ix. notify NITDA of Personal Data breaches within 72 (seventy-two) hours of becoming aware of the breach; x. update agreements with third party processors to ensure compliance with the NDPR; xi. design system and processes to make data requests and access seamless for Data Subjects; xii. design systems and processes to enable Data Subjects to easily correct or update their Personal Data; xiii. design system and processes to enable Data Subjects to easily transfer data to another platform or person (natural or artificial) at minimal costs; xiv. within the first 6 (six) months of incorporation and then on a biennial basis, train members of senior management and employees that collect and/or process Personal Data in the course of their duty, on Nigerian data protection laws and practices; xv. clearly communicate to Data Subjects the process for objecting to the processing of their Personal Data; and xvi. outline the procedure for informing Data Subject and for protecting their rights, where an automated decision is being made on their Personal Data. 3.3 Compliance Approach 3.3.1 The approach adopted for the NDPR is to ensure compliance by all stakeholders in a business-friendly manner. A triangular compliance model set out below is adopted: NITDA (as National DPO) 7|Page