Privacy Notice
[TO BE REVIEWED BY MPDA / LEGAL] This is placeholder text prepared for review. It has not been approved by MPDA, its data protection officer or a lawyer, and must not be treated as a statement of legal compliance.
Version: v2
1. Who we are
The Master Painters & Decorators Association, Lagos ("MPDA", "we", "us") runs this Membership Registration Portal. [CONFIRM WITH MPDA: registered name, address and registration details]
2. What we collect
When you register and apply for membership we collect:
- Account details: name, phone number, email address (optional) and a password (stored only as a one-way hash).
- Personal details: date of birth, gender, marital status (optional), residential address, state and local government area, and WhatsApp number (optional).
- Identity details: your National Identification Number (NIN), a passport photograph, and your chosen means of identification (National ID, Voter’s Card, International Passport or Driver’s License) with its number and dates of issue and expiry. An ID number other than your NIN is protected in the same way as your NIN.
- Professional details: your primary trade, years of experience, highest skill level, other skills, and (if applicable) your business name, address, LGA, state and the type of service offered.
- Next of kin details: the name, relationship, phone number and address of your next of kin, which you provide. We use them only to contact that person in an emergency or if we cannot reach you.
- Membership category and declaration: the category you apply for, and your typed signature with the date and time you signed.
- Referee details: the name, phone number, NIN, photograph, relationship and address of one referee that you provide.
- Technical and audit records: actions taken on your application, and delivery records for messages we send you (without the message contents).
3. Why we collect it and our lawful basis
| Purpose | Lawful basis [TO BE CONFIRMED BY MPDA / LEGAL] |
|---|---|
| Assess and verify your membership application | Steps taken at your request before entering into a membership |
| Verify your identity and prevent duplicate or fraudulent registrations | Legitimate interests of MPDA and its members |
| Contact your referee to confirm they agree to act as your referee | Legitimate interests of MPDA |
| Keep records of decisions and protect the security of the portal | Legitimate interests / legal obligations |
| Communicate with you about your application | Steps taken at your request; consent where required |
4. Who can see your information
Only authorised MPDA administrators can see your application. Your NIN and any other ID number are encrypted in storage, shown only in masked form in normal screens, and revealed in full only to an authorised administrator who explicitly requests it; each such access is recorded. Your passport photograph is stored privately and is never publicly accessible. We do not sell your information.
If you become an approved member, a public verification page (reached by scanning your membership card's QR code) shows only your name, membership number, profession, status and, if MPDA enables it, your photograph. It never shows your phone, NIN, address or referee details.
Service providers: we use providers for hosting, image storage, SMS/WhatsApp delivery, identity verification and payments. [LIST PROVIDERS AND COUNTRIES OF PROCESSING — TO BE CONFIRMED BY MPDA / LEGAL]
5. Your referee
The referee's details are provided by you. We send your referee a message asking whether they know you and agree to act as your referee. The confirmation page shows them only your name and photograph. If they decline, or do not respond in time, their NIN, photograph and other details are deleted.
6. How long we keep your information
| Information | Retention [TO BE CONFIRMED BY MPDA / LEGAL] |
|---|---|
| Draft applications that are never submitted | Deleted after a period of inactivity (currently 180 days), after a warning message |
| Rejected applications | Deleted after a set period (currently 12 months) |
| Referee data where the referee declined or did not respond | Deleted immediately |
| Approved membership records | Kept while you are a member and for a period afterwards [PERIOD TO BE CONFIRMED] |
| Audit records | Kept for security and accountability, with personal identifiers removed if you are erased |
7. Your rights
Under the Nigeria Data Protection Act 2023 you may have the right to: be informed about how your data is used; access your data; correct inaccurate data; request erasure; object to or restrict processing; and complain to the Nigeria Data Protection Commission. [CONFIRM WITH MPDA / LEGAL]
In this portal you can, from your dashboard's Privacy page:
- Download your data as a file. Your NIN is included only after you re-enter your password.
- Request deletion of your account and personal data. A super administrator reviews the request. Membership numbers are never reused, and a minimal non-identifying record may be kept for audit purposes.
8. Contact
Data protection officer: [NAME — TO BE PROVIDED BY MPDA] Email: [EMAIL — TO BE PROVIDED BY MPDA] Phone: [PHONE — TO BE PROVIDED BY MPDA] Address: [ADDRESS — TO BE PROVIDED BY MPDA]
9. Changes to this notice
When this notice changes we publish a new version and ask existing members to accept it the next time they log in.