OVERHAUL ENERGY LIMITED
DATA PROTECTION POLICY
DATA PROTECTION POLICY
OVERHAUL ENERGY LIMITED recognizes the importance of safeguarding personal data and
respecting individuals' privacy rights. This Data Protection Policy outlines our commitment to
protecting personal data in accordance with various data protection laws and regulations, which
may include but are not limited to:
The General Data Protection Regulation (GDPR) in Nigeria
The Personal Data Protection Act (PDPA) in Nigeria
The Privacy Act as may be required by State, LGAs and Clients
This policy establishes the framework for how we collect, process, store, and manage personal
data responsibly and in compliance with these laws.
RESPONSIBILITIES
EMPLOYEES
All employees are responsible for ensuring the proper handling of personal data in their day-to-
day activities. They must adhere to this policy and report any data protection concerns to the
Data Protection Officer.
CONTRACTORS AND THIRD PARTIES
Contractors and third parties engaged by the Company are also responsible for adhering to this
policy and for ensuring the proper handling of personal data in their activities on behalf of the
Company. They must comply with applicable data protection laws and regulations and report any
data protection concerns to the Data Protection Officer.
DATA PROTECTION OFFICER (DPO)
The Company has appointed a Data Protection Officer Mss Blessing Kelvin who is responsible
for overseeing data protection matters, ensuring compliance with applicable laws, conducting
regular audits or reviews of data processing activities, and acting as a point of contact for data
subjects and regulatory authorities.
DATA COLLECTION AND PROCESSING
LAWFUL PROCESSING
The Company will only collect and process personal data when it has a lawful basis to do so,
including but not limited to:
The consent of the data subject
Contractual necessity
Legal obligation
Legitimate interests
The protection of vital interests
TRANSPARENCY
Data subjects will be informed of the purposes for which their data is collected and processed,
including the lawful basis for processing, at the point of data collection or before, and their rights
in relation to their data.
CONSENT
Where consent is required for processing personal data, the Company will obtain explicit and
freely given consent from data subjects. Consent will be obtained through clear and easily
accessible means, and records of consent will be maintained.
DATA SECURITY
DATA BREACH RESPONSE
A data breach is defined as any unauthorized access, disclosure, or acquisition of personal data
that compromises its confidentiality, integrity, or availability. In the event of a data breach, the
Company will promptly:
Assess and mitigate the impact of the breach
Notify affected data subjects in a timely manner, providing details of the breach and
actions they can taken to protect themselves
Notify relevant regulatory authorities where required by applicable law
DATA SUBJECT RIGHTS
Data subjects have the following rights regarding their personal data:
Right to Access: Data subjects can request access to their personal data.
Right to Rectification: Data subjects can request corrections to their personal data.
Right to Erasure: Data subjects can request the deletion of their personal data.
Right to Data Portability: Data subjects can request the transfer of their personal data.
Right to Object: Data subjects can object to the processing of their personal data.
Right to Restriction of Processing: Data subjects can request the restriction of processing
under certain circumstances.
To exercise these rights, data subjects can contact the Data Protection Officer at the contact
information provided below.
CONTACT INFORMATION
Data subjects can contact the Data Protection Officer at:
Mss Blessing Kelvin - kelvin@[Link]
APPROVAL AND EFFECTIVE DATE
This Data Protection Policy was approved by Mss Blessing Kelvin and is effective from 01st
January 2023.