1. Introduction
As a body established by the Lagos State Government, the Lagos State Security Trust Fund (LSSTF) must meet its contractual, statutory, and administrative obligations. We are committed to ensuring that the personal data of our donors, partners, beneficiaries, and service users is handled in accordance with the Nigeria Data Protection Act (NDPA) and all applicable data protection regulations.
This privacy notice tells you what to expect when LSSTF collects personal information about you. It applies to all individuals who interact with LSSTF, including donors, volunteers, event attendees, grant applicants, and visitors to our website and online platforms. The information we process about you will vary depending on your specific involvement with LSSTF.
If we are requesting your personal data, it is because it is necessary and relevant to the service or function being performed. If you withhold information, we may not be able to perform that service or there may be a delay in doing so.
LSSTF is the controller for this information unless this notice specifically states otherwise. Our Data Protection Officer can be contacted at dataprotection@lsstf.lagosstate.gov.ng
2. Collection of Information
The personal data we process in order to carry out our functions includes but is not limited to names, titles, aliases, and photographs; contact details such as telephone numbers, addresses, and email addresses; gender, age, nationality, and occupation; financial identifiers such as bank account numbers, BVN, payment card numbers, transaction identifiers, and donation records; and residency identifiers such as LASRRA number and National Identification Number (NIN).
We may also process Sensitive Personal Data where required by law or in the substantial public interest. These categories include criminal convictions or alleged offences, racial or ethnic origin, mental and physical health records, political beliefs, genetic data, and biometric data. Sensitive personal data requires higher levels of protection and we process it only in the following circumstances: where it is needed to carry out our specific legal obligations; where it is needed for a matter of substantial public interest such as a threat to public safety; in connection with legal claims or to protect the vital interests of individuals who are not capable of giving consent; or where you have already made the information public.
3. Use of Personal Data
We may use your personal data for the following purposes, which include but are not limited to: processing and acknowledging donations made to LSSTF; producing and issuing formal donation receipts; featuring donors in the LSSTF Annual Report in accordance with stated recognition preferences; contacting you in connection with your donation, grant application, or other interaction with LSSTF; confirming your identity; preventing and detecting fraud and corruption in the use of funds; complying with all legal and statutory obligations; processing relevant financial transactions including donations, grants, and payments; maintaining our accounts and records; seeking your views or feedback; notifying you of changes to our services, programmes, or events; sending you communications which you have requested; and allowing statistical analysis of data in order to plan and improve our operations.
LSSTF is based in Nigeria and the information we collect is governed by the Nigeria Data Protection Act. By interacting with LSSTF or providing information to us, you consent to the processing and transfer of information within Nigeria.
4. Information Sharing
We use a number of third-party consultants, vendors, and partners to store or manage personal information on our behalf and to provide certain services. Where we have such arrangements, a contract, memorandum of understanding, or information sharing protocol is always in place to ensure compliance with data protection regulations.
We may also share data internally between departments and partner agencies of LSSTF where this is legal and proportionate.
In addition, there are circumstances in which we may share data with other public authorities and organisations where there is a legal basis for doing so, including Lagos State Government ministries, departments and agencies; the Federal Government of Nigeria; the Nigeria Police Force and other security agencies supported by LSSTF; health service providers or regulators; and voluntary and charitable organisations.
In very limited circumstances, we may share your personal information when there is a pressing and lawful reason that outweighs your right to confidentiality, such as the detection and prevention of crime or fraudulent activity; a serious risk to the safety of the public, our staff, or other professionals; or the protection of a child or vulnerable adult.
When using personal data for research purposes, data will be anonymised to prevent identification of individuals unless consent has been given. We do not sell or provide personal information to any organisation for the purposes of direct marketing. We will seek your consent before sending your personal data to a country without an adequate data protection framework.
5. Security
We take appropriate steps to ensure that records about you, whether held on paper or electronically, are kept securely and made available only to those who have a right to see them. Our security measures include encryption of data in transit and at rest; firewall and network security frameworks; access controls on systems and in offices containing personal or sensitive data; data protection training and awareness programmes for all staff; and documented policies and procedures around data protection and information security.
6. How Long We Keep Your Personal Data
LSSTF will retain your data only for as long as it is needed for the purpose for which it was collected, or as required by law, or as dictated by best practice in line with our retention policy. Some records will be kept permanently where we are legally required to do so. Financial records are kept for a minimum of eight years to support audits and satisfy statutory obligations. We will endeavour to delete personal data as soon as it is no longer needed.
7. Your Rights as a Data Subject
The law gives you certain rights in respect of the personal data LSSTF holds about you.
Right of Access: you have the right to request a copy of the personal data we hold about you.
Right to Rectify: you have the right to correct inaccurate personal data we hold about you. A supporting document may be requested.
Right to be Forgotten: in certain circumstances, you may ask for the data we hold about you to be erased from our records.
Right to Restrict Processing: where certain conditions apply, you have the right to restrict how we process your personal data.
Right to Portability: you have the right to have your personal data transferred to another organisation.
Right to Object: you have the right to object to the processing of your personal data.
Right to Lodge a Complaint: you have the right to lodge a complaint about the handling of your personal data with the Nigeria Data Protection Commission (NDPC).
To exercise any of your rights, please contact our Data Protection Officer at dataprotection@lsstf.lagosstate.gov.ng
8. Breach and Privacy Violations
In the event of a security breach leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data, LSSTF shall within 72 hours of becoming aware report the details to the Nigeria Data Protection Commission (NDPC).
Where we determine that such a breach is detrimental to your rights and freedoms, we shall within seven days of becoming aware take steps to inform you of the breach, the risk to your rights and freedoms arising from it, and any action being taken to remedy the situation.