Version 1.0 · Effective April 2026 · Aligned with the Nigeria Data Protection Act (NDPA) 2023
In plain language
VIAS is a data-analysis assistant built for the National Population Commission (NPC) to decentralise access to civil registration insights across Nigeria. It stores your chats so we can improve the AI. We follow the Nigeria Data Protection Act (NDPA) 2019. You have rights, and we explain them below.
The VitalReg Intelligent Analytics System (VIAS) is an AI-powered analytics platform purpose-built for Nigeria's National Population Commission (NPC). It forms part of an innovation initiative to decentralise data analysis from a small team of data scientists in Abuja headquarters to programme officers, state directors, DCRs, and field staff across the 36 states and the Federal Capital Territory.
VIAS provides real-time, natural-language access to the VitalReg CRVS database, allowing authorised NPC staff and government partners to query birth and death registration statistics, generate structured reports, and monitor programme performance — without writing a single line of SQL.
For the purposes of the NDPA, the data controller is:
VIAS is developed and maintained by:
Under the NDPA, your data is processed on the following lawful bases:
We collect only the data needed to operate the service:
Identity & Account Data
Full name, username, work email, phone number, job title, organisation, state of assignment, role, and password hash.
Usage & Interaction Data
Chat conversations, AI-generated documents, tool calls executed on your behalf, query parameters, response contents, and file generation history.
Technical Data
IP address, browser user-agent, device information, session timestamps, authentication events.
VitalReg Data (accessed on your behalf)
When you query the system, VIAS retrieves data from the VitalReg CRVS database per your organisation's access scope. This includes aggregated registration statistics and (where your role authorises it) individual registration records.
Your data is used strictly to:
Your data is NOT used to train any third-party AI model, sold, or shared with external commercial entities.
Authorised VIAS administrators may review your chat conversations only for these purposes:
When an administrator views your conversation, the system automatically masks personally identifiable information (NINs, phone numbers, email addresses) unless the admin has explicit superadmin clearance.
Access to personal data is enforced at the API layer through organisation profiles:
| Data Type | Retention Period |
|---|---|
| Chat conversations | 90 days after last activity |
| Generated files (CSV, charts) | 30 days from creation |
| Documents & reports | Retained until user-initiated deletion |
| Admin audit logs | 12 months (extended as legally required) |
| Consent records | Retained for the lifetime of the account + 3 years |
| Account data | Retained while account is active; deleted within 30 days of account closure |
You have the following rights with respect to your personal data:
To exercise these rights, contact your organisation administrator or the VIAS developer at billibukun@gmail.com. We will respond within 30 days.
We implement the following technical and organisational safeguards:
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Nigeria Data Protection Commission within 72 hours of becoming aware of the breach, as required by the NDPA. Where the risk is high, affected users will be notified directly without undue delay.
Primary processing occurs on infrastructure hosted in Nigeria where available. Where AI processing requires the use of foreign-hosted services (e.g. Google Gemini for natural-language responses), only the minimum necessary query text and aggregate numerical results are transmitted, and no individual-level PII is shared. All such transfers are subject to the recipient's own enterprise-grade security controls and are subject to the safeguards outlined in Section 41 of the NDPA 2023 (Cross-Border Transfer of Personal Data).
VIAS uses only session cookies strictly necessary for authentication and security. We do not use third-party analytics trackers, advertising cookies, or behavioural profiling. No tracking pixels are embedded in emails.
Your use of VIAS must comply with the following:
Violations may result in account suspension and referral to appropriate disciplinary or legal processes.
VIAS processes records of children registered under the civil registration system. Access to such records is strictly limited to authorised officers fulfilling their legal duties, governed by the Child Rights Act 2003 and the Compulsory Registration of Births and Deaths Act (Decree No. 69 of 1992). VIAS applies enhanced PII masking on records of minors by default.
VIAS uses AI to generate analytical responses, but does not make automated decisions that produce legal effects concerning you. The AI is a decision-support tool; all operational, administrative, and programmatic decisions remain with authorised human personnel.
This Data Privacy Notice may be revised to reflect new features, regulatory updates, or organisational changes. When the version number is incremented, you will be required to review and re-accept the updated notice at your next login. Historical versions are archived and available on request. Current version: 1.0.
If you believe your data is being processed unlawfully, you may:
Legal References
For anything related to this notice, your data, platform features, or technical issues, please contact the VIAS developer:
Ibukunoluwa Omonijo
VIAS Developer & System Architect
billibukun@gmail.com
By accepting this notice, you confirm that you have read, understood, and agree to these terms.