| Today’s topic | The 90-Day Compliance Programme |
|---|---|
| Estimated time | 60-90 minutes |
| Primary Act reference | Whole Act |
| Guide reference | Guide pp.12-17 |
Learning Objectives
Explain and apply days 1-30 priorities.
Explain and apply days 31-60 implementation.
Explain and apply days 61-90 remediation.
Explain and apply governance evidence.
Explain and apply dashboard and management reporting.
Diagnostic Assessment
Attempt these questions before reading the model responses.
1. What is the principal compliance issue addressed by Whole Act?
Show model response
Model response: It is the 90-day compliance programme. The analysis should focus on days 1-30 priorities and the connected statutory conditions.
2. Identify two concepts that must be considered when analysing the 90-day compliance programme.
Show model response
Model response: Any two of the following are relevant: days 1-30 priorities, days 31-60 implementation, days 61-90 remediation, governance evidence.
3. Why should a DPO cite the exact section instead of relying only on a general privacy principle?
Show model response
Model response: The section contains the controlling conditions, limits and exceptions. A general principle may guide analysis but cannot replace the specific statutory test.
4. What evidence should an organisation retain when applying Whole Act?
Show model response
Model response: It should retain the facts considered, the statutory test, the decision, supporting records, responsible approval and any review or corrective action.
5. How should the organisation respond when the uploaded sources do not resolve a material detail?
Show model response
Model response: It should record the limitation and avoid inventing a requirement. The DPO should return to the full statutory wording and seek current authoritative material when permitted.
Structured Lesson
1. Days 1-30 Priorities
Days 1-30 priorities is a central issue for this study day. The DPO should locate the exact statutory conditions in Whole Act, apply them to the particular processing activity and retain evidence supporting the conclusion.
2. Days 31-60 Implementation
Days 31-60 implementation is a central issue for this study day. The DPO should locate the exact statutory conditions in Whole Act, apply them to the particular processing activity and retain evidence supporting the conclusion.
3. Days 61-90 Remediation
Days 61-90 remediation is a central issue for this study day. The DPO should locate the exact statutory conditions in Whole Act, apply them to the particular processing activity and retain evidence supporting the conclusion.
4. Governance Evidence
Governance evidence is a central issue for this study day. The DPO should locate the exact statutory conditions in Whole Act, apply them to the particular processing activity and retain evidence supporting the conclusion.
5. Dashboard And Management Reporting
Dashboard and management reporting is a central issue for this study day. The DPO should locate the exact statutory conditions in Whole Act, apply them to the particular processing activity and retain evidence supporting the conclusion.
Nigerian Scenario and Model Analysis
A Akwa Ibom State ministry begins a project involving staff or customer personal data. The project raises questions about days 1-30 priorities and days 31-60 implementation. Identify the controller, any processor, the data subjects, likely personal data, the required statutory analysis under Whole Act, key risks and the compliance evidence that should be retained.
Show model response
Model analysis: The organisation determining why and how the project operates is normally the controller. A vendor acting only on documented instructions is normally a processor. Staff or customers are the data subjects. The DPO should inventory the data, apply Whole Act to the stated purpose, document the decision, assign controls and retain evidence. The final conclusion depends on the precise facts and statutory conditions.
Lesson Summary
Day 29 establishes how a DPO should understand and apply the 90-day compliance programme. The legal starting point is Whole Act. The main operational lesson is to connect days 1-30 priorities, days 31-60 implementation, days 61-90 remediation to documented facts and evidence.
Ten Key Terms
| Term | Working definition |
|---|---|
| Controller | A person or body that determines the purposes and means of processing personal data. |
| Processor | A person or body that processes personal data on behalf of a controller. |
| Data Subject | The identified or identifiable individual to whom personal data relate. |
| Personal Data | Information relating to an identified or identifiable individual. |
| Processing | An operation performed on personal data, including collection, use, storage, disclosure or deletion. |
| Lawful Basis | A statutory justification that permits processing under section 25. |
| Accountability | Responsibility for compliance and the ability to demonstrate it with evidence. |
| Security | Risk-appropriate technical and organisational protection for personal data. |
| Recipient | A person or body to whom personal data are disclosed. |
| Dpo | A Data Protection Officer who advises, monitors compliance and acts as a regulatory contact under section 32. |
Definitions are paraphrased for study. Check section 65 and the relevant operative provision for controlling wording.
Five Revision Questions and Responses
1. What provisions govern this lesson?
Show model response
Response: Whole Act
2. What are the principal concepts?
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Response: days 1-30 priorities, days 31-60 implementation, days 61-90 remediation, governance evidence, dashboard and management reporting.
3. What is the correct source hierarchy?
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Response: The Act is primary authority. The Guide supports learning and professional application. Tutor explanation assists interpretation without creating new law.
4. What is the central evidence requirement?
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Response: Record the facts, applicable test, conclusion, approval, controls and review trigger.
5. What common error should be avoided?
Show model response
Response: Do not assume a broad principle answers the issue. Test the exact conditions and exceptions in the assigned section.
Five Multiple-Choice Questions
1. Which source provides the primary statutory rule for Day 29?
A. The Guide
B. The Act
C. A workplace policy
D. A vendor contract
2. Which provision set should be consulted first?
A. Section 1 only
B. Whole Act
C. Section 65 only
D. No statutory provision
3. What should follow identification of the relevant section?
A. Assume compliance
B. Test conditions and exceptions
C. Ignore evidence
D. Use consent automatically
4. Which record best supports accountability?
A. An undocumented opinion
B. A reasoned decision record
C. A verbal assurance
D. A marketing brochure
5. If the sources do not resolve a detail, what should the learner do?
A. Invent a rule
B. State the limitation
C. Cite an unrelated law
D. Ignore the uncertainty
Show model response
Answer key: 1-B, 2-B, 3-B, 4-B, 5-B. Review the lesson citations before marking.
Practical Workplace Task
Prepare a one-page compliance record for a Nigerian organisation applying Whole Act. Include the processing purpose, actors, data subjects, personal data, statutory test, risks, decision, controls, owner, evidence and review date.
Show model response
Expected deliverable: A dated, approved record that links factual evidence to each applicable statutory condition and records any unresolved issue.
Three Flashcards
Front: Act reference for Day 29? | Back: Whole Act
Front: Central topic? | Back: The 90-Day Compliance Programme
Front: Best analysis habit? | Back: Facts → role → section → conditions → evidence.
Reread and Progress Record
Reread: Whole Act; Guide pp.12-17.
| Date completed | ________________ | Score | ______% |
|---|---|---|---|
| Strong areas | ________________ | Weak areas | ________________ |
| Recommended revision | ________________ | Readiness | Developing / Competent / Ready |