10.1.3 Investigation NITDA will investigate any complaint filed against a Data Controller or Administrator when a preliminary review of the facts indicates a possible violation of the provision(s) of the NDPR. NITDA may by its officers or through a designated DPCO, investigate any complaint filed by third parties and may also do so based on a special audit check or “spot check”. Investigation may include a review of the policies, procedures, or practices of the concerned entity and of the circumstances regarding any alleged violation. At the time of the initial written communication with the concerned entity, NITDA will indicate the basis of the audit. 10.1.4 Administrative Sanctions Where NITDA has ascertained through the foregoing tools of enforcement or by the Administrative Redress Panel established, pursuant to Article 4.2 of the NDPR, that a party is in breach, NITDA may issue an order for compliance with relevant provisions to curtail further breach. NITDA, shall issue a monetary fine following an administrative process that complies with principles of fair hearing and judicial safeguards. A decision on the money value shall be based on the following considerations: a) nature, gravity and severity of the breach; b) the number of data subjects affected; c) damage suffered by data subjects; d) opportunity for curtailment left unexplored and e) whether the breach is the first by the offending entity. NITDA may also issue other administrative orders to include: i. Suspension of service pending further investigations; 22 | P a g e

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