Privacy Policy

We collect the following categories of personal data:

• Contact and identity data

  Name, job title, employer, email address, telephone number, business address.

• Enquiry and engagement data

  The content of your enquiry, demand or support request, meeting notes, and records of our correspondence with you.

• Event and marketing data

  Event or webinar registration details, attendance records, marketing preferences and subscription status.

• Recruitment data

  CV, work history, qualifications, references, right-to-work information and interview records.

• Client project data

  Personal data contained within client systems we are engaged to migrate, support, configure or manage, handled strictly under the client’s instructions.

• Technical and usage data

  IP address, browser type, device information, pages visited and referring source, collected through cookies and similar technologies.

We do not knowingly collect personal data from children. Where we become aware that we hold such data without appropriate consent, we delete it.

• Directly from you

  When you complete a form on our website, email or call us, request a demonstration or proposal, subscribe to updates, register for an event, or apply for a role.

• Automatically

  Through cookies and similar technologies when you use our website, subject to your cookie choices.

• From third parties

  Our clients and partners, recruitment agencies, publicly available business sources and professional networks.

1. 01

   Responding to enquiries and providing proposals

   Personal data used

   Contact, identity, enquiry data

   Lawful basis (NDPA 2023)

   Steps at your request prior to entering a contract;Legitimate interest

2. 02

   Delivering contracted services to clients

   Personal data used

   Contact, engagement and project data

   Lawful basis (NDPA 2023)

   Performance of a contract;Legitimate interest

3. 03

   Managing our client and supplier relationships

   Personal data used

   Contact, identity, correspondence

   Lawful basis (NDPA 2023)

   Performance of a contract;Legitimate interest

4. 04

   Sending marketing communications, event invitations and newsletters

   Personal data used

   Contact and marketing data

   Lawful basis (NDPA 2023)

   Consent, which you may withdraw at any time

5. 05

   Recruitment and candidate assessment

   Personal data used

   Recruitment data

   Lawful basis (NDPA 2023)

   Steps prior to a contract of employment;Consent;Legal obligation

6. 06

   Website operation, security and analytics

   Personal data used

   Technical and usage data

   Lawful basis (NDPA 2023)

   Legitimate interest;Consent for non-essential cookies

7. 07

   Meeting legal, regulatory, tax and audit obligations

   Personal data used

   All relevant categories

   Lawful basis (NDPA 2023)

   Compliance with a legal obligation

Where we rely on legitimate interest, we have assessed that our use of your data is proportionate and does not override your rights.

Much of our work involves designing, migrating, securing and supporting systems for corporate and public-sector clients. Where personal data resides in those systems, our client is the data controller and we act solely as a data processor. In that role we:

• Process personal data only on the documented instructions of the client, as set out in the applicable agreement, statement of work or purchase order;
• Do not use client personal data for our own purposes, and do not sell personal data under any circumstances;
• Apply the technical and organisational security measures agreed with the client and required by law;
• Notify the client without undue delay of any personal data breach affecting their data;
• Do not engage a sub-processor without the client’s prior authorisation, and bind every sub-processor to terms no less protective than our own;
• Return or securely delete the data at the end of the engagement, on the client’s instruction.

If your personal data is held in a client system we support, please direct your request to that organisation in the first instance; we will assist them in responding.

• Our clients, where we act as their service provider or processor;
• Cloud and technology providers who host our systems, principally Microsoft, under written data protection terms;
• Professional advisers, including auditors, legal and accounting advisers, bound by confidentiality;
• Regulators, law-enforcement and other authorities where we are legally required to disclose;
• A purchaser or successor entity in the event of a corporate reorganisation or sale of business.

Some of our technology providers process data outside Nigeria. Where personal data is transferred internationally, we rely on an adequacy decision of the NDPC, standard contractual clauses, or another lawful transfer mechanism under Part VIII of the NDPA 2023, and we assess whether the destination offers an adequate level of protection. For engagements subject to data-residency requirements, including the Central Bank of Nigeria data-localisation directive, we configure Nigeria-resident hosting or a location expressly approved by the client, and maintain a documented record of where data resides.

• Enquiries that do not become engagements

  24 months from last contact.

• Client contract and project records

  Duration of the engagement plus 7 years, to meet legal, tax and audit obligations.

• Marketing and subscription records

  Until you unsubscribe or withdraw consent, plus a suppression record.

• Unsuccessful job applications

  12 months from the outcome, unless you consent to a longer period.

• Website analytics and cookie data

  Up to 12 months, depending on the cookie.

• Client personal data processed on instruction

  As directed by the client in the applicable agreement.

At the end of the applicable period we securely delete or irreversibly anonymise the data.

Our controls include role-based access on the principle of least privilege, multi-factor authentication, encryption of data in transit and at rest, full-disk encryption on all endpoints, centrally managed anti-malware, patch and vulnerability management, data loss prevention, logging and monitoring, backup and tested disaster recovery, and mandatory annual privacy and security awareness training for all employees and contractors. Access is reviewed periodically and revoked promptly when no longer required.

Under the NDPA 2023 you have the right to:

• Be informed about how your personal data is used

• Access a copy of the personal data we hold about you

• Have inaccurate or incomplete data corrected

• Request deletion of your data where there is no continuing lawful basis to retain it

• Restrict or object to processing, including objecting to direct marketing at any time

• Receive your data in a portable, machine-readable format

• Withdraw consent at any time, without affecting processing carried out before withdrawal

• Lodge a complaint with the Nigeria Data Protection Commission

To exercise any of these rights, contact our Data Protection Officer using the details in section 11. We will verify your identity before acting on a request and will respond within one month. Where a request is complex, we may extend this period and will tell you if we do. There is no charge unless a request is manifestly unfounded or excessive.

Our website uses cookies that are strictly necessary for it to function, and, with your consent, cookies for analytics and performance. When you first visit, a banner allows you to accept all, reject non-essential cookies, or manage your preferences by category. You can change or withdraw your choice at any time through the cookie settings link on our website, or by clearing cookies in your browser. Rejecting non-essential cookies will not prevent you from using the site.

Questions, requests or complaints about this notice or our handling of personal data should be directed to:

If you are not satisfied with our response, you may complain to the NDPC at any time.

We review this Privacy Notice at least annually and whenever our processing activities change materially. The version number and last-updated date at the top of this page show when it was last revised. Where changes are significant, we will bring them to your attention directly. Previous versions are available on request.