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Customer Data Protection and Privacy Policy

1.INTRODUCTION

Welcome to Eko Electricity Distribution Plc’s (EKEDP) Data Protection and Privacy Policy.

EKEDP respects the privacy of your personal data or personal information and is committed to protecting it in accordance with the relevant laws and regulations.

This Data Protection and Privacy Policy (the “Policy”) informs our customers and the public (hereinafter referred to as “you”, “your” or “data subject”) as to how we use and look after your personal data, your privacy rights and how we plan to protect them.

Any reference to "we", "us", "our" and “the Company” is to EKEDP.

2.PURPOSE OF THIS PRIVACY POLICY

This Policy aims to give you information on how EKEDP collects and processes your personal data when you fill/complete any of our forms, access or create an account our website as well as other mediums and platforms through which you provide us with your personal data in order enable us perform a contract with you, including providing our products and services to you.

The Policy is intended to comply with our obligations to provide you with information about the Company's processing of your personal information under the relevant laws and regulations. It neither has a contractual status nor constitutes any agreement to contract with you or provide you with our products and services

It is important that you read and retain this Policy, together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

This privacy policy supplements other notices and privacy policies and is not intended to override them.

3.CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

EKEDP reserves the right to update this Policy at any time, and we will provide you with the revised Policy when we make any updates.

We encourage you to frequently visit our website for any changes to this Policy, so as to stay informed about how we are helping to protect the personal information we collect.

It is also important that the personal data we hold about you is accurate and current. In view of this, always update your personal data and keep us informed if there are changes to your personal data during your relationship with us.

4.EKEDP ’S DATA PROTECTION PRINCIPLES

In collecting and processing your personal data, EKEDP will, in compliance with the relevant laws and regulations, ensure that your personal data is:

a) collected and processed in accordance with specific, legitimate and lawful purpose consented to by you;

b) adequate, accurate and without prejudice to the dignity of human person;

c)stored only for the period within which it is reasonably needed; and

d)secured against all foreseeable hazards and breaches such as theft, cyber- attack, viral attack, dissemination, manipulations of any kind, damage by rain, fire or exposure to other natural elements.

5.DATA CONTROL

EKEDP is the data controller. This means that we are responsible for deciding how we hold and use personal information about you.

EKEDP shall take all necessary steps and measures to ensure that in the event that any third party handles your personal data, such party must do so in strict compliance with the applicable laws and regulations and under a written contract.

6.DATA PROTECTION OFFICER

To ensure that any concerns you may have regarding the protection of your personal data is addressed sufficiently and timeously, we have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Policy.

If you have any questions about this Policy or our privacy practices, including any requests to exercise your legal rights which have been specified in this Policy, please contact the DPO using the details set out below:

  • Attention: The Data Protection Officer, Eko Electricity Distribution Plc
  • Postal address: 24/25 Marina Road, Lagos Island, Lagos, Nigeria
  • Email address: dpo@ekedp.com
  • Telephone number: 0812 992 9045

Without prejudice to your right to make a complaint at any time to the National Information Technology Development Agency (NITDA), the supervisory authority for data protection issues (dpo@ekedp.com) for any alleged breach of your data privacy rights, we would appreciate that you contact us in the first instance through the DPO if you have any concerns regarding the protection of your data or this Policy.

7.THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

a) Identity Data includes first name, maiden name, middle name, last name, username or similar identifier, marital status, title, date of birth/age and gender.

b) Contact Data includes billing address, delivery address, email address and telephone numbers.

c) Financial Data includes bank account and payment card details.

d) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

e) Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

f) Profile Data includes your username and password, requests made by you, your interests, preferences, feedback and survey responses.

g) Profile Data includes information about how you use our website, products and services.

h) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Sensitive Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions and views, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

8.COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

9.FAILURE TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, or to provide our products and our services and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (including to provide you with our products and services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

10. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

a) Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, accessing or creating an account on our website, corresponding with us by post, phone, email as well as other related medium/platforms. This particularly covers personal data you provide when you apply for our products or services, give us feedback or contact us.

b) Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

c) Third parties or publicly available sources. We will receive personal data about you from third parties.

11.HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

a) Performance of Contract - means processing your data where it is necessary for the performance of a contract to which you are a party (including providing our products and services) or to take steps at your request before entering into such a contract.

b) Compliance with legal obligation -means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

c) Legitimate Interest -means the interest of our business in conducting and managing our business to enable us to give you the best products and services and most secure experience.

d) Public Interest -means where processing your data is necessary in order to protect your interest, the interest of another data subject or for the performance of a task carried out in the public interest or in exercise of official public mandate vested in us.

Generally, we rely on your consent as the legal basis for processing your personal data. This covers cases where you require us to process your personal data for the purpose of performing a contract with you, or accessing our products and services including but not limited to payment of electricity bills; raising a complaint for clearance of faults; whistleblowing and accessing any of our customer care services.

We do not generally use your data for marketing purposes. However, if the need ever arises, we will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

With regards to what constitutes data subject’s consent, in accordance with the applicable laws and regulations, EKEDP shall ensure that consent is freely given and is obtained without fraud, coercion or undue influence. Accordingly, EKEDP would typically collect and process your personal data where you require us to perform a contract, including the provision of our products and services to you.

Since the performance of a contract with you and provision of our products and services to you are conditional on your consent, we shall deem that you have granted us your voluntary, free and express consent to collect and process your personal data when you fill any of our forms, access or create an account on our website, correspond with us by post, phone, email as well as other related medium/platforms in order to enable us contract with you or provide you with our products and services. Please note that you have the right to withdraw consent at any time to the processing of your personal data by contacting us.

12.PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

SN PURPOSE/ACTIVITY TYPE OF DATA LAWFUL BASIS FOR PROCESSING
1 To register you as a new customer (a) Identity (b) Contact (c) Financial (a) Performance of a contract with you (b) Necessary for our legitimate interests (c) Necessary to comply with a legal obligation
2 To perform contract with you, and provide our product and services (a) Identity (b) Contact (c) Financial (d) Transaction (e)Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (c)Necessary to comply with a legal obligation
3 To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usages Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
4 To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (a) Identity (b) Contact (c) Profile (d)Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

13.HOW WE USE YOUR PERSONAL DATA

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us through our DPO.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

14.DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above and in compliance with the applicable laws and regulations.

a)Service providers who provide IT and system administration services, revenue collection services, electricity billing and printing services, gateway channel services, workforce management services and vending services.

b)Professional advisers including consultants, lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

c)Regulatory agencies and authorities who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions as stipulated in a written contract.

15.INTERNATIONAL TRANSFER

Generally, we do not transfer your personal data outside Nigeria or to an international organisation. However, whenever there is a need to transfer your personal data out of Nigeria or to an international organisation arises, we shall ensure that we comply with the relevant laws and regulations.

16.DATA SECURITY AND PROTECTION

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know same. They will only process your personal data on our instructions and they are subject to a duty of confidentiality as governed by a written contract.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

17.DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

18.YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION

Under certain circumstances, you have rights under data protection laws and regulations in relation to your personal data. You have the right to the following:

a) Request access to your personal data (commonly known as a “Data Subject Access Request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

b) Request correction/rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

c) Request erasureof your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with a legal obligation in Nigeria. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: If you want us to establish the data’s accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; and when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

f) Request the transfer (commonly known as “Data Portability”) of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

g) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you wish to exercise any of the rights set out above, that is, to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DPO.

19.FEE FOR PROCESSING REQUEST & TIMELINE

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances by writing to you and copying NITDA.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within a reasonable time. Occasionally, it could take us longer time if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

20.BREACH

In the event of a personal data breach leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, EKEDP shall within a reasonable time of becoming aware of the breach:

a) promptly assess the risk;

b) promptly notify the affected data subject;

c)take all necessary measures and steps to ensure that further damage is not caused by the breach;

d)take all steps to retract the data (in cases of unauthorised access or disclosure); and

e)if appropriate, report the breach to NITDA.