A decade ago, few Nigerians paused to ask what happened to their personal data after filling out an online form or signing up for a mobile app. Data privacy was hardly a public concern, and companies operated in a largely unregulated digital environment where breaches or data misuse often went unnoticed or unpunished.

Fast forward to 2025, Nigeria is now charting a new course in data governance—backed by legislation, strategy, and a clear commitment to user rights. The catalyst? Growing smartphone penetration, a booming startup scene, and the global reckoning on privacy sparked by scandals like Cambridge Analytica.

A Shift in the Regulatory Landscape

The landmark Nigeria Data Protection Act (NDPA), passed in 2023, laid the groundwork for a rights-based framework around personal data. However, the introduction of the General Application and Implementation Directive (GAID) 2025 signaled a much deeper transformation. It introduced binding obligations such as mandatory Data Protection Impact Assessments (DPIAs) and the appointment of Data Protection Officers (DPOs)—even for early-stage startups.

For many in Nigeria’s tech ecosystem, this shift has raised concerns. Can lean startups afford to comply?

“It’s a fair question,” says Vanessa Obi, a data protection consultant and legal advisor with Banwo & Ighodalo. “Startups are already stretched thin—so additional regulatory burdens can feel overwhelming. But the intent isn’t to punish, it’s to encourage responsible innovation.”

Compliance as a Growth Lever

According to Obi, compliance isn’t about red tape—it’s about trust. “At the core of these requirements is the idea that users deserve transparency and control. If startups rely on user data, it’s only fair they assess the risks and handle that data responsibly.”

To support this, the NDPC (Nigeria Data Protection Commission) encourages startups to work with licensed Data Protection Compliance Organisations (DPCOs) instead of hiring full-time DPOs—allowing flexibility and affordability while ensuring oversight.

Over time, Obi believes, internal data protection capacity will grow organically within the startup ecosystem. “It’s not about checking boxes. It’s about maturing into responsible data stewards.”

Empowering the Public

GAID 2025 also aims to simplify data rights for everyday Nigerians. One such mechanism is the Standard Notice to Address Grievance (SNAG)—a user-friendly tool that allows citizens to lodge complaints or request data access without needing legal expertise.

“This lowers the barrier for individuals to engage with their rights,” Obi notes. “It’s an important shift from abstract legalese to accessible action.”

Remaining Challenges: Cross-Border Enforcement

Despite this progress, key challenges remain—particularly around cross-border data transfers. With many Nigerian companies using cloud services hosted abroad and data flowing between global tech platforms, enforcement remains a grey area.

Obi points to three main gaps: the sheer volume of data transfers, internal data movement within multinationals that evade public scrutiny, and the judiciary’s ongoing learning curve on digital rights cases.

“We’ve seen some encouraging steps,” she says, referencing the Meta-FCCPC case on unauthorised direct marketing. “But for Nigeria to enforce its laws internationally, it will need stronger legal frameworks, judicial capacity, and multilateral cooperation.”

A Collective Effort

The road ahead requires collaboration—between regulators, courts, private sector leaders, and civil society. GAID 2025 provides a strategic framework, but implementation will depend on cultural and institutional buy-in.

For startups, data protection doesn’t have to be a stumbling block—it can be a competitive edge. “Done well, compliance becomes a business enabler,” says Obi. “It fosters loyalty, prevents costly missteps, and builds credibility with partners and customers alike.”

Conclusion

Nigeria is at a pivotal moment in its digital evolution. As the country balances innovation with accountability, the tech ecosystem will need to view data protection not just as a legal mandate—but as a cornerstone of digital trust and long-term sustainability.