For businesses collecting and processing personal data in Nigeria, understanding the law is only the first step. Organisations also need to know how to put data protection requirements into practice.
This is where Data Protection Compliance Organisations (DPCOs) come in. The role has become highly important as Nigeria’s data protection framework develops and more organisations come under regulatory oversight.
The NDPC’s 2025 Annual Report describes licensed DPCOs as institutional partners in building a resilient and trusted data-protection ecosystem, noting their role in supporting compliance frameworks, regulatory standards and responsible data-driven growth.
But what exactly does a DPCO do, when does a business need one, and what should an organisation look for before engaging one?
What is a DPCO?
Data Protection Compliance Organisations (DPCOs) are organisations licensed by the Nigeria Data Protection Commission (NDPC) to provide professional services that help businesses and other organisations meet their data-protection obligations. Their work can include compliance consulting, audits, training, privacy advisory services, breach-response support and other data-protection services.
Section 33 of the Nigeria Data Protection Act 2023 provides for the licensing of persons or organisations with the requisite expertise to monitor, audit and report on compliance by data controllers and data processors.
The NDPC’s current DPCO registration and requirements guidance describes a DPCO as an entity licensed to provide training, auditing, consulting and other services aimed at compliance with the Nigeria Data Protection Act 2023 or applicable foreign data-protection laws or regulations having effect in Nigeria.
DPCOs can include different types of professional organisations, such as:
- Professional service and consultancy firms
- IT service providers
- Audit firms
- Law firms
The important factor is not the type of business itself but whether the organisation has the relevant expertise and has obtained the required NDPC licence.
The NDPC maintains a public list of licensed DPCOs, which businesses can use when looking for an authorised provider.
What does a DPCO actually do?
A DPCO can provide a range of services depending on its licence and areas of expertise.
The NDPC identifies services that can include:
- Data-protection compliance and breach services
- Privacy advisory services
- Data-protection training and awareness
- Data-protection contract drafting and advisory
- Privacy-breach remediation planning and support
- Information privacy audits
- Data-breach impact assessments
- Data-protection due diligence investigations
- Outsourced Data Protection Officer services
This means that a DPCO’s role can extend well beyond completing an annual audit.
A business may engage a DPCO at different stages of its data-protection journey, from understanding its obligations and identifying compliance gaps to preparing for an audit or responding to a privacy incident.
How DPCOs help businesses understand their data-protection obligations
One of the first challenges businesses face is simply understanding what the data-protection rules mean for their particular operations.
A fintech, for example, does not process the same types of information as a school. A hospital does not have the same data environment as an e-commerce company. An employer may process employee information that requires different controls from those used by a telecommunications company.
A DPCO can assess an organisation’s activities and help identify the data-protection requirements that apply to its operations.
This can involve reviewing:
- What personal data the organisation collects
- Why the data is collected
- The legal basis for processing
- Who can access the information
- Where information is stored
- Which third parties process it
- Whether information is transferred outside Nigeria
- How long information is retained
- What security measures are in place
- How data-subject requests are handled
The goal is to turn broad legal requirements into practical processes that fit the organisation.
1. DPCOs can help organisations identify compliance gaps
A company may believe it is compliant simply because it has a privacy policy or has registered with the NDPC.
But data protection covers much more than having a document or obtaining a registration certificate.
A DPCO can conduct an assessment of the organisation’s existing practices and identify areas where its policies, systems or procedures may not adequately address applicable requirements.
For example, an assessment could reveal that:
- Employees have excessive access to customer information.
- A business does not have a clear process for handling data-subject requests.
- Vendor contracts do not adequately address data processing.
- Personal information is retained longer than necessary.
- International data transfers have not been properly assessed.
- The organisation’s breach-response process is unclear.
- The organisation’s privacy notices do not adequately explain its processing activities.
Identifying these gaps before a regulatory investigation or data breach can allow an organisation to address them.
2. DPCOs and data protection audits
Auditing is one of the most visible functions associated with DPCOs.
The purpose of a data-protection audit is to assess an organisation’s practices against applicable data-protection requirements and identify areas that require attention.
This can involve reviewing the organisation’s:
- Policies
- Procedures
- Data-processing activities
- Security controls
- Vendor relationships
- Data-subject rights processes
- Records and documentation
- Privacy notices
- Governance structures
The NDPC’s framework provides for Compliance Audit Returns, and its current FAQ states that CARs are filed with the Commission through a licensed DPCO.
This is an important distinction.
An organisation may use other professional advisers for particular aspects of its privacy programme, but where the regulatory framework requires a DPCO verification statement for a Compliance Audit Return, that function must be performed through an appropriately licensed DPCO.
What is a Compliance Audit Return?
A Compliance Audit Return, commonly referred to as a CAR, is part of the NDPC’s ongoing regulatory oversight.
The NDPC currently states that Data Controllers are expected to file their audit returns annually before 31 March each year under the relevant provisions of the NDP Act and GAID 2025.
The Commission also states that CARs are filed through licensed DPCOs.
This means an organisation that falls within the applicable category cannot simply prepare an internal document and submit it independently where a licensed DPCO verification statement is required. The DPCO’s involvement provides an external compliance function within the regulatory framework.
However, submitting an audit return should not be confused with having perfect compliance.
The NDPC’s earlier regulatory reporting specifically noted that submission of an audit report alone does not necessarily indicate full compliance.
That remains an important point for organisations to understand.
3. DPCOs can provide data-protection training
Data protection is not only a legal or IT responsibility.
Employees across an organisation may handle personal information every day. Customer-service representatives, HR teams, sales staff, marketers, finance teams, developers and administrators can all encounter personal data.
A DPCO can therefore provide training and awareness programmes designed to help employees understand their responsibilities.
Training may cover areas such as:
- Handling personal information
- Recognising privacy risks
- Responding to data-subject requests
- Secure information handling
- Phishing and social-engineering risks
- Data-sharing procedures
- Breach reporting
- Privacy-by-design principles
- Employee responsibilities under organisational policies
This matters because even a well-designed privacy programme can fail if employees do not understand how they are expected to handle personal information.
4. DPCOs can support organisations during a data breach
A data breach can create significant pressure for an organisation.
When personal information is exposed, stolen, accessed without authorisation or otherwise compromised, the organisation may need to determine what happened, assess the affected information, contain the incident and take appropriate regulatory and operational steps.
Some DPCOs provide breach-response and remediation services, including privacy-breach impact assessments and remediation planning.
A DPCO can therefore help an organisation assess the privacy implications of an incident and develop an appropriate response.
This is particularly relevant because data protection and cybersecurity can overlap during an incident.
A cybersecurity failure may result in a personal-data breach, while a data-protection issue may also expose weaknesses in an organisation’s information-security practices.
Techsoma previously examined this relationship in Nigeria’s data breach claims exposed a critical cybersecurity coordination gap.
5. DPCOs can help with privacy policies and contracts
Data protection obligations also affect an organisation’s agreements and documentation.
Depending on the organisation’s activities, a DPCO may help review or develop:
- Privacy notices
- Data-processing agreements
- Processor contracts
- Data-sharing agreements
- Employee privacy documentation
- Consent mechanisms
- Data-retention policies
- Breach-response procedures
- Internal data-protection policies
The NDPC lists data-protection contract drafting and advisory services among the services DPCOs may provide.
This can be particularly useful for organisations that work with multiple technology vendors or process personal information on behalf of other organisations.
6. DPCOs can support data-protection due diligence
Businesses increasingly rely on third-party technology providers.
A company may use a cloud hosting provider, payment processor, customer relationship management platform, HR software, marketing platform or other service that processes personal information.
This creates another layer of risk.
Before sharing personal data with a third party, an organisation may need to understand how that provider handles the information, what security controls it uses, where the information is stored and what contractual protections are in place.
The NDPC lists Data Protection and Privacy Due Diligence Investigation among the services that licensed DPCOs may provide.
A DPCO can therefore help an organisation evaluate third-party data-processing arrangements and identify areas that require stronger controls.
Can a DPCO act as an outsourced Data Protection Officer?
Yes, the NDPC’s current DPCO service description includes outsourced Data Protection Officer services.
This can be relevant to organisations that need specialist data-protection expertise but do not have the resources or operational need to maintain a large internal privacy team.
However, outsourcing the DPO function does not mean management can completely hand off accountability for the organisation’s data practices.
The organisation still needs to understand how it processes personal data and provide the DPO with the access and organisational support necessary to perform the role effectively.
The DPO should not simply be a name attached to a registration form.
Why might a business engage a DPCO?
There are several practical reasons an organisation may choose to work with a licensed DPCO.
Specialist expertise
Data protection combines legal, technical, governance and operational issues.
A DPCO can bring specialist knowledge that may not exist internally, particularly for businesses without dedicated privacy professionals.
Independent assessment
An external review can identify weaknesses that internal teams may overlook.
This can be particularly useful before an organisation submits a Compliance Audit Return or launches a new data-intensive product.
Regulatory preparation
Working with a DPCO can help an organisation understand what information it needs to document and what areas require attention before dealing with the regulator.
Employee awareness
Training can help ensure that data protection is understood across the organisation rather than being treated as the responsibility of one compliance officer.
Breach preparedness
Organisations can use DPCO expertise to develop or test processes for responding to privacy incidents before an actual breach occurs.
Third-party risk management
DPCOs can help organisations assess vendors and processors that handle personal data on their behalf.
Ongoing compliance
Data protection requirements do not end after registration. An external compliance partner can help organisations maintain their privacy programme as their business, technology and regulatory obligations change.
Does every organisation have to hire a DPCO?
No. This distinction is important.
The existence of the DPCO licensing framework does not mean every organisation that processes personal data must permanently retain a DPCO.
The NDPC’s FAQ states that professionals are not prohibited from advising clients on data protection. However, only licensed DPCOs can provide the competent verification statement for Compliance Audit Returns.
So, the need to engage a DPCO depends on the organisation’s regulatory obligations and the services it requires.
For example, a business may engage a DPCO for an audit, compliance assessment, training programme, breach response or outsourced DPO service without necessarily requiring the DPCO to manage every aspect of its privacy programme.
Does hiring a DPCO make a business compliant?
No. This is another distinction businesses need to understand.
A DPCO can provide professional advice, audits, training and other compliance services, but the organisation remains responsible for how it processes personal data.
Engaging a consultant does not automatically protect a business from regulatory consequences.
The organisation still needs to:
- Process personal data lawfully.
- Protect personal information appropriately.
- Respect data-subject rights.
- Manage processors and third-party vendors.
- Maintain appropriate records.
- Respond to data breaches.
- Meet applicable registration obligations.
- File required Compliance Audit Returns.
- Implement recommendations arising from compliance assessments.
A DPCO can help an organisation fulfil these responsibilities, but it cannot take ownership of the organisation’s entire legal responsibility.
This is why businesses should view DPCOs as compliance partners rather than compliance substitutes.
How should a business choose a DPCO?
Choosing a DPCO should involve more than looking for the cheapest provider.
The first step should be to confirm that the organisation is actually licensed by the NDPC.
The Commission maintains a public register of licensed DPCOs, which organisations can use to verify a provider’s status.
Businesses should then consider the provider’s relevant experience.
For example:
- Does it understand your industry?
- Has it worked with organisations of a similar size?
- Does it understand your type of data processing?
- Does it have legal and technical expertise?
- Can it support your specific compliance needs?
- Does it have experience with audits and CAR filing?
- Can it support breach response?
- Does it understand international data transfers?
- Can it provide employee training?
- Will it provide practical recommendations rather than only documents?
The right DPCO will depend on the organisation’s needs.
A bank with extensive financial and identity data may need a different level of expertise from a small technology company or professional-services firm.
What should businesses ask before signing a DPCO?
Before engaging a DPCO, organisations can ask:
What exactly will you be responsible for?
The organisation should understand whether the engagement covers auditing, consulting, training, DPO services, breach support, CAR filing or another specific service.
Are you currently licensed by the NDPC?
The organisation should verify the provider through the Commission’s official register rather than relying solely on the provider’s own claims.
Who will actually work on our account?
Understanding the team’s qualifications and experience can be important, particularly for complex processing environments.
What will the assessment cover?
A good engagement should clearly define the scope of the review.
What happens after the audit?
The organisation should understand whether the DPCO will help prioritise and address identified gaps or simply deliver a report.
How will confidential information be handled?
A DPCO may receive access to sensitive organisational and personal information, so confidentiality and security arrangements should be considered carefully.
What happens if a DPCO fails to do its job?
DPCOs themselves are subject to regulatory oversight.
The NDPC’s DPCO requirements state that a DPCO found guilty of concealing or abetting a data breach by a data controller or processor can lose its licence, with previous reports potentially subject to investigation.
This is important because the DPCO framework is not simply a commercial consultancy arrangement.
Licensed DPCOs operate within a regulatory ecosystem overseen by the NDPC.
The Commission’s 2025 Annual Report describes DPCOs as institutional partners in the data-protection ecosystem and highlights their role in supporting compliance frameworks and responsible data-driven growth.
DPCOs and Nigeria’s growing data-protection ecosystem
The need for professional data-protection services is becoming more significant as more Nigerian organisations come under regulatory oversight.
The NDPC reported in its 2025 Annual Report that more than 38,000 entities had been placed under regulatory oversight through DCPMI registration by the end of 2025. The Commission linked this expansion to greater accountability and transparency in data processing.
The same report describes DPCOs as key institutional partners supporting the development and implementation of data-protection standards and best practices.
This means DPCOs have a role beyond individual audits.
They are part of the infrastructure supporting Nigeria’s wider data-protection ecosystem.
DPCO vs Data Protection Officer: Are they the same thing?
No. The two roles are related but different.
A Data Protection Officer (DPO) is responsible for supporting data-protection governance within an organisation.
A DPCO, on the other hand, is an external organisation licensed by the NDPC to provide professional data-protection compliance services.
An organisation can have an internal DPO and still engage a DPCO for an audit, training, consulting, breach response or other specialist work.
In some circumstances, a licensed DPCO can also provide outsourced DPO services.
The simplest way to think about it is:
DPO = a data-protection role.
DPCO = a licensed professional organisation that provides data-protection compliance services.
Final thoughts
Data protection compliance can become complicated as an organisation grows.
A business may start by collecting basic customer information and later introduce cloud systems, payment platforms, marketing tools, employee-management software, analytics systems and other technologies that process personal data.
With every new system, vendor and business process, the organisation may create new data-protection considerations.
A licensed DPCO can provide specialist support in navigating that environment.
From audits and training to privacy advisory services, breach response, due diligence and outsourced DPO support, DPCOs can help organisations turn the requirements of Nigeria’s data-protection framework into practical processes.
But businesses should remember that engaging a DPCO does not remove their own responsibility.
The organisation remains accountable for the personal data in its custody.
The best use of a DPCO is therefore not to outsource compliance, but to bring in qualified expertise that helps the organisation understand its obligations, identify gaps, strengthen its controls and maintain a more effective data-protection programme.
