Responding to Data Breaches in Nigeria: A Step-by-Step Plan for Businesses
In 2024, multiple Nigerian banks and fintechs were hit with attempted cyber intrusions, with one breach reportedly exposing over 100,000 customer records. Cybersecurity threats continue to intensify across Africa, with Nigeria consistently ranking among the most targeted countries. This article provides practical, regulatory-aware guidance on responding to data breaches in Nigeria.
These are not distant threats. They are happening now, with real consequences.
What matters most is how you respond. This guide breaks down exactly what to do, including how to navigate Nigerian regulations like the Nigeria Data Protection Act (NDPA) 2023.
Quick Response Checklist
First Hour: Activate Incident Response Plan, isolate compromised systems, preserve evidence, notify response team
First Day: Assess scope with forensics, document everything, determine if breach meets NDPA high-risk threshold, begin regulatory notification if required
First Week: Complete NDPA notification (within 72 hours if high risk), notify affected individuals, implement immediate security improvements, and brief senior leadership
Step 0: Responding to Data Breaches in Nigeria Starts with Preparation
The worst time to figure out your breach response is when you’re already in crisis mode. Preparation isn’t optional.
Develop a Formal Incident Response Plan
Your IRP must include:
- Clear roles and responsibilities with RACI matrix (Responsible, Accountable, Consulted, Informed)
- Escalation paths to the board and senior leadership for material breaches
- Decision-making authority at each level
- Communication protocols and flow charts
- Contact information for IT, legal, compliance, and executive leadership
- Regulator contact details (NDPC, NITDA, CBN, EFCC)
- Regulator-ready notice templates with required data fields
- Decision logging procedures
- Emergency hotline numbers for external partners
Test It and Build Partnerships
Run tabletop exercises regularly. Vet forensic firms, legal counsel, cyber insurers, and PR agencies before you need them. Get their emergency contacts and understand their response capabilities.
Learn more: Key Features of the Nigeria Data Protection Act 2023
Step 1: Contain and Mobilize
The moment you suspect a breach, speed matters.
Activate and Contain
Treat indicators as real until disproved. Disconnect compromised systems, disable accessed accounts, change credentials immediately, and block suspicious IP addresses. Limit access to affected systems and enable write-blocking where possible to preserve forensic integrity and chain of custody.
Preserve evidence. Don’t wipe drives or reimage systems yet. Forensic investigators need to see what happened.
Lesson learned: A Nigerian e-commerce company wiped their compromised server before forensics arrived. They never fully understood the attack vector, and regulators weren’t pleased.
Mobilize Your Team
Get the right people involved: IT and security, legal, compliance, communications, and senior management. Assign a single spokesperson for all communications to avoid confusion.
For best practices in incident handling, refer to the NIST Computer Security Incident Handling Guide, SP 800-61 Rev. 3 (2025).
Step 2: Assess the Scope and Impact
Work with forensic experts to establish the full picture. This investigation phase is critical and shouldn’t be rushed.
Key Questions to Answer
What type of data was accessed?
- Personal information (names, addresses, phone numbers, email addresses)
- Financial records (account numbers, transaction history, payment card data)
- Health data (medical records, test results, treatment information)
- Intellectual property (trade secrets, proprietary information, source code)
- Authentication credentials (passwords, security questions, access tokens)
How many individuals and records were affected?
Initial estimates are often wrong. What appears to be 500 affected records may actually be 5,000 once the forensic analysis is complete.
What was the root cause and attack vector?
Understanding how attackers got in is essential for preventing repeat breaches. Common vectors include phishing attacks, unpatched vulnerabilities, misconfigured security settings, compromised vendor access, or insider threats.
When did the breach actually start?
Many breaches go undetected for weeks or months. Check logs carefully.
Engage Forensics Through Legal Counsel
Engage forensics through legal counsel to help protect findings under the attorney-client privilege. This matters if the breach leads to litigation or regulatory investigations.
Create a Formal Timeline Document
Document everything: when discovered, which systems were affected, every decision made and why, who was notified and when, and all actions taken.
Lesson learned: Poor documentation can make organizations appear unprofessional to regulators, even when response efforts are solid.
Step 3: Notify Regulators, Authorities, and Insurers in Nigeria
NDPA 2023 Requirements
The NDPA requires you to notify the Nigeria Data Protection Commission (NDPC) within 72 hours if the breach poses a high risk.
Start the notification workstream as soon as high risk is likely to occur. The 72-hour clock won’t pause while you investigate—and it includes weekends and holidays.
See NDPC official resources for guidance.
Also, compare with the European Data Protection Board breach notification guidelines for a global context.
Other Required Notifications
Financial services: Notify the Central Bank of Nigeria
Criminal Breaches: Report to EFCC – Channels of Reporting Complaints
Critical infrastructure: Align with NITDA’s frameworks where applicable
Insurance: Notify your cyber liability insurer immediately.
Lesson learned: A Nigerian logistics company waited two weeks to notify their insurer. The claim was denied, resulting in a loss of over ₦50 million.
Step 4: Communicate Transparently with Affected Parties
The NDPA requires you to notify affected individuals directly when there is a high risk of harm.
Use this notification outline:
- What happened: Brief, plain-language description
- What data was exposed: Specific data types
- What we’ve done: Immediate actions taken
- What you should do: Clear protection steps
- Where to get help: Direct contact information
Bad example: “We experienced an unauthorized access event affecting our database infrastructure.”
Good example: “Someone gained unauthorized access to our customer database on September 15. They may have accessed your name, email, phone number, and account balance. We’ve secured the system and are working with security experts. Change your password immediately and monitor your account.”
Offer remedies like password reset support, credit monitoring, dedicated helplines, or fraud protection.
Step 5: Eradicate and Recover
Patch exploited vulnerabilities and fix misconfigurations. Strengthen defenses by enforcing MFA, updating access controls, reviewing vendor access, and implementing better monitoring tools.
Restore from clean backups only after validating that all vulnerabilities have been remediated and monitoring is active.
For current trends and costs, see IBM Cost of a Data Breach Report
Step 6: Learn and Improve
Conduct a Post-Incident Review
Deliverables: incident report, root-cause analysis, lessons-learned memo, updated IRP, training plan, board briefing.
Ask why every failure occurred and be honest about what worked. List specific technical and procedural improvements.
Lesson learned: One Nigerian logistics company updated their IRP after each minor breach. By the third incident, response time dropped from 48 hours to 4 hours.
Train Your Staff
Run phishing simulations, conduct workshops, update onboarding materials, and refresh training quarterly.
Step 7: Rebuild Trust After Responding to Data Breaches
Show Concrete Proof
- Commission third-party audits
- Conduct penetration testing
- Create a security status page
- Pursue certifications (ISO 27001, SOC 2)
- Publish transparency reports
Follow Up Consistently
Update customers on improvements, share milestones, and demonstrate sustained commitment.
Companies that demonstrated accountability and transparency often emerged with stronger reputations.
Related reading: Data Protection Compliance in Nigeria: Strategies for Success
The Bottom Line
A data breach is a defining moment for any organization. The difference between reputational damage and renewed trust lies in your response.
Start preparing now. Here’s your action plan:
Day 1-2: Audit your current state.
Day 3-4: Identify gaps.
Day 5-7: Start building.
The NDPC is actively enforcing the NDPA. Customers are more aware of their rights. The cost of being unprepared is rising.
Preparation doesn’t require massive budgets. It requires commitment, planning, and consistent effort.
Need Help Getting Started?
At PlanetWeb Solutions, we share practical insights, research, and strategies to help Nigerian businesses strengthen their cybersecurity posture.
Explore more thought leadership and resources for practical cybersecurity guidance tailored to Nigerian organizations: Cybersecurity & Data Protection
Related articles:
