Sending data out of the country.
WHY IT IS REGULATED
Data sent elsewhere may not receive equivalent protection.
WHAT COUNTS AS A TRANSFER
Storing data on servers abroad Using a service provider based elsewhere Allowing access from another country
WHY THAT LAST ONE SURPRISES PEOPLE
Remote access is a transfer, even with no copying.
WHAT NIGERIAN LAW BROADLY REQUIRES
A valid mechanism for transfers outside the country.
WHAT MECHANISMS TYPICALLY EXIST
A determination that the destination provides adequate protection Contractual safeguards Binding internal rules within a group Specific derogations, narrowly applied
WHY THIS MATTERS ENORMOUSLY HERE
Most cloud infrastructure, analytics and business tools are hosted abroad.
WHAT THAT MEANS
Nearly every Nigerian business makes transfers.
WHAT TO DO
Identify every transfer in your inventory Establish the mechanism for each Document it
WHAT TO CHECK WITH PROVIDERS
Where data is actually stored and processed Whether they offer contractual safeguards Whether they transfer onward
WHY ONWARD TRANSFERS MATTER
Your provider's providers extend the chain.
WHAT TO CONSIDER
Local hosting, where it is practical.
WHAT IT PROVIDES
Simpler compliance, and lower latency.
WHAT TO VERIFY
The current requirements, which evolve.
