records and reports in credible news media. Accordingly, the distinction between legal and natural persons for the purpose of limiting due diligence is irrelevant. 2.5 PUBLICITY AND CLARITY OF PRIVACY POLICY Notwithstanding anything contrary in this Regulation or any instrument for the time being in force, any medium through which Personal Data is being collected or processed shall display a simple and conspicuous privacy policy that the class of Data Subject being targeted can understand. The privacy policy shall in addition to any other relevant information contain the following: a) what constitutes the Data Subject’s consent; b) description of collectable personal information; c) purpose of collection of Personal Data; d) technical methods used to collect and store personal information, cookies, JWT, web tokens etc.; e) access (if any) of third parties to Personal Data and purpose of access; f) a highlight of the principles stated in Part 2; g) available remedies in the event of violation of the privacy policy; h) the time frame for remedy; and i) provided that no limitation clause shall avail any Data Controller who acts in breach of the principles set out in this Regulation. 2.6 DATA SECURITY Anyone involved in data processing or the control of data shall develop security measures to protect data; such measures include but not limited to protecting systems from hackers, setting up firewalls, storing data securely with access to specific authorized individuals, employing data encryption technologies, developing organizational policy for handling Personal Data (and other sensitive or confidential data), protection of emailing systems and continuous capacity building for staff. 2.7 THIRD PARTY DATA PROCESSING CONTRACT Data processing by a third party shall be governed by a written contract between the third party and the Data Controller. Accordingly, any person engaging a third 10 NIGERIA DATA PROTECTION REGULATION

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