Structured Interventions for Compliance, Trust, Governance and Resilience.

Organisations often have documents but cannot demonstrate that privacy governance operates in practice. Policies sit in document repositories; DPIAs have never been conducted; processing records are incomplete. When the NDPC inspects, the gap between policy existence and operational evidence becomes immediately apparent and immediately enforceable.

• Lawful basis documentation for every processing activity
• DPIA evidence for high-risk processing
• Records of Processing Activities (RoPA) — current and complete
• Breach readiness — 72-hour notification capability
• Data subject rights handling procedures
• Accountability records — timestamped, attributed, retrievable

As an NDPC-Licensed DPCO (NDPC/DCP/01784), SAC implements an end-to-end compliance architecture aligned with NDPA and GAID expectations — structured to the evidence standard the NDPC's inspection framework applies, not the standard that satisfies internal review.

Boards acknowledge privacy accountability under the NDPA but have no governance framework for measuring, reporting on, or evidencing their discharge of that accountability. Digital trust and data protection are managed operationally but invisible at the governance layer — leaving the board exposed to accountability it cannot demonstrate.

• Board-level data protection oversight structure
• Regular DPO reporting to the board or audit committee
• Digital trust KPIs in board governance agenda
• Board-visible accountability for NDPA obligations
• Audit committee digital trust briefings

As Nigeria's ISACA DTEF Certified Facilitator, SAC builds a board-level privacy and digital trust governance framework — from accountability structures to KPI dashboards — that makes board oversight structured, measurable, and reportable to the NDPC and external stakeholders.

When the NDPC inspects or internal auditors request compliance evidence, organisations scramble to produce records that should already exist. Evidence assembled under time pressure is structurally weaker than evidence built into the compliance architecture from the start — and auditors and inspectors can usually tell the difference.

• Contemporaneous, timestamped compliance records
• Attributed documentation (who approved, who actioned)
• Structured evidence pack formatted to NDPC's inspection framework
• Management action plans for identified gaps
• Evidence of remediation — not just intent

SAC conducts a structured audit evidence review, identifies and fills documentation gaps, formats the evidence pack to the NDPC's inspection standard, and builds the ongoing evidence management architecture that ensures future audit readiness without a pre-inspection scramble.

Most organisations could not execute an NDPA-compliant breach response today. The 72-hour notification clock starts running the moment a breach is discovered — not when it is investigated. Breach response plans that exist only as documents and have never been tested produce disorganised, delayed, and incomplete notifications that compound the original breach liability.

• 72-hour NDPC notification from moment of discovery
• Documented breach assessment process
• Data subject notification where required
• Breach register with timeline evidence
• Remediation records and post-breach review

SAC builds the breach response architecture — framework, protocols, roles, breach register, notification templates, and escalation procedures — and then tests it through a structured simulation. As a licensed DPCO with 24-hour response SLA, SAC can also be engaged as the first-call breach response resource when an incident occurs.

Organisations routinely share personal data with vendors — cloud platforms, payroll processors, marketing tools, IT support providers — without data processing agreements in place, without due diligence on the vendor's security posture, and without a formal assessment of the transfer risk. Under the NDPA, a controller is accountable for what its processors do with data on its behalf.

• Data Processing Agreements with all processors
• Processor due diligence and security assurance
• Third-party transfer risk assessments
• Sub-processor oversight and notification procedures
• Vendor privacy risk register and review cycle

SAC maps the organisation's data sharing relationships, identifies unprotected transfers, drafts DPA terms, conducts vendor privacy risk assessments, and builds the ongoing third-party risk management architecture that keeps the vendor estate NDPA-compliant across its lifecycle.

Multinationals, development organisations, and businesses using international cloud services are transferring personal data outside Nigeria without confirming whether the transfer is lawful under the NDPA. International data transfers without a lawful basis are a breach of the NDPA — and NDPC enforcement has begun targeting organisations with cross-border transfer exposures.

• Lawful basis for each international transfer
• Adequacy assessment for the recipient country
• Standard Contractual Clauses or equivalent where adequacy is not confirmed
• Transfer impact assessment for high-risk transfers
• Transfer records in the RoPA

SAC maps all international data flows, assesses each against NDPA transfer conditions, identifies unlawful transfers, designs the lawful transfer mechanism for each, and builds the ongoing transfer monitoring architecture — producing a transfer compliance framework that holds under NDPC scrutiny.

Organisations have not assessed whether they meet the DCPMI classification threshold — and therefore do not know if mandatory registration is overdue. Some have heard of DCPMI requirements but assume they do not apply. Most regulated entities, banks, hospitals, and public sector bodies meet the threshold. Registration is mandatory, not voluntary — and failure to register carries active enforcement risk.

• Threshold assessment against GAID criteria
• NDPC DCPMI registration application
• DPO designation and registration
• Annual renewal and compliance maintenance
• CAR filing by a licensed DPCO

SAC conducts the threshold assessment, prepares and submits the DCPMI registration application, manages NDPC correspondence, and supports the DPO designation — as a licensed DPCO authorised to act as the organisation's DPCO of record for registration and CAR filing purposes.

Following a gap assessment, internal audit finding, or regulatory notification, organisations receive lists of compliance gaps — but not a structured plan for closing them. Compliance remediation without a sequenced roadmap produces scattered, incomplete action that leaves material gaps unresolved while less critical items receive disproportionate attention.

• Prioritised remediation sequence with risk rationale
• Responsibility assignment for each action item
• Progress tracking with evidence requirements
• Board-visible remediation status reporting
• Independent verification of remediation completion

SAC designs a structured compliance remediation roadmap — gap-prioritised by regulatory risk, sequenced for operational feasibility, assigned with named responsibilities, and tracked with the evidence disciplines that allow independent verification of completion. Available as a standalone scoping engagement or as a follow-on to a SAC gap assessment.