← NDPA 2023 · Governance

s.44 — Registration as a data controller or processor of major importance

critical policy-governancerecords

Requirement

A data controller or processor of major importance shall register with the Commission within six months of the Act's commencement or of becoming one, and notify the Commission of significant changes (s.44). Under the GAID 2025 these organisations are designated ultra-high, extra-high or ordinary-high level; ordinary-high level registrations are renewed annually. This duty has no direct GDPR equivalent and is frequently missed by organisations that have simply reused their GDPR programme.

What the engine looks for

Every group below must be satisfied — by an affirmative statement, not a plan, a hedge or a denial — for the control to count as covered. A term ending in … matches any word it begins. Supporting terms do not change the verdict — they raise confidence and distinguish a policy that names a mechanism from one that gestures at a category.

Required element 1 — any one of
registered withregistration withregister withregistration asregistered asregistration certificaterenew our registrationregistration is renewed
Required element 2 — any one of
commissionndpcnigeria data protection
Supporting terms — specificity signals
section 44six monthsmajor importancethresholdrenewalassessmentannual returncompliance audit returnsultra-highextra-highordinary-high
Contradiction markers

Finding any of these outranks coverage — a policy that admits the gap is worse than silence.

not registered no assessment of major importance

Equivalent controls elsewhere

Matched on shared topics. Satisfying this control usually moves these too.

FrameworkControlTitleShared topics
GDPR Art.5(2) Accountability policy-governance records
ISO 27001 A.5.31 Legal, statutory, regulatory and contractual requirements policy-governance records
GDPR Art.24 Responsibility of the controller policy-governance
GDPR Art.30 Records of processing activities records
GDPR Art.31 Cooperation with the supervisory authority policy-governance
CCPA/CPRA Regs 7101 Records of consumer requests kept for 24 months records
SOC 2 CC1.1 Commitment to integrity and ethical values policy-governance
SOC 2 CC1.2 Board independence and oversight policy-governance