[last updated 15th JUNE 2021.]
Introduction
The Chartered Institute of Taxation of Nigeria (“CITN’’, “we”, “us”, “our”) is a professional membership association for people who are in the field of Taxation. We strive to provide our members, customers, and other users of our website with the best products and services available and recognize that building a long-term business relationship with you depends a great deal on trust. We provide this Privacy Policy to describe how we collect, use, share, and otherwise process the Personal Data we collect. We are aware of and care about your own personal privacy interests, and we take that seriously.
We recognize that information privacy and data protection is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new Personal Data practices or adopt new Data Protection Policies.
You accept this Privacy Policy and hereby give us consent to save, process and use your Personal Data to the extent as allowed by the Nigeria Data Protection Regulation (NDPR) or any other applicable law when you provide us with details of your Personal Data or by clicking on the button.
Questions or suggestions arising from this Privacy Policy should be directed to dataprotection@citn.org
All information regarding this site is from sources deemed reliable. No representation is made as to the accuracy thereof, and such information is subject to errors, omission, and change of details without notice.
CITN’s Privacy Statement
CITN is very sensitive to privacy issues. Any Personal Data we collect is considered private and we do not use or share it with unauthorised persons, without the your consent. In most cases, we use your Personal Data at CITN in line with this Privacy Policy or when we have identified a lawful basis for doing so. This privacy statement applies to all Personal Data we collect and process about you. We believe it is important you know how we treat your Personal Data you may provide to us.
How we collect your Personal Data
We may collect and process the following information about you:
- Information or Personal Data that we obtain or learn, such as your cookies ID, IP Address, or information about the browser or device you use to access our site, how you use this site and the pages you visit, traffic and location data.
- If you sign up for our Newsletter or register to receive alerts or updates.
- When you contact us, send us a message, or provide your Personal Data while signing up for Membership Registration, or registering for a training or an event.
- When you purchase or order for any of our products or services.
- Personal Data you provide us with or any of our Partners over the telephone, by filling a form, via chat or through mail or email.
- When you apply for a job or for the purpose of recruitment.
- When you visit our premises (this may include registration as a visitor or guest and the use of CCTV)
- When you attend any of our virtual programs that is being recorded.
- When we capture photos and video of you.
- Personal Data we receive from other sources.
- We may also ask you to complete surveys for research purposes or in order to improve our services.
Use of Personal Data Collected by CITN:
CITN uses your Personal Data to better understand your needs and provide you with better service. We do not sell your Personal Data to anyone and only share it with third parties who are facilitating the delivery of CITN services. Specifically, we use your Personal Data in the following ways:
- to provide our services to you;
- to fulfil any other purpose for which you provided it;
- to operate, improve and personalise the products and services we offer, and to give you a more consistent and personalised experience when interacting with us;
- for customer service, security, to detect fraud or illegal activities, or and for archival and backup purposes in connection with the provision of our services;
- to verify your certification status with CITN;
- to communicate with you, either via email, telephone, text (SMS) messages, postal mail, or otherwise to inform you about our services, special offers, or any of our business activities;
- to better understand how you access and use our site and services, for the purposes of trying to improve the site and services and to respond to your preferences;
- to help us develop new products and services and improve our existing products and services;
- carryout any activity in our business legitimate interest as a professional body and our regulators;
- to provide users with advertising and direct marketing that is more relevant to you;
- to enforce any other applicable policies; and
- to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with our services.
- for any other purpose with your consent.
CITN is an Institute based in Nigeria and the Personal Data we collect is governed by the NDPR.
Cookies
We use cookies on our website. Cookies can make using our website easier by storing information about your preferences and enabling you to take full advantage of our services. Cookies are very small text files that a website can transfer to your computer’s hard drive or portable electronic device’s memory for record keeping.
We may use cookies so that we can see which parts of our website you visit when you access it. We may use this information for marketing products and services to you. We keep this information confidential.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
Use of Email Tools:
Upon registration, you may decide to subscribe for some offerings e.g. news, promotional materials. If you no longer wish to receive our newsletters and promotional communications from CITN, you may opt-out of receiving them by following the instructions included in our newsletters, communication materials, or by emailing us at dataprotection@citn.org.
Opt-Out Policy:
We offer visitors to the Site a means for controlling the use of session information. If, at any time after registering for membership or ordering a service, you change your mind about receiving information from us or about the use of information volunteered by you, please send us a request specifying your new choice to dataprotection@citn.org.
To opt out of marketing or promotional emails, please either click ‘unsubscribe’ in the body of the email communication.
Disclosure of Personal Data
CITN makes every possible effort to preserve your privacy; we may however need to disclose your Personal Data when required by law or in the process of conducting our business transactions.
CITN does not sell, rent, or lease your Personal Data to any third party, except stated otherwise. While CITN endeavours to ensure the highest level of standards with a similar respect to your privacy, CITN cannot be responsible for losses or damages that can result from a third party.
We may disclose your Personal Data with other companies or individuals in the following limited circumstances:
- We may provide such Personal Data to affiliated companies or other trusted businesses or persons for the purpose of processing Personal Data on our behalf. We require that these parties agree to process such Personal Data based on our instructions and in compliance with the Nigeria Data Protection Regulation (NDPR) and any other appropriate confidentiality and security measures. When they no longer need your Personal Data to fulfil this service, they will dispose of the details in line with the NDPR.
- With other non-affiliated companies for our business purposes, such as to process transactions, respond to court orders and legal investigations.
- In response to a request for Personal Data, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process.
- With relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate.
- With Training Partners to provide you with the required support and learning on taxation.
- With your consent or at your direction, including if we notify you that the Personal Data you provide will be shared in a particular manner and you provide such Personal Data.
- We may also share aggregated or de-identified or anonymized Information, which cannot reasonably be used to identify you.
When CITN does not have a lawful basis for disclosure of your Personal Data, we will obtain consent from you before sharing your Personal Data with third parties. Where we need to transfer your Personal Data to another country, such country must have an adequate data protection law. We will seek your consent where we need to send your Personal Data to a country without an adequate data protection law.
Security of Personal Data
CITN is committed to protect all Personal Data about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Additionally, we will take reasonable measures to protect the confidentiality and security of your Personal Data. We have also taken measures to comply with provision of security facilities for the protection of your Personal Data through the set-up of firewalls, limited access to specified authorized individuals, encryption and continuous capacity building for relevant personnel. We therefore have digital and physical security measures to limit and eliminate possibilities of data privacy breach incidents.
How long we keep your Personal Data
We will hold your Personal Data on our systems for as long as it is necessary to fulfil the purpose for which it was collected or to comply with legal or regulatory requirements. Except as otherwise mentioned in this Privacy Policy, we will keep your Personal Data in accordance with our Retention Policy.
Your rights as a Data Subject
The law gives you certain rights in respect to your Personal Data we hold about you. Below is a highlight of some of those rights. At any point while we are in possession of or processing your Personal Data, you, the Data Subject has the following rights:
- RIGHT OF ACCESS – You have the right to request a copy of the information that we hold about you.
- RIGHT TO RECTIFY – You have the right to correct the Personal Data we hold about you that is inaccurate.
- RIGHT TO BE FORGOTTEN – In certain circumstances you may ask for the data we hold about you to be erased from our record.
- RIGHT TO RESTRICT PROCESSING – Where certain conditions apply, you have a right to restrict processing of your Personal Data.
- RIGHT TO PORTABILITY – You have the right to have your Personal Data transferred to another organisation.
- LODGE COMPLAINT – You have a right to lodge a complaint about the handling of your Personal Data with the National Information Technology Development Agency (NITDA) at info@nitda.gov.ng
- RIGHT TO OBJECT – You have the right to object to the Processing of Personal Data.
NITDA’s website (https://nitda.gov.ng/) has a wealth of useful information in respect of your rights over your Personal Data. If you wish to exercise your rights, you may contact our Data Protection Officer at dataprotection@citn.org or you may write to us at The Tax Professionals’ House, Plot 16 Otunba Jobi Fele Way, Alausa Ikeja Lagos Nigeria
Breach / Privacy Violation
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data, we shall within 72 (Seventy-Two) hours of having knowledge of such breach report the details of the breach to NITDA.
Furthermore, where we ascertain that such breach is detrimental to your rights and freedoms in relation to your Personal Data, we shall having knowledge of the occurrence of such breach take steps to inform you of the breach incident, the risk to your rights and freedoms resulting from such breach and any course of action to remedy said breach.
Changes to this Privacy Statement:
If CITN decides to change our Privacy Policy, we will post those changes to this Privacy Policy on the homepage of our website, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
Cardholders Policy
Each individual cardholder is responsible for the payment card issued in their name and must take all necessary actions to ensure the card is maintained in a safe manner that follows all card guidelines. Access to the payment card should be carefully controlled and all charges on the card should be reconciled promptly to ensure all charges are legitimate. Any questionable activity must be reported immediately.
Questions or Concerns
If you are not happy with our Privacy Policy or if you have any complaint, then you should tell us via dataprotection@citn.org. If a dispute is not settled, then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration