Credit Direct Limited (“CDL”, “we”, “our”, or “us”) is committed to protecting the personal information of job applicants and its employees. This Notice sets out important information about how CDL collect and use your personal information during the course of your employment and after your employment has ended. You should read this Notice carefully and raise any questions you may have with the People Management or Data Protection Officer.

1. What Personal Information Do We Collect About You?

Personal information means any data which identifies you and relates to you as an individual. As a job applicant or employee, CDL will collect, use and store your personal information for a wide variety of reasons in connection with the employment relationship. We have set out below the following categories of employee personal information which we process about you:

• personal contact information (including your name, home address, personal telephone number(s) and personal e-mail address);
• business contact information (including e-mail address and telephone number);
• job title and corporate grade;
• date of birth;
• gender;
• marital status;
• passport / portrait photograph;
• Regulatory ID (International Passport, Driver’s License, National Identity Card or Permanent Voters Card);
• tax and pension information;
• emergency contact information / next of kin details;
• bank account details;
• sensitive personal information (including religion, blood group and genotype);
• documents gathered during the recruitment process (including cv, application form, references, professional memberships and qualifications, and background vetting information)
• general employment records including details of training, disciplinary and grievance matters, benefits, holiday and other absences, performance records (including appraisals) and salary history;
• information gathered through CDL’s monitoring of its IT systems, building access records and CCTV recording; and
• personal information which you otherwise voluntarily provide, for example when using your company e-mail.

The personal information we collect is mandatory in order for us to administer an employment relationship and/or comply with statutory requirements relating to your employment. Failure to provide personal information may affect our ability to accomplish the purposes stated in this Notice and potentially affect our recruitment process and your employment.   The list set out above is not exhaustive, and there may be other personal information that CDL collects, stores and uses. We will update this Notice from time to time to reflect any notable changes in the categories of personal information which we process.

2. How Do We Get Your Personal Information?

The personal information which we process will be collected in a variety of ways and from the following sources:

• directly from you;
• from notes made during your recruitment interview;
• from a recruitment agency;
• in some circumstances, your personal information may be provided by third parties, such as former employers, health providers from your medical test; and
• from background checks and investigation.

3. Why Does CDL Process Your Personal Information?

CDL processes your personal information for a variety of purposes:

• in order to perform its obligations under your employment contract or take steps to enter into a contract with you;
• where we need to comply with a legal obligation or any statutory requirements;
• where we have a legitimate business interest;
• where it is in your vital interest;
• where it is in the interest of the public; or for official purposes; or in furtherance of national security or investigation; and
• when we have obtained consent from you.

4. How Do We Use Your Personal Information?

CDL will only use your personal information for different purposes and when the law allows us to or in the following circumstances:

• the payment of salary and the administration of benefits under the employment contract;
• the management of tasks and responsibilities;
• to manage performance, including the conduct of annual appraisals;
• to consider eligibility for promotion or for alternative roles within CDL;
• to comply with legal requirements, such as reporting to the local tax authority;
• to address disciplinary and grievance issues with individual employees;
• to protect CDL’s confidential and proprietary information, and intellectual property;
• to monitor the proper use of CDL’s IT systems;
• to prevent fraud against CDL and its clients; and
• if a business transfer or change of ownership occurs

Again, this list is not exhaustive, and we may undertake additional processing of personal data in line with the purposes set out above. We will update this Notice from time to time to reflect any notable changes in the purposes for which it processes your personal information.

5. Who Has Access To Your Personal Information?

We may share your personal information internally with staff where it is necessary for them to undertake their duties.

When we disclose your personal information to third parties, we only disclose the personal information that is necessary for them to provide services.

6. Security Of Your Personal Information

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.  In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

7. Retention Of Your Personal Information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any regulatory, accounting, or reporting requirements.

To determine the appropriate retention period for the personal information we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, and the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

8. Your Personal Information Rights

You may have the following rights in relation to your personal information:

• Right of withdrawal of Consent – To withdraw your consent for the processing of your personal information if we are relying on consent and have no other legal grounds for processing your personal information, you can withdraw your consent.
• Right of Access – To request a copy of the personal information processed in relation to you.
• Right of Correction – To request that we correct your personal information. You have a right to request an update to any of your personal information that is out of date or incorrect.
• Right to Object – To object to how we process your personal information. If you have any concerns about how we process your personal information, please send your request to People Management via CDLPeopleMgt@fcmb.com or our Data Protection Officer via CDLDataProtection@fcmb.com.
• Right to Restriction of processing – To restrict how your personal information. This enables you to ask us to suspend the processing of personal information about you.
• Right to Portability – To request a copy of the personal information you have given to us in a machine-readable format. However, it is expected that you shall have taken all steps to ensure the security and safety of the medium of receiving the data and CDL shall not be liable for any disclosure of your personal information provided that same was not as a result of the negligence or willful misconduct of CDL.
• Right to Erasure – To ask us to delete your personal information, for example if we no longer have a valid reason to process it. This may be subject to extant relevant legislations requiring retention of personal information of specific data subjects.

9. Complaints

If you have a complaint in relation to the processing of your personal information and you are not happy with the way we deal with it, please discuss this at our office or with our People Management Team or contact the Data Protection Officer (DPO).

You also have the right to complain to the data protection authority currently the Nigeria Data Protection Bureau (NDPB).

10. Remedies And Contacting Us

In the event of a breach of personal information, CDL shall within 72 (Seventy-Two) hours of having knowledge of such breach report the details of the breach to NDPB. Furthermore, where we ascertain that such a breach is detrimental to your rights and freedoms in relation to your personal information, we shall take reasonable steps to inform you of the breach incident.

Where you have concerns relating to the processing of your personal information by Credit Direct Limited or require any clarification on this Notice, please notify us through or contact details provided below:

cdldataprotection@fcmb.com

Credit Direct Limited
48/50 Isaac John Street, GRA,
Ikeja, Lagos, Nigeria

We will respond to your concerns within one month of receiving your notice.

11. Changes To This Privacy Notice

This Privacy Notice may be updated from time to time, and you are advised to visit this site regularly to check for any amendments.