Legal review required
This is a working draft written to the structure the Nigeria Data Protection Act 2023 expects. It is not legal advice and must be reviewed by a lawyer, and the bracketed items completed, before publication. In particular, an organisation handling incident reports about identifiable people has obligations beyond an ordinary brochure website.
Last updated: [date] · Applies to: vigilantegroup.org
On this page
1. Who we are
Vigilante Group of Nigeria, of No. 52B, Ishaya Shekeri Crescent, Gwarinpa Estate, Abuja, is the data controller for personal information submitted through this website. Our data protection contact is vgmhqkd@gmail.com.
2. What we collect
- Membership applications: name, date of birth, telephone, email, state, LGA, ward, referee details, and anything you write in the free-text field.
- Incident reports: the details of the report itself, and — only if you choose to give them — your name, telephone and email. Reports may be submitted anonymously.
- Enquiries: name, email, telephone, organisation and message.
- Technical data: [complete once you know whether analytics are enabled — see section 7].
3. Why we collect it
We process this information in order to:
- assess membership applications and carry out character screening;
- record, assess and act on incident reports and complaints;
- respond to enquiries;
- maintain the register of members required for accountability.
Our lawful bases are your consent (enquiries and applications), the performance of a task carried out in the public interest (community safety), and compliance with a legal obligation where one applies. [Confirm with counsel.]
4. Who we share it with
- The Nigeria Police Force and other statutory agencies, where a report discloses a criminal offence or a threat to life.
- The relevant state command, where a matter must be handled locally.
- Service providers who host this site and deliver our email. [Name them once chosen.]
We do not sell personal information, and we do not share it for marketing. We do not disclose a complainant’s identity to the person complained about without the complainant’s knowledge — though once a matter reaches the police or a court, disclosure is governed by law rather than by us.
5. How long we keep it
[Set actual retention periods. As a starting point: unsuccessful applications [12 months]; member records for the duration of membership plus [x] years; incident reports [x] years; general enquiries [24 months].]
6. Your rights
Under the Nigeria Data Protection Act 2023 you may ask us to:
- confirm what personal information we hold about you, and give you a copy;
- correct information that is inaccurate or incomplete;
- delete information where we no longer have a good reason to keep it;
- restrict or object to certain processing;
- withdraw consent, where consent is the basis we rely on.
Write to vgmhqkd@gmail.com. We will respond within [30] days. Some rights are limited where information forms part of a report to the police or an ongoing disciplinary matter.
7. Cookies
This website sets no cookies and runs no advertising or tracking scripts. Fonts are loaded from Google Fonts, which means Google receives your IP address when a page loads. [If you want to remove even that, self-host the two font files and I will update the stylesheet — then the site makes no third-party requests at all.]
8. Security
The site is served over HTTPS. Form submissions are transmitted to [name the destination once the forms are wired up]. Access to incident reports is limited to the duty officer and the Provost Marshal’s office.
9. Complaints
If you are not satisfied with how we have handled your information, contact us first at vgmhqkd@gmail.com. You also have the right to complain to the Nigeria Data Protection Commission.