Contents

1. Summary
   1. Facts
   2. Holding
2. Comment
3. Further resources
4. The Decision

Summary

Electronic Settlement Limited has been fined N5 million by the National Information Technology Development Authority (NITDA) for a data breach.

Facts

Electronic Settlement Limited is an independent, private sector led, limited liability company located in Lagos, Nigeria focused on providing innovative, dependable, easy-to-use, affordable and secure payment solutions to everyday financial problems in Africa.

Acording to NITDA an investigative process instituted against the firm and involved an analysis of the company’s applications and websites; visit to the company’s office in Lagos, review of its technical documents as submitted to the Agency and interrogation of its officials by NITDA investigation team in Abuja.

According to NITDA, at the end of the process, it was established that there was a data breach involving the company.

Holding

NITDA held that the firm would be under a six-month information technology oversight by NITDA. Additionally;

• ESL is fined N5million.
• a clear data security and governance document is drawn up between the Electronic Settlement Limited and all its Information Technology services vendors identifying roles, responsibilities and processes involved in securing and protecting personal data.
• The company conducts regular NDPR training for all staff, publish and implement appropriate policies as required by the NDPR.
• ESL submits 2020/2021 regulatory audit as required by Article 4.1.6 of the NDPR, conducted by a Data Protection Compliance Organization (DPCO) as licensed by NITDA.
• ESL conducts Data Protection Impact Assessment on some data-intensive applications and products.

Comment