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Breach Notification

If a breach of security leads to accidental or unlawful destruction, loss, alteration or unauthorised disclosure of personal data, we will:

  1. Promptly assess and contain it: establishing what data, whose, and what risk.
  2. Notify the competent authorities where and when required:
    • the NDPC within 72 hours of becoming aware, where the NDPA applies: see Nigeria;
    • EU/UK supervisory authorities without undue delay and, where feasible, within 72 hours, where the GDPR or UK GDPR requires notification: see EU/UK;
    • US authorities and affected residents as state breach-notification laws require: see United States.
  3. Inform affected people without undue delay where their rights and freedoms are at material risk, with what happened, what we did, and what they can do.
  4. For Cueprise™ licensee data, notify the affected licensee without undue delay with the detail it needs for its own obligations: see the Cueprise™ Privacy Notice.

We keep an internal record of every incident, including those that did not meet a notification threshold, and what we changed afterwards.

Last updated 29 September 2026.