Nigeria has never been known for half-measures. When we decide something matters, we rarely ease into it. We move decisively, sometimes noisily, and often with a confidence that precedes consensus. That instinct was on full display in 2019, when Nigeria turned its attention to data protection and chose an uncompromising route. Under the Nigeria Data Protection Regulation, almost every organisation handling personal data was expected to appoint a Data Protection Officer.
This was not framed as best practice or gradual alignment. It was a requirement, applied broadly and without much ceremony. Banks, fintechs, logistics firms, SMEs, startups were all swept into scope. If personal data passed through your systems, someone had to be named and accountable. In a business environment often criticised for informality and improvisation, the insistence on formal responsibility was striking.
The move was also unusually ambitious given the context. At the time, Nigeria was still strengthening its regulatory institutions and digital infrastructure. Enforcement capacity was uneven, and organisational understanding of privacy was limited. Yet the regulation positioned data governance as something serious, structured, and unavoidable. Data protection was not to be treated as a legal footnote or a technical inconvenience. It was framed as a leadership responsibility.
What made this posture especially notable was how far it went compared to international practice. In Europe, where data protection enjoys near-mythical status, not every organisation is required to appoint a Data Protection Officer. The obligation is triggered by risk, scale, and the nature of processing activities. Public bodies and organisations engaged in extensive monitoring or sensitive data processing fall within scope, while many smaller operators do not. Nigeria initially chose a much broader application.
The contrast with the United States is even sharper. Despite hosting some of the world’s largest data-driven companies, there is no general requirement for organisations to appoint a privacy officer outside certain regulated sectors. Nigeria, at least on paper, briefly imposed a stricter standard than economies that export data-intensive services at scale. Such a contrast unsettled assumptions about who leads and who follows in regulatory seriousness.
Within Africa, Nigeria’s position sat firmly at the assertive end of the spectrum. Kenya adopted a similarly expansive approach, while Ghana opted for flexibility by making the role optional. South Africa introduced an information officer model that prioritised accountability without mandating a standalone privacy function for every organisation. Nigeria’s approach left little room for interpretation and little space for gradualism.
There were clear benefits to this posture. It accelerated awareness and forced conversations that many organisations would otherwise have postponed. It sent a signal to international partners that Nigeria was taking data governance seriously at a time when trust increasingly shapes commercial relationships. It also created a visible locus of responsibility within organisations, even if that responsibility was not always fully understood.
The practical challenges, however, surfaced quickly. Mandating a Data Protection Officer for organisations of every size exposed capacity gaps. Skilled practitioners were scarce, and smaller businesses struggled to interpret what meaningful compliance looked like. In many cases, organisations complied in form rather than substance, appointing DPOs on paper while operational practices remained unchanged. Enforcement mechanisms struggled to keep pace with the breadth of the obligation.
The result was predictable. Compliance existed, but effectiveness varied widely. The gap between regulatory ambition and operational reality became harder to ignore as the ecosystem matured.
This is where Nigeria’s regulatory journey becomes more instructive than symbolic. With the introduction of a new Data Protection Act, the country adjusted course. The requirement to appoint a Data Protection Officer now applies primarily to data controllers of major importance. Scale and risk once again matter, and proportionality has been restored. Large, data-intensive organisations remain clearly within scope, while smaller players are spared unnecessary regulatory weight.
This shift reflects learning rather than retreat. Nigeria tested an expansive model, observed its limitations, and recalibrated. The initial ambition helped build awareness and professionalise privacy discussions. The subsequent refinement restored balance without undermining intent.
For Nigerian business leaders, the implications are clear. Data protection is no longer optional or cosmetic. It is an operational discipline that shapes credibility, partnerships, and resilience. The real question is not whether privacy matters, but whether it is being governed with clarity, judgement, and realism. Nigeria’s experience shows that serious systems are built not through perfection, but through the willingness to adjust when reality demands it.
Michael Irene, CIPM, CIPP(E) certification, is a data and information governance practitioner based in London, United Kingdom. He is also a Fellow of Higher Education Academy, UK, and can be reached via moshoke@yahoo.com; twitter: @moshoke
