DATA PROTECTION/PRIVACY POLICY

Version 1.1

Date Created 19/09/2018

Document Author ISMS Manager
Document Owner Fidelity Bank
Date Reviewed 22/05/2020
Document Classification Public

Retention Period 1 Year

Confidentiality

No part of this document may be disclosed verbally or in writing, including by reproduction, to any
third party without the prior written consent of Fidelity Bank. This document, its associated
appendices and any attachments remain the property of Fidelity Bank and shall be returned upon
request.

Document Classification | PUBLIC

Document Control Sheet

Version and Update History

Version Date Author Change from Previous Version
Version 1.0 6th June 2019 ISMS Manager
Version 1.1 22nd May 2020 ISMS Manager  Added the DPO, CISO & MD in the
approval page
 Added the following clauses
1. Transfer of Personal Data to Foreign
Country
2. General Principles for Processing of
Personal Data clauses
3. Training
4. Data Protection Officer
5. Data Protection Audit
Distribution List

Name Version Date

Public Version 1.0 6th June 2019
Public Version 1.1 22nd May 2020

Change Control

The contents of this document are subject to change control

Document Review

This document is subject to continuous changes. In case there are no

changes, then an annual review shall be performed
 1. Introduction

Fidelity Bank Plc is a bank licensed in Nigeria by the Central Bank of

Nigeria. We provide banking services to a wide variety of customers
including individuals, small and medium enterprises, large corporates
and multinationals, governmental institutions and non-governmental
institutions. Our banking services are provided at our branches and
through e-channels including the Internet.

Customers and potential customers can access our services through

these channels including our website www.fidelitybank.ng.

By accessing the Bank’s services through account opening at the

branch and or e-channels and or subscribing to any of our various
products such as online banking, instant banking, ATM card services,
customers provide certain personally identifiable information.

This document details the policies of the Bank guiding the collection,
use, storage, destruction and disclosure of this personally identifiable
information.

This policy document is available on our website at

www.fidelitybank.ng and our branches. Please read it thoroughly
before accessing our service. By opening an account or accessing or
subscribing to any of the Bank’s services, you give consent to the
processing of your personal data in accordance with this policy.

Unless otherwise defined in this Privacy Policy, terms used in this Privacy
Policy have the same meanings as in our Terms and Conditions on
www.fidelitybank.ng.

Please read this privacy policy carefully as it will help you make
informed decisions about sharing your personal information with us.

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 1.1 Glossary

“Consent” of the Data Subject means any freely given, specific,

informed and unambiguous indication of the Data Subject's
wishes by which he or she, through a statement or a clear
affirmative action, signifies agreement to the processing of
Personal Data relating to him or her;

“Data” means characters, symbols and binary on which

operations are performed by a computer, which may be stored
or transmitted in the form of electronic signals, stored in any format
or any device;

“Data Protection Officer or DPO” means the person appointed

as such under the Data Protection Laws and in accordance with
its requirements. A DPO is responsible for advising Fidelity Bank
(including its employee) on their responsibilities under the Data
Protection Laws, for monitoring compliance with Data
Protection Law

“Data Subject” means any person, who can be identified,

directly or indirectly, by reference to an identification number or
to one or more factors specific to his physical, physiological,
mental, economic, cultural or social identity;

“NDPR” means the Nigeria Data Protection Regulation, 2019;

“Our Services” means the online banking services provided by to

the Bank to the customer, which include but not limited to
Online/Mobile banking, instant banking;

“Personal Data” means any information relating to an identified

or identifiable natural person (‘Data Subject’); an identifiable
natural person is one who can be identified, directly or indirectly,
in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to
one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that
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 natural person; It can be anything from a name, address, a
photo, an email address, bank details, posts on social networking
websites, medical information, and other unique identifier such
as but not limited to MAC address, IP address, IMEI number, IMSI
number, SIM, Personal Identifiable Information (PII) and others;

“Personal Identifiable Information (PII)” means information that

can be used on its own or with other information to identify,
contact, or locate a single person, or to identify an individual in a
context
“PCI DSS” means Payment Card Industry Data Security Standards
“Processing” means any operation or set of operations, which
is performed on Personal Data or on sets of Personal Data, whether
or not by automated means, such as collection, recording,
organization, structuring, storage, adaptation or alteration,
retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or
combination, restriction, erasure or destruction;

2. Information Collection and Use

We collect several different types of information for various purposes

to provide and improve our services to you.

2.1. Types of Data Collected

Personal Data

While using our services, we may ask you to provide us with certain
personally identifiable information that can be used to contact or
identify you ("Personal Data"). Personally identifiable information may
include, but is not limited to:

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 Name and Contact Data: We collect your first, middle and last name,
email address, bank verification number, postal address, phone
number, signature, date of birth, an identification document such as
a copy of driver’s license, international passport, national identity
card, and other similar contact data.

Credentials: when you subscribe to any of our products, particularly

our e-channels products (online/mobile Banking, Instant Banking,
Mvisa) you may be required to provide a User ID, a password, details
from a token response device, password hints and similar security
information used for authentication and account access. You may
also be required or opt to use biometric identification to access your
account and authenticate transactions. While this information is
required to ensure that you carry out transactions securely,
appropriate security measures have been implemented to protect
these data including encryption and storage in a secured
environment, if required.

Payment Data: If you subscribe to our ATM card products, we will issue
you ATM cards each with unique numbers called Personal Access
Number (PAN), Personal Identity Number (PIN), and Card Verification
Number. You are required to keep your card and these security
numbers from access by another person. For certain payment cards,
a default PIN may be provided by us. In such circumstances, you are
required to change the default PIN to a new PIN to enable activation
and/or use of the card. When you carry out transactions or enrollment
related to card services or online services, these card security numbers
or any of them may be required for authentication.

We collect data necessary to process your payment if you make

payment/transfers, such as your card number and the security code
associated with your payment card. All payment data are processed,
transmitted and stored securely in line with PCI DSS requirements.

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 Usage Data: We may also collect information that your browser sends
whenever you access our online services and or when you access the
services by or through a mobile device ("Usage Data").

This Usage Data may include information such as your computer'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 you access services by or through a mobile device, this Usage

Data may include the following:

Geo-Location information: We may request access or permission

to and track location-based information from your mobile
device, either continuously or while you are using our mobile
application, to provide location-based services. If you wish to
change our access or permissions, you may do so in your
device's settings.

Mobile Device Access: We may request access or permission to

certain features from your mobile device, including your mobile
device's camera, calendar, bluetooth, contacts, storage and
other features. If you wish to change our access or permissions,
you may do so in your device's setting.

Mobile Device Data: We may automatically collect device

information (such as your mobile device ID, model and
Manufacturer), operating system, version information, IP address
and diagnostic data.

Tracking & Cookies Data: We use cookies and similar tracking

technologies to track the activity on our Service

Cookies are files with small amount of data which may include an
anonymous unique identifier. Cookies are sent to your browser from a

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 website and stored on your device. Tracking technologies also used
are beacons, tags, and scripts to collect and track information and to
improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when
a cookie is being sent. However, if you do not accept cookies, you
may not be able to use some portions of our Service.

2.2. Use of Analytics to Collect/Monitor/Analyze Data

We may use third-party Service Providers to monitor and analyze the

use of our Service.

• Google Analytics

Google Analytics is a web analytics service offered by Google that

tracks and reports website traffic. Google uses the data collected to
track and monitor the use of our Service. This data is shared with other
Google services. Google may use the collected data to contextualize
and personalize the ads of its own advertising network.

For more information on the privacy policies of Google, please visit

the Google Privacy & Terms web page located at
https://policies.google.com/privacy?hl=en

• Addthis

Oracle Corporation operates AddThis.com, a social bookmarking

service that can be integrated into a website with the use of a web
widget. This is used to share content from our website to social media
platforms such as Facebook, MySpace, Google Bookmarks, Pinterest,
and Twitter.

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 AddThis analytics also allow us to track how, where, and by whom our
content is being shared. In addition, the analytics show follow activity,
related posts performance, visits, and conversions.

You can prevent AddThis from using your information for analytics
purposes by opting-out. To opt-out of AddThis service, please visit this
page: http://www.addthis.com/privacy/opt-out/

For more information on what type of information AddThis collects,

please visit the Terms of Use page of AddThis
http://www.addthis.com/privacy/terms-of-service/

Links To Other Sites

Our Service may contain links to other sites that are not operated by
us. If you click on a third-party link, you will be directed to that third
party's site. We strongly advise you to review the Privacy Policy of
every site you visit.

We have no control over and assume no responsibility for the content,

privacy policies or practices of any third-party sites or services.

2.3. Use of Data

The purpose of collecting personally identifiable information is to

enable us to provide you with the banking services you have
subscribed to and ensure that you are able to carry out transactions
without hitches.

The usage of data may be extended beyond the above whenever

necessary for the purposes of meeting legal, regulatory, contractual
obligations, and other legitimate business interests.

Specifically, the uses the Bank could put your data into include but
not limited to:

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 • To provide and maintain our services
• To notify you about changes to our service
• To allow you to participate in interactive features of our Service
when you choose to do so
• To provide customer care and support
• To provide analysis or valuable information so that we can improve
the Service
• To monitor the usage of the Service
• To detect, prevent and address technical issues
• To facilitate account opening
• To send you marketing and promotional communications for
business purposes
• To deliver targeted advertising to you for our Business Purposes
and/or with your consent. We may use your information to develop
and display content and advertising (and work with third parties
who do so) tailored to your interests and or location and to measure
its effectiveness

3. Transfer of Data

The world today is interconnected and so is the provision of banking

services. For instance, there could be many counterparties involved
for a card transaction to be successfully completed. These include the
personalization companies, the switching companies, processors,
acquirers, merchants, and the card schemes. Certain personal data
will traverse these parties in the normal course of carrying out
transactions.

Save as related to the provision of banking services and meeting

legal, regulatory, contractual, and other uses tangential or incidental
to these, Fidelity will not share your personal data with a third party.
Where it becomes necessary to do so, adequate security measures
will be taken to protect the data from access by recipients other than
those for which it is intended. All data we collect will reside in Fidelity’s
computer systems in Nigeria. Where cloud services are used,
adequate governance measures that apply to such cloud services
will be complied with.

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 Fidelity Bank Plc will take all steps reasonably necessary to ensure that
your data is treated securely and in accordance with this Privacy
Policy. No transfer of your Personal Data will take place to an
organization or a country unless there are adequate controls in place
including the security of your data and other personal information.

Transfer of Personal Data To Foreign Country

Where Personal Data is to be transferred to a country outside Nigeria, the

Bank shall put adequate measures in place to ensure the security of such
Personal Data. In particular, The Bank shall, among other things, conduct
a detailed assessment of whether the said country is on the National
Information Technology Development Agency (NITDA) White List of
Countries with adequate data protection laws.

Transfer of Personal Data out of Nigeria would be in accordance with the

provisions of the Nigeria Data Protection Regulation, 2019 (NDPR). The
Bank will therefore only transfer Personal Data out of Nigeria on one of
the following conditions:

a. The consent of the Data Subject has been obtained;

b. The transfer is necessary for the performance of a contract

between the Bank and the Data Subject or implementation of pre-
contractual measures taken at the Data Subject’s request;

c. The transfer is necessary to conclude a contract between the Bank

and a third party in the interest of the Data Subject;

d. The transfer is necessary for reason of public interest;

e. The transfer is for the establishment, exercise or defense of legal

claims;

f. The transfer is necessary in order to protect the vital interests of the

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 Data Subjects or other persons, where the Data Subject is physically
or legally incapable of giving consent.

Provided, in all circumstances, that the Data Subject has been manifestly
made to understand through clear warnings of the specific principle(s)
of data protection that are likely to be violated in the event of transfer to
a third country, this proviso shall not apply to any instance where the
Data Subject is answerable in duly established legal action for any civil
or criminal claim in a third country.

The Bank will take all necessary steps to ensure that the Personal Data is
transmitted in a safe and secure manner. Details of the protection given
to your information when it is transferred outside Nigeria shall be provided
upon the Data Subject’s request.

Where the recipient country is not on the White List and none of the
conditions stipulated in this Privacy Policy are met, the Bank will engage
with NITDA and the Office of the Honourable Attorney General of the
Federation (HAGF) for approval with respect to such transfer.

4. Disclosure of Data

We only share and disclose your information in the following situations:

Compliance with Laws: We may disclose your information where we

are legally required to do so in order to comply with applicable law,
governmental requests, a judicial proceeding, court order, or legal
process, such as in response to a court order or a subpoena (including
in response to public authorities to meet national security or law
enforcement requirements).

Vital interests and Legal Rights: We may disclose your information

where we believe it is necessary to investigate, prevent, or take action
regarding potential violations of our policies, suspected fraud,
situations involving potential threats to the safety of any person and
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 illegal activities, or as evidence in litigation in which we are involved.

Vendors, Consultants and Third-party Service Providers: We may share

your data with third party vendors, service providers, contractors or
agents who perform services for us or on our behalf and require
access to such information to do that work, which is necessary to
provide the envisaged banking services. Examples include but not
limited to: payment processing, data analysis, email delivery, hosting
services, customer service and marketing efforts. For the purpose of
service improvement, we may allow selected third parties to use
tracking technology on the services which will enable them to collect
data about how you interact with the services over time. This
information may be used to, among other things, analyze and track
data, determine the popularity of certain content and better
understand online activity. Unless described in this policy, we do
notshare, sell, rent or trade any of your information with third parties
for their promotional purposes.

Business transfers: we may share or transfer your 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 your consent we may disclose your personal information for any
other purpose.

5. Security of Data

The security of your data is important to us. We have implemented

appropriate technical and organizational security measures designed
to protect the security of any personal information we process.
However, please also remember that we cannot guarantee that the
internet it itself is 100% secure. Although we will do our best to protect
your personal information, transmission of personal information to and
from our services is at your own risk. You should only access the
services within a secure environment.

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 6. General Principles for Processing Of Personal Data

The Bank is committed to maintaining the principles in the NDPR

regarding the processing of Personal Data.

To demonstrate this commitment as well as our aim of creating a

positive privacy culture within the Bank, The Bank adheres to the
following basic principles relating to the processing of Personal Data:

6.1 Lawfulness, Fairness and Transparency

Personal Data must be processed lawfully, fairly and in a transparent

manner at all times. This implies that Personal Data collected and
processed by or on behalf of The Bank must be in accordance with
the specific, legitimate and lawful purpose consented to by the Data
Subject, save where the processing is otherwise allowed by law or
within other legal grounds recognized in the NDPR.

6.2 Data Accuracy

Personal Data must be accurate and kept up-to-date. In this regard,

The Bank shall:

a) ensure that any data it collects and/or processes is accurate and

not misleading in a way that could be harmful to the Data
Subject;

b) make efforts to keep Personal Data updated where reasonable

and applicable; an

c) make timely efforts to correct or erase Personal Data when

inaccuracies are discovered.

6.3 Purpose Limitation

The Bank collects Personal Data only for the purposes identified in the
appropriate The Bank Privacy Notice provided to the Data Subject
and for which consent has been obtained. Such Personal Data
cannot be reused for another purpose that is incompatible with the
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 original purpose, except a new consent is obtained.

6.4 Data Minimization

6.4.1 The Bank limits Personal Data collection and usage to data that
is relevant, adequate, and absolutely necessary for carrying out
the purpose for which the data is processed.

6.4.2 The Bank will evaluate whether and to what extent the
processing of personal data is necessary and where the
purpose allows, anonymized data must be used.

6.5 Integrity and Confidentiality

6.5.1 The Bank shall establish adequate controls in order to protect

the integrity and confidentiality of Personal Data, both in digital
and physical format and to prevent personal data from being
accidentally or deliberately compromised.

6.5.2 Personal data of Data Subjects must be protected from

unauthorized viewing or access and from unauthorized
changes to ensure that it is reliable and correct.

6.5.3 Any personal data processing undertaken by an employee who

has not been authorized to carry such out as part of their
legitimate duties is un-authorized.

6.5.4 Employees may have access to Personal Data only as is

appropriate for the type and scope of the task in question and
are forbidden to use Personal Data for their own private or
commercial purposes or to disclose them to unauthorized
persons, or to make them available in any other way.

6.5.5 Human Resources Department must inform employees at the

start of the employment relationship about the obligation to
maintain personal data privacy. This obligation shall remain in
force even after employment has ended.

6.6 Personal Data Retention

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 6.6.1 All personal information shall be retained, stored and destroyed
by The Bank in line with legislative and regulatory guidelines. For
all Personal Data and records obtained, used and stored within
the Company, The Bank shall perform periodical reviews of the
data retained to confirm the accuracy, purpose, validity and
requirement to retain.

6.6.2 To the extent permitted by applicable laws and without

prejudice to The Bank’s Document Retention Policy, the length
of storage of Personal Data shall, amongst other things, be
determined by:

(a) the contract terms agreed between The Bank and the
Data Subject or as long as it is needed for the purpose for
which it was obtained; or

(b) whether the transaction or relationship has statutory

implication or a required retention period; or

(c) whether there is an express request for deletion of Personal

Data by the Data Subject, provided that such request will
only be treated where the Data Subject is not under any
investigation which may require The Bank to retain such
Personal Data or there is no subsisting contractual
arrangement with the Data Subject that would require the
processing of the Personal Data; or

(d) whether The Bank has another lawful basis for retaining that
information beyond the period for which it is necessary to
serve the original purpose.

Notwithstanding the foregoing and pursuant to the NDPR,

The Bank shall be entitled to retain and process Personal
Data for archiving, scientific research, historical research or
statistical purposes for public interest.

6.6.3 The Bank would forthwith delete Personal Data in The Bank’s
possession where such Personal Data is no longer required by
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 The Bank or in line with The Bank’s Retention Policy, provided no
law or regulation being in force requires The Bank to retain such
Personal Data.

6.7 Accountability

6.7.1 The Bank demonstrates accountability in line with the NDPR

obligations by monitoring and continuously improving data
privacy practices within The Bank.

6.7.2 Any individual or employee who breaches this Privacy Policy

may be subject to internal disciplinary action (up to and
including termination of their employment); and may also face
civil or criminal liability if their action violates the law.

6.7.3 When a potential breach has occurred, the Bank will investigate
to determine if an actual breach has occurred and the actions
required to manage and investigate the breach as follows:

a) Validate the Personal Data breach.

b) Ensure proper and impartial investigation (including digital

forensics if necessary) is initiated, conducted, documented,
and concluded.

c) Identify remediation requirements and track resolution.

d) Report findings to the top management.

e) Coordinate with appropriate authorities as needed.

f) Coordinate internal and external communications.

g) Ensure that impacted Data Subjects are properly notified, if

necessary.

7. Children's Privacy

The Bank has a children’s account called Sweeta. This account is

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 opened and run by a child’s parent or guardian until the child reaches
the age of majority. All personal information pertaining to such
account is provided by the guardian. A parent or guardian should
therefore read this policy thoroughly to understand how the data
provided is handled.

Other than as related to the operation of the aforementioned

children’s account, the Bank does not enter into banking relationship
with minors (persons under the age of 18).

We do not knowingly collect personally identifiable information from

anyone under the age of 18. If you are a parent or guardian and you
are aware that your Children have provided us with Personal Data,
please contact us. If we become aware that we have collected
Personal Data from children without verification of parental consent,
we will take steps to remove that information from our servers.

8. Personal Data Retention Period

We will only keep your personal information for as long as it is

necessary for the purposes set out in this Privacy Policy, unless a longer
retention period is required or permitted by law (such as tax,
accounting or other legal requirements). Upon request for account
closure, your account will be closed but this closure will not involve
deletion of historical records of the account for the reasons already
stated. However, except as may be required by law or law
enforcement agents and or regulators, further processing of the
personal information related to the account will cease from the time
of closure.
9. Your Privacy Rights

In some regions (like the European Economic Area), you have certain
rights under applicable data protection laws. These may include the
right (i) to request access and obtain a copy of your personal
information, (ii) to request rectification or erasure; (iii) to restrict the
processing of your personal information; and (iv) if applicable, to data
portability. In certain circumstances as stated in section 2.8 of the
Nigeria Data Protection Regulation, you may also object to the
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 processing of your personal information. To make such a request,
please use the contact details provided below. We will consider and
act upon any request in accordance with applicable data protection
laws.

If we are relying on your consent to process your personal information,

you have the right to withdraw your consent at any time. Please note
however that this will not affect the lawfulness of the processing
before its withdrawal.

if you are resident in the European Economic Area and you believe
we are unlawfully processing your personal information, you also have
the right to complain to your local data protection supervisory
authority. You can find their contact details here:
https://edpb.europa.eu/about-edpb/board/members_en

Account Information

If you would at any time like to review or change the information in

your account or terminate your account, you can contact us using
the contact information provided.

Cookies and Similar technologies: Most web browsers are set to

accept cookies by default. If you prefer, you can usually choose to
set your browser to remove cookies and to reject cookies. If you
choose to remove cookies or reject cookies, this could affect certain
features of our services to you. To opt-out of interest-based advertising
by advertisers on our services visit http://www.aboutads.info/choices/

Opting out of email marketing: You can unsubscribe from our

marketing email list at any time by clicking on the unsubscribe link in
the emails that we send or by contacting us using the details provided
below. You will then be removed from the marketing email list -
however, we will still need to send you service-related emails that are
necessary for the administration and use of your account. To
otherwise opt-out, you may:

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 Note your preferences when you register an account with the site
Access your account settings and update preferences
Contact us using the contact information provided
10. Automated individual decision-making or profiling
We do not use any automated processing systems for coming to
specific decisions – including profiling.

11. Training

The Bank shall ensure that employees who collect, access and process
Personal Data receive adequate data privacy and protection training in
order to develop the necessary knowledge, skills and competence
required to effectively manage the compliance framework under this
Privacy Policy and the NDPR with regard to the protection of
Personal Data. On an annual basis, The Bank shall develop a capacity
building plan for its employees on data privacy and protection in line with
the NDPR.

12. Data Protection Officer

The Bank shall appoint a Data Protection Officer(s) (DPO) responsible

for overseeing the Company's data protection strategy and its
implementation to ensure compliance with the NDPR requirements.
The DPO shall be a knowledgeable person on data privacy and
protection principles and shall be familiar with the provisions of the
NDPR.

The main tasks of the DPO include:

a) administering data protection policies and practices of The Bank;

b) monitoring compliance with the NDPR and other data protection

laws, data protection policies, awareness-raising, training, and
audits;

c) advice the business, management, employees and third parties

who carry on processing activities of their obligations under the
NDPR;
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 d) acts as a contact point for The Bank;

e) monitor and update the implementation of the data protection

policies and practices of The Bank and ensure compliance
amongst all employees of The Bank;

f) ensure that The Bank undertakes a Data Protection Impact

Assessment and curb potential risk in The Bank data processing
operations; and

g) maintain a database of all The Bank personal data collection

and processing operations of The Bank.

13. Data Protection Audit

The Bank shall conduct an annual data protection audit through a

licensed Data Protection Compliance Organization (DPCO) to verify
The Bank’s compliance with the provisions of the NDPR and other
applicable data protection laws.

The audit report will be certified and filed by the DPCO to NITDA as
required under the NDPR.

14. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you
of any changes by posting the new Privacy Policy on this page and
making it available at our branches.

You are advised to review this Privacy Policy periodically for any
changes. Changes to this Privacy Policy are effective when they are
posted on this page.

15. Contact Us

If you have any questions or comments about this policy, you may
contact our Data Protection Officer (DPO) by email at
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 [email protected] or by post to:
Data Protection Officer
Fidelity Bank Plc
2 Kofo Abayomi Street
Victoria Island Lagos
Nigeria

If you have any further questions or comments about us or our policies,

email us at [email protected] or by post to:
Fidelity Bank Plc
2 Kofo Abayomi Street
Victoria Island Lagos
Nigeria
Phone: 014485252

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