Last updated 23 October 2026
1. Who is responsible
[COMPANY LEGAL NAME], [REGISTERED ADDRESS], is the data controller for EmployTrail under the Nigeria Data Protection Act 2023 (NDPA). Contact our data protection officer at support@employtrail.ng.
2. The short version
- Employers never see or search by your NIN. It’s stored encrypted.
- Nobody sees your work trail unless you approve them with a code from your phone, and approval ends after 30 days.
- Guarantors’ NIN and full address are never shown to employers, only the result of each check.
- We don’t sell personal data or use it for advertising.
3. What we collect
| Who | What |
|---|---|
| Everyone with an account | Name, email, phone number, password (stored as a one-way hash), and the codes we text you (stored as hashes, deleted after 7 days). |
| Employees | NIN (encrypted, plus a keyed fingerprint to stop duplicate accounts), the name and date of birth from your NIN record, an optional selfie (used once for matching, then deleted), your jobs, evidence you upload, CV details, letters, and your talent-pool preferences. |
| Employers | Business details, CAC documents, team members and their roles, what you confirm, deny or review, and payments (card details are handled by Paystack and never reach us). |
| Guarantors | Name, phone, NIN (encrypted), occupation, city, home address (encrypted), your signature, and for the address check your phone’s location at that moment and a photo of the building, or a document you upload. |
| Everyone | A log of searches, approvals and changes, with IP addresses stored only as fingerprints, and the cookies needed to keep you signed in. |
4. Why we use it, and on what basis
- To run your account and the service (performance of our contract with you).
- To show your trail to an employer, only after you approve each one (your consent, which you can withdraw).
- To verify identity, stop fraud and keep records honest, including checking guarantors’ photos and holding doubtful checks for review (our legitimate interests in a trustworthy service).
- To meet legal obligations, such as keeping financial records and responding to lawful requests.
5. Who we share it with
- Businesses you approve see your trail, exit reviews and guarantors’ check results for 30 days.
- Service providers who process data for us under contract: identity verification (Dojah), SMS (Termii), payments (Paystack), address lookups (Google Maps), email delivery [EMAIL PROVIDER], hosting [HOSTING PROVIDER] and field agents for home visits [PARTNER].
- Authorities, where the law requires it.
Some providers may process data outside Nigeria. Where they do, we rely on the transfer safeguards the NDPA allows. [TRANSFER MECHANISMS AND HOSTING LOCATION TO BE CONFIRMED.]
6. How long we keep it
- Employer access to a trail: 30 days from approval.
- Texted codes: 7 days. Guarantors’ building photos: 30 days after the check is decided.
- Notifications: 90 days after you read them, and no more than a year.
- Your account and trail: while your account is open, and [RETENTION PERIOD] after you close it, unless the law requires longer.
- The audit log is kept so records can’t be quietly changed; IP addresses in it are fingerprints, not the addresses themselves.
7. How we protect it
Encryption of NINs, addresses and salaries; hashing of passwords, codes and link tokens; role-based access for business teams; rate limits on searches and logins; and an audit log of who did what.
8. Your rights
Under the NDPA you can ask to access, correct or delete your data, to restrict or object to how we use it, to receive it in a portable form, and to withdraw consent. Employees can download a copy of their data from their Profile page. For anything else, send us a data request or email support@employtrail.ng. We reply within 30 days. If you’re not satisfied, you can complain to the Nigeria Data Protection Commission.
9. Cookies
We use only the cookies needed to keep you signed in and protect forms from misuse. We don’t use advertising or tracking cookies. Our pages load fonts from Google Fonts, which receives your IP address when you visit. [CONFIRM OR SELF-HOST FONTS.]
10. Children
EmployTrail is not for anyone under 18.
11. Changes
We’ll update this policy when our practices change and tell you about significant changes before they take effect.