Intercompany Data Processing Agreement Template for Nigeria

1. Cross-Border Data Transfers: Required when data will be transferred outside Nigeria, specifying compliance with NDPA transfer requirements

2. Sub-processing: Include when the processor may need to engage sub-processors, detailing approval requirements and obligations

3. Group Company Additions: Mechanism for adding other group companies to the agreement, useful for expanding corporate groups

4. Data Protection Impact Assessment: Required when processing is likely to result in high risk to rights and freedoms of data subjects

5. Charges and Costs: Include if there are specific cost arrangements between group companies for processing services

6. Insurance Requirements: Specific insurance obligations for data processing activities, if required by group policy

1. Schedule 1 - Processing Activities: Detailed description of processing activities, including data categories, purposes, and processing operations

2. Schedule 2 - Technical and Organizational Measures: Specific security measures, controls, and protocols implemented for data protection

3. Schedule 3 - Authorized Sub-processors: List of approved sub-processors and their specific roles, if applicable

4. Schedule 4 - Data Transfer Mechanisms: Details of mechanisms used for any international data transfers

5. Schedule 5 - Contact Points and Escalation Procedure: Key contacts and procedures for operational matters and emergencies

6. Appendix A - Standard Contractual Clauses: If required for international transfers, incorporating relevant data transfer clauses

7. Appendix B - Security Breach Response Plan: Detailed procedures and responsibilities for handling data breaches