes yes is a formality, and reads like one.
Find the transfer nobody papered before the NDPC does
Asiri reads where each connected system is hosted and compares it against your transfer register. A vendor that quietly moved region shows up as a new transfer, not as nothing.