Privacy Policy

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.

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.

3 What we collect, why, and on what legal ground

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.

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

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

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.

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