1.0 Introduction and Scope

FITC LTD/GTE (The Company) is a non-profit world class, innovation-led, and technology-driven knowledge organisation that understands the importance of regulating the processing of personal information received by the Organization in compliance with General Data Protection Regulations.

This Data Protection and Privacy policy seeks describes our policies and procedures on the collection, use and disclosure of data considerations in the company’s operations. It is based respect for privacy rights, compliance with the law, and mitigation of the risk of data breaches.

The policy aims to integrate Data Protection and Privacy considerations into the company’s programmes, processes, and people operations to uphold the privacy rights of individuals. It recognizes that the Organization may collect personal data from programme participants, employees, directors, associates, facilitators, vendors, and other individuals (Data Subjects), for corporate purposes only if there is consent or deemed consent and the Data Subjects have been notified of such corporate purposes.

It also indicates the company’s commitment to the management of Data Protection and Privacy issues within the organisation and details the company’s responsibility towards a workplace that manages Data Protection and Privacy risk.

The Technology unit is responsible for the administration, revision, interpretation, and application of this policy.

The Board Corporate Strategy (Technical) Committee will provide oversight functional support in the administration of this policy.

The Board has ultimate responsibility for review and approval of this policy.

• Purpose and Objectives

The purpose of this policy is to promote a Data Protection and Privacy company culture that elicits strong socially responsible behavior within the company and its stakeholder relations. It outlines Data Protection and Privacy considerations and how they affect the company and its stakeholders’ relations in the collective responsibility.

It brings to the consciousness of the company workforce the impact of the company’s operations in relation to actions of Data Users with respect to the processing and handling of Data. Any third-party processing of data shall be subject to an agreement outlining the third party’s responsibility to comply with FITC Data Protection and Privacy Policy, including entering into a non-disclosure agreement.

This Policy does not specifically identify every circumstance or requirement for Data Protection and Privacy in the company. Therefore, it should not be assumed that any situation or requirement not described herein is exempt from the Policy.

Additionally, it is recognised that local and foreign laws may impose Data Protection and Privacy obligations or restrictions which are required for compliance. Such can be adopted accordingly.

Where a novel Data Protection and Privacy situation arises, leading to uncertainty regarding interpretation or application of this Policy or relevant law, a legal consultant may be referred for direction.

The objectives of this policy are to,

1.1.1 Support the Data Protection and Privacy practices in the company as well as compliance with relevant legal and regulatory requirements.

1.1.2 Safeguard information from unauthorized or unlawful processing, loss, theft, destruction, or damage.

1.1.3 Prevent external malicious actors and internal threats from gaining unauthorized access to data and systems in the company.

1.1.4 Provide and regulate provisions for Data Protection and Privacy in the company.

1.1.5 Integrate Data Protection and Privacy considerations into the company’s business operations.

1.1.6 Provide guidelines on how data should be collected.

1.1.7 Outline strategy to secure privacy, availability, and integrity of data.

1.1.8 Make a reasonable effort to ensure that personal data collected by the company or on its behalf is accurate and complete.

1.1.9 Promote and develop a culture of Data Protection and Privacy objectives.

2.0 Principles

2.1   In consideration of data protection and privacy within the company, the company prohibits any illegal or fraudulent practices in relation to data processing. Such activity must be reported and sanctioned appropriately as prescribed by the Board Corporate Strategy (Technical) Committee.

2.2 In consideration of good stakeholder data management, the company encourages acting bona fide towards colleagues and other stakeholders such as clients, suppliers, partners, service providers and collaborating companies, and regulatory authorities.

2.3   Requirement for Data Protection and Privacy considerations may arise and not limited to the following circumstances:

• Data Retention: The Company will retain Personal Data only for as long as is necessary for the purposes set out in this Policy. Retention and use of Personal Data is to the extent necessary to comply with legal obligations (such as data retention in compliance with applicable laws), dispute resolution, and enforcement of legal agreements and policies. The Company will also retain Usage Data for internal analysis purposes. Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of the Company’s Service,
• Data Transfer: Information, including Personal Data received is processed at the Company’s operating offices and any other places where the parties involved in the processing are located. It means that this information may be transferred to and maintained on computers located outside of the data subject state, province, country, or other governmental jurisdiction where the data protection laws may differ in jurisdiction. Consent to this Policy followed by Your submission of such information represents Your agreement to that transfer.
• The Company will take all steps reasonably necessary to ensure that data is treated securely and in accordance with this Privacy Policy and no transfer of Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of data and other personal information,
• Ensuring efficient administration of Data Protection and Privacy risks through its risk policy for risk management to assign responsibilities, establish general guidelines, and framework for identifiable risks in the company,
• Commitment to Data Protection and Privacy by integrating such criteria into processes of the company programmes,
• Compliance with legal requirements regarding public information,
• Correct any error or omission in any personal data that is in the company’s possession or control upon request,
• All forms of Data Protection and Privacy breaches.

2.4   Disclosure of Personal Data in Business Transaction: If the Company is involved in a merger, acquisition or asset sale, Personal Data may be transferred. A notice in this regard will be provided before Personal Data is transferred and becomes subject to a different Privacy Policy.

2.5   Disclosure of Personal Data for Legal Enforcement: Under certain circumstances, the Company may be required to disclose Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

2.6   Disclosure in relation to other legal requirement: The Company may disclose Personal Data bona fide that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

2.7   Security of Personal Data: The security of Personal Data is important to the Company. Nevertheless, note that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Personal Data, the company cannot guarantee its absolute security.

2.8  Children’s Privacy: The Company’s service does not typically address anyone under the age of 13 and by implication do not knowingly collect personally identifiable information from anyone under the stated age. If parent, guardian, or any other person is aware that a child has provided the company with Personal Data, please contact the company immediately. If the company becomes aware that it has collected Personal Data from anyone under the age of 13 without verification of parental consent, the company will take steps to remove that information from the company servers.

2.9   Links to third party websites: The company service may contain links to other websites that are not operated by it. If a data subject clicks on a third-party link, it will direct to that third party’s site on which the company bears no responsibility. It is strongly advised that the Privacy Policy of every site visited be reviewed.

         The company has no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

2.10 Training of the workforce and designated staff on Data Protection and Privacy considerations will be required for continuous improvement under this policy.

2.11 Communication of the Data Protection and Privacy Policy to all the concerned stakeholders of the company to facilitate awareness of the policy and make same available on demand.

2.12 The Board of Directors and Management are committed to promoting Data Protection and Privacy culture within the company.

2.13 The Technology unit shall take all such steps as shall from time to time be necessary towards administration of compliance with the provisions of this policy by relevant stakeholders.

3.0 Definitions

The following meanings are applicable in this Data Protection and Privacy Policy:

• Company:

Financial Institutions Training Centre otherwise known as ‘FITC’.

• Account:

A unique account created for data subject to access our Service or parts of our Service.

• Stakeholder:

Any director, vendor, with which the Company interacts in the normal course of its business activities.

• Stakeholder:

Any director, vendor, with which the Company interacts in the normal course of its business activities.

• Cookies:

Small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

• Country:

Nigeria.

• Device:

Any device that can access the Service such as a computer, a mobile phone or a digital tablet.

3.10 Personal Data:

Any information that relates to an identified or identifiable individual.

3.11 Service:

The company’s Website.

3.12 Service Provider:

Any natural or legal person who processes the data on behalf of the Company. Also refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

3.13 Usage Data:

Data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

3.14 Website:

   FITC, accessible from www.fitc-ng.com.

3.15 You:

The individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

4.0 Collection and Use of Personal Data

While using the company’s Service, certain personally identifiable information that can be used to contact or identify the data subject may be requested. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City

Personal Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When data subject accesses the Service by or through a mobile device, the company may collect certain information automatically, including, but not limited to, the type of mobile device used, mobile device unique ID, the IP address of mobile device, mobile operating system, the type of mobile Internet browser used, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing, and your experience.

Personal information may be shared in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain products, services, or promotions.
• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

• Tracking Technologies and Cookies

The company uses Cookies and similar tracking technologies to track the activity on its Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze the company’s Service. The technologies used may include:

Cookies or Browser Cookies. A cookie is a small file placed on the data subject device. A data subject can instruct own browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if data subject does not accept Cookies, such may be unable to use some parts of the company Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.

Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_

Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies: What Are Cookies?.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies, we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

6.0 Policy Review

6.1 The Head, Technology unit will conduct an internal review of this policy periodically at least once in two (2) years, or if significant changes occur, and ensure its continuing suitability, adequacy, and effectiveness.

6.2   The company will notify data subjects of any changes to this policy by posting the new /updated Policy on the company website. Notice of change will be via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Policy. Data subjects are advised to review this Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

6.3 Any proposed updates to this policy will be further reviewed and approved by:

• The Board Corporate Strategy (Technical) Committee,
• The Board.

7.0 Policy Breach

7.1    A breach of this policy is liable to disciplinary action in accordance with the Company’s disciplinary procedure and/or sanction.

7.2   Any breach of this policy shall be investigated.

8.0 Non-Compliance Implication

8.1 Where this Data Protection and Privacy policy is not complied with, governance of the company will be compromised.

8.2   Failure to comply with this policy could lead to the consequences of disciplinary action initiated by the company, including dismissal and/or termination of any third-party contractual relationship by the company for breach of this Policy.

Contact Us

If you have any questions regarding this Data Protection  and Privacy Policy or, please contact our Data Protection Officer at [email protected]

APPENDIX I

CONSENT STATEMENT

CONSENT *

This program includes a feature to record the audio, video and any document or materials exchanged or displayed during the session. By participating you have agreed to the recording and publication of same by FITC or its affiliates.

We collect and use your personal information to better provide you with the required services, or information such as:

• Respond to queries or requests submitted by you,
• Keep you informed of the services offered by FITC, industry developments, service offerings, seminars and other events hosted by the Organization, that may be of interest to them,
• For general management and reporting purposes.