Titita Empowerment FoundationTititaEmpowerment Foundation

Privacy and personal data

Privacy Policy

What Titita Empowerment Foundation collects about you, why, who sees it, how long we keep it, and what you can ask us to do.

Contents
  1. 1 Who we are
  2. 2 The principles we follow
  3. 3 What we collect, why, and on what legal ground
  4. 4 This website
  5. 5 Who we share it with
  6. 6 How long we keep it
  7. 7 How we protect it
  8. 8 Your rights
  9. 9 Other things you should know
  10. Annex Notice for people at an outreach
DocumentValue
ReferenceTF-PRV-001, version 1.1
Effective4 October 2026
Applies toThis website, www.tititafoundation.org; our emails, calls and messages; our donors, volunteers, partners and suppliers; the people we help through outreaches; and people who apply to work with us
LawThe Nigeria Data Protection Act, 2023 and the General Application and Implementation Directive, 2025 issued under it, and section 37 of the Constitution of the Federal Republic of Nigeria, 1999 (privacy of citizens). Where someone in the United Kingdom or the European Union is affected, the UK and EU General Data Protection Regulations also apply to that data
ReviewAt least once a year, and whenever our activities or the law change

1 Who we are

Titita Empowerment Foundation (“we”, “us”) is a Nigerian charity registered with the Corporate Affairs Commission under IT Number 7283869. We are the data controller for the personal data described in this policy: we decide why and how it is used.

OfficePlot 116 Zone A, Apo Urban Market Luxury Shop Mall, Abuja, Federal Capital Territory
Privacy contactEmail partnerships@tititafoundation.org with “Privacy” in the subject line, or call +234 707 633 0522 or +234 805 146 6501
Data protection officerThe Board designates a person responsible for data protection and gives that person’s contact details through the same address. We appoint a certified Data Protection Officer and register with the Nigeria Data Protection Commission whenever the law requires it of us

2 The principles we follow

  • We collect only what we need, and say why when we ask.
  • We use it only for the purpose we gave, or a compatible one.
  • We keep it accurate, and no longer than we need.
  • We protect it, and we tell you and the regulator if it is lost or stolen.
  • We never sell it. We never use it to profile you or to decide things about you automatically.
  • We never use anything collected from the people we help for any political, campaign or electoral purpose, and we never give it to a political party, candidate or campaign.

The law requires a lawful ground for each use of personal data. The grounds we use are: your consent; a contract with you; a legal obligation; protecting someone’s vital interests; and our legitimate interests, which we balance against your rights.

Who you areWhat we collectWhy we use itLegal ground
Visitors to the websiteStandard technical data that the company hosting our website may record when a page loads, such as your internet address, the time, the page requested and your browser type. We do not receive or use this data to identify youTo deliver the site and keep it secureLegitimate interests (our host’s, and ours)
People who contact usName, telephone number, email address and what you tell usTo answer you and keep a record of what we agreedConsent, or our legitimate interests in replying
Donors and fundersName and contact details if you give them, the amount and date of a gift, how it was paid, and, only where our anti-money laundering policy calls for it, identification and a statement of where the money comes from. You may give anonymously, and then we record only the gift and how it was paidTo receive and acknowledge a gift, keep accounts, and check where money comes from when there is a reason toLegal obligation; contract; legitimate interests
VolunteersName, contact details, identification, two references, a declaration of interests, availability, emergency contactTo choose, brief and protect volunteers and our beneficiariesConsent; legitimate interests; legal obligation
Partners, hosts and suppliersBusiness and contact details of their officers, registration documents, bank details, identification of the people who run themTo check who we deal with, pay for work and keep our accountsContract; legal obligation
People we helpUsually a name or a code, the ward or village, the item or service received, the date, and confirmation that the person received it. Never more than the activity needsTo make sure the right person is helped once, to show our partners and donors that help arrived, and to prevent misuseLegitimate interests; consent where the activity needs more
Staff and job applicantsName, contact details, identification, qualifications, references, bank details, performance recordsTo recruit, pay and manage people and to meet employment and tax lawContract; legal obligation; consent for applicants

3.1 Sensitive personal data

Health, religion, ethnic origin, political opinion, biometric data, criminal record and similar information is sensitive. We collect it only when it is necessary for what you have asked us to do, and only with your clear consent or another ground that the law allows. We do not record anyone’s political opinion or party membership. Health information about the people we help is collected by, and stays with, the licensed health provider we work with; we receive only the figures we need to report.

3.2 Children

A child is anyone under 18. We collect a child’s data only with the consent of a parent or guardian, which we ask for in a way the parent can understand, and only what is needed to help the child safely. We never use a child’s image or name in public material without written parental consent. Our Safeguarding and Child Protection Policy applies to everything we do with children.

3.3 Photographs and recordings

We take photographs at outreaches to show what was done. We take them of people only when they have agreed, and we stop if they ask us to. We take no photograph that shows a person in distress or in a state of undress, or that reveals where a vulnerable person lives.

4 This website

At the date of this policy, the website:

  • does not set cookies and does not use advertising, analytics or tracking tools;
  • does not collect anything you type, because it has no forms;
  • does not load fonts, scripts or images from other companies’ servers.

The company that hosts the site may record standard technical logs, as web hosts commonly do. We do not control those logs or use them to identify visitors, and the host keeps them for the period in its own policy. When you telephone or email the address on the site, we receive your number or email address and whatever you say. Our Facebook and Instagram accounts (@Titita_foundation) are run by Meta, which has its own privacy rules. If we add forms, analytics or cookies, we will update this policy first and ask for your consent where the law requires it.

5 Who we share it with

RecipientWhat and why
Our service providersEmail, storage, accounting, printing and IT providers, so that they can do work for us. They may use the data only on our instructions and must protect it.
Implementing partners and hostsThe minimum needed to run an activity, such as the list of people to be helped, under a written agreement that protects it and forbids other use.
Donors and fundersReports with numbers and de-identified results. Names of people we help are shared only where you agree, or where a funder has a lawful audit right and the data is protected.
Regulators and the authoritiesThe Corporate Affairs Commission, the Nigerian Financial Intelligence Unit, the Special Control Unit against Money Laundering, the Economic and Financial Crimes Commission, the Nigeria Data Protection Commission, the police and the courts, when the law requires or lets us. We disclose only what is required, and keep a record of it.
Auditors and legal advisersTo audit our accounts and advise us, under a duty of confidence.

We do not sell, rent or trade personal data. We do not give it to any political party, candidate or campaign.

5.1 Sending data outside Nigeria

Some of the tools we use keep data on servers outside Nigeria. We transfer personal data out of Nigeria only to a country or organisation that gives adequate protection, or with appropriate safeguards or another ground the Nigeria Data Protection Act allows (sections 41 to 43), and we record which one applies.

6 How long we keep it

DataKept forWhy
Website hosting logsSet by our hosting provider, not by usSecurity and fault finding by the host
Enquiries and correspondence24 months after the last contactTo follow up and to show what was agreed
Donor records and accounts7 years after the gift or the end of the tax yearAccounting, audit and tax law
Identification and diligence records5 years after the relationship ends, or 7 years where they sit with financial recordsOur anti-money laundering policy and the law
Partner, host and supplier files7 years after the agreement endsContract and audit
Volunteer files3 years after the last activityReferences and safeguarding
Outreach registers of people helped7 years, then names are deleted and only counts are keptDonor audit, preventing duplication and misuse
PhotographsUntil you withdraw consent, or 5 years, whichever is soonerTo show what was done
Staff records7 years after the employment endsEmployment, pension and tax law
Unsuccessful job applications12 monthsTo consider you again

We keep data for longer where a legal claim, an investigation or an audit is open. When the period ends, we delete or destroy it securely, or make it anonymous.

7 How we protect it

  • Only people who need the data for their job see it, and each has agreed in writing to keep it confidential.
  • Paper registers are locked away. Phones and computers that hold data are password protected and, where we can, encrypted.
  • We share data with providers and partners only under written agreements.
  • Everyone who handles data is trained on this policy.
  • We keep a log of data incidents. If personal data is lost, stolen or exposed in a way that is likely to harm anyone’s rights, we tell the Nigeria Data Protection Commission within 72 hours of becoming aware of it, as the Act requires (section 40), and we tell the people affected without delay where the risk to them is high.

8 Your rights

You can ask us, free of charge, to:

  • tell you whether we hold data about you and give you a copy;
  • correct data that is wrong or incomplete;
  • delete data we no longer need or that we should not have, unless the law requires us to keep it;
  • restrict our use of it while a complaint is dealt with;
  • stop using it where we rely on our legitimate interests, or for direct communications;
  • give you the data you gave us in a form you can pass on to someone else;
  • withdraw a consent you gave, at any time. This does not affect what we did before.

You have the right not to be the subject of a decision made only by a machine that significantly affects you. We make no such decisions.

8.1 How to use your rights

Write to or call the privacy contact in section 1. We may ask you to prove who you are before we release data, so that it does not reach the wrong person. We answer without undue delay and within one month. If we cannot do what you ask, we tell you why. You may use these rights through a parent or guardian if you are a child, or through someone you authorise in writing.

8.2 If you are not satisfied

Tell us first and we will try to put it right. You may also complain to the Nigeria Data Protection Commission (ndpc.gov.ng) or go to court. If you are in the United Kingdom or the European Union, you may complain to your own data protection authority.

9 Other things you should know

  • Anti-money laundering. We follow Nigeria’s anti-money laundering law. In some cases, such as a gift from abroad or from a public figure, we may ask for identification and the source of a gift. You can always give anonymously, in which case we record only the gift and how it was paid. Where the law requires, we may have to give information to the authorities without telling you. Our Anti-Money Laundering Manual explains this.
  • Links. The site links to other websites. We do not control them. Read their policies.
  • Changes. We will post any change on this website, with its date and a summary. A change that affects how we use your data in a way you would not expect will be notified to you directly where we can.
  • Language. We will explain this policy in the language you speak when we collect your data, in person or by telephone, on request.

Annex Notice for people at an outreach

This notice is read aloud, in the language of the community, and displayed where people register. It is not signed on a person’s behalf by anyone else.

What we tell you before we write anything down

We are Titita Empowerment Foundation, a registered charity from Abuja. Today we will write down your name or a number, your village or ward, and what you received, so that every person is helped once and so that the people who give us things can see that they reached you. We will not write down anything we do not need.

Your information stays with us and with the partner running today’s activity. We will never give it to a political party or a candidate, we will never use it for any campaign, and we will not sell it. We keep the names for seven years, then we delete them and keep only the numbers.

You can say no. If you say no, you will still be helped. If you are under 18, we need your parent or guardian to agree. You may ask us at any time what we wrote about you, ask us to correct it, or ask us to remove it. Ask any member of our team here, or call +234 707 633 0522 or +234 805 146 6501.

Staff reading this notice must tell people that help does not depend on agreeing to photographs, and must record any refusal.