The White Elephant Classification of Data Controllers and Processors of Major Importance in Nigeria

The Nigerian Federal Government recently passed the Nigerian Data Protection Act 2023 into law which creates a special class of data controllers and processors of major importance who are subject to more stringent regulatory oversight. This article critically assesses the provisions of the Nigerian Data Protection Act 2023 as well as the Guidance Notice on the Registration of Data Controllers and Processors of Major Importance issued by the Nigerian Data Protection Commission in 2024. The article engages in a brief comparative analysis with the position in the European Union under the General Data Protection Regulations 2018 and makes recommendations for the Nigerian regulator.