Effective Date: 7th October, 2026
This Privacy Policy explains how Leadership and Value Culture Development Initiative (“LVCDI,” “we,” “us,” or “our”) collects, uses, stores, discloses and protects personal data relating to individuals who visit our website, contact us, participate in or apply for our programmes, volunteer, mentor, donate, subscribe to our publications, attend our events, or otherwise engage with LVCDI.
This Policy applies to personal data processed in connection with:
This Policy should be read together with our Website Terms & Conditions, and other applicable notices or policies issued by LVCDI.
By using our Website or providing personal data to us, you acknowledge the processing described in this Policy. Where applicable law requires your consent, we will obtain it in accordance with applicable law.
Leadership and Value Culture Development Initiative (LVCDI) is a youth-development initiative focused on helping young people discover their potential, develop strong values, gain practical skills, build healthy relationships and grow into responsible and productive adults.
LVCDI’s activities include, among other areas:
For purposes of the Nigeria Data Protection Act 2023 (“NDPA”), LVCDI may act as a Data Controller in respect of personal data processed for its own programme, administrative, safeguarding, donor, volunteer, recruitment, communications and other organisational purposes.
Depending on the nature of a particular activity or arrangement, LVCDI may also process personal data on behalf of a partner, funder, school, programme sponsor or other organisation and may therefore act as a Data Processor or otherwise process personal data pursuant to documented instructions.
This Policy applies to personal data relating to:
Where LVCDI processes personal data on behalf of a partner or another Data Controller, the relevant organisation’s privacy notice or applicable contractual arrangement may also apply.
We collect different categories of personal data depending on the nature of your relationship with LVCDI.
|
Category |
Specific Data |
When Collected |
|
Identity Data |
Name, title, age/date of birth where necessary, photograph where provided |
Programme registration, events, recruitment and other interactions |
|
Contact Data |
Email address, telephone number, residential/business address and correspondence details |
Enquiries, registrations, programme administration and communications |
|
Parent/Guardian Data |
Name, relationship to participant, contact details and consent/authorisation information |
Where a participant is a child or where parental/guardian involvement is required |
|
Programme Data |
Programme selected, attendance, participation records, preferences and relevant programme information |
Programme registration and participation |
|
Education & Professional Data |
School, educational level, employer, job title, qualifications and career interests where relevant |
Education, career and skills-development activities, recruitment and professional engagements |
|
Identification & Verification Data |
Identification documents, signatures, age verification and other verification information where necessary |
Programme safeguarding, verification and compliance |
|
Health, Emergency & Safeguarding Data |
Emergency contact details and health, accessibility, dietary or other information necessary for safety and participation, where applicable |
Programme participation, camps, events and safeguarding |
|
Financial/Donation Data |
Donation amount, transaction/reference information and payment records; payment-card details may be processed by payment providers rather than LVCDI |
Donations, campaigns, accounting and payment administration |
|
Communications Data |
Emails, messages, enquiries, applications and correspondence with LVCDI |
Whenever you communicate with us |
|
Marketing Preferences |
Newsletter subscription status, communication preferences and areas of interest |
Newsletter and communications subscription |
|
Media Data |
Photographs, video, audio, testimonials and other content featuring or provided by participants, volunteers or supporters |
Events, programmes, impact reporting and communications, where appropriately authorised |
|
Technical Data |
IP address, browser/device information, operating system, pages visited, access times and related technical information |
Automatically when using the Website |
|
Cookie Data |
Information collected through cookies and similar technologies |
Website use, subject to applicable cookie settings and notices |
If you provide us with personal data relating to another person—for example, a child, parent/guardian, participant, emergency contact, volunteer, mentor or other individual – you should ensure that you are authorised to provide that information and that the individual has been informed where required by applicable law.
We may collect personal data:
Where appropriate and lawful, we may receive personal data about participants from parents or guardians, schools, partner organisations, programme sponsors, volunteers, mentors, emergency contacts and other persons connected with a programme.
Where appropriate and lawful, we may obtain information from publicly available sources, professional directories, partner organisations, public records and other legitimate sources.
When you use our Website, we may automatically collect certain technical information through cookies and similar technologies.
Under the NDPA, personal data must be processed on a lawful basis. Depending on the circumstances, LVCDI may rely on one or more of the following lawful bases:
|
Purpose |
What We Do |
Legal Basis |
|
Programme administration |
Registering participants, administering programmes and communicating programme information |
Contract/legitimate interest/consent, where applicable |
|
Child and participant safeguarding |
Assessing safety needs, emergency contacts, safeguarding concerns and appropriate participation arrangements |
Legal obligation/vital interest/legitimate interest/consent, where applicable |
|
Mentorship and youth development |
Delivering mentorship, education, skills, leadership, talent and community activities |
Contract/legitimate interest/consent, where applicable |
|
Parent/guardian engagement |
Obtaining and managing required parental or guardian permissions and communications |
Legal obligation/legitimate interest/consent, where applicable |
|
Volunteer, mentor and recruitment administration |
Assessing applications and managing volunteer, mentor and recruitment processes |
Legitimate interest/contract/consent, where applicable |
|
Donations and campaign administration |
Processing donations, maintaining records and communicating campaign information |
Contract/legitimate interest/legal obligation/consent, where applicable |
|
Regulatory and legal compliance |
Complying with applicable laws, lawful requests and organisational obligations |
Legal obligation |
|
Communicating with participants and supporters |
Responding to enquiries and communicating regarding programmes, campaigns and activities |
Contract/legitimate interest/consent, where applicable |
|
Newsletters and publications |
Sending updates, programme information, impact stories and event information |
Consent/legitimate interest, where permitted |
|
Events and outreach |
Registering participants and administering events and activities |
Contract/legitimate interest/consent |
|
Website improvement |
Analysing Website performance and improving content and functionality |
Consent/legitimate interest, depending on the technology used |
|
Security and fraud prevention |
Detecting, preventing and investigating security incidents, fraud and misuse |
Legitimate interest/legal obligation |
|
Protecting legal and safeguarding interests |
Establishing, exercising or defending legal claims and protecting participants or others |
Legitimate interest/legal obligation/vital interest, where applicable |
|
Organisational administration |
Managing LVCDI operations, records, personnel, partnerships and supporter relationships |
Legitimate interest/contract/legal obligation |
|
Impact reporting and communications |
Reporting on programme activities, outcomes and impact and communicating LVCDI’s work |
Legitimate interest/consent, where required |
We will generally use personal data only for the purposes for which it was collected or for another purpose permitted by applicable law. Where we intend to process personal data for a materially different purpose, we will provide appropriate information and, where required, obtain consent or establish another lawful basis before doing so.
Subject to applicable law and the legitimate requirements of our activities:
Depending on the circumstances and subject to applicable confidentiality, safeguarding and legal obligations, personal data may be shared with:
LVCDI authorised personnel – Personal data may be accessed by authorised staff, programme personnel, volunteers, mentors, consultants and other persons where necessary to perform their functions.
Parents, guardians and authorised representatives – Where necessary for a participant’s safety, programme administration or where otherwise authorised or required by law, information may be shared with a parent, guardian or other authorised representative.
Schools, partners and programme collaborators – Where reasonably necessary to administer a programme or partnership, information may be shared with relevant schools, partner organisations, programme sponsors or collaborators subject to appropriate safeguards.
Professional advisers and experts – We may engage accountants, auditors, legal advisers, safeguarding professionals, consultants, trainers, healthcare professionals or other advisers where reasonably necessary for an activity or LVCDI administration.
Such providers will only receive information reasonably necessary for the services they provide and will be subject to appropriate contractual or other safeguards where required.
We will not otherwise disclose personal data to unrelated third parties except where authorised by you, permitted or required by law, or otherwise supported by a lawful basis.
LVCDI may use service providers, technology platforms, professional advisers, donors, partners or other resources that process personal data outside Nigeria.
Where personal data is transferred outside Nigeria, we will take reasonable steps to ensure that the transfer and subsequent processing comply with applicable Nigerian data protection requirements.
Depending on the circumstances, appropriate safeguards may include contractual protections, adequacy arrangements or other lawful transfer mechanisms recognised under applicable law.
Where LVCDI acts as a Data Processor for a partner or another Data Controller, international transfers may also be governed by that organisation’s instructions and applicable contractual arrangements.
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, taking into account our legal, safeguarding, programme, contractual and legitimate organisational requirements.
Retention periods may therefore vary depending on the nature of the information.
|
Data Type |
Retention Approach |
|
Participant and programme records |
For the duration of the programme and thereafter for the period reasonably required for safeguarding, accountability, reporting, legal obligations and legitimate record-keeping requirements |
|
Parent/guardian and consent records |
For the period reasonably necessary to demonstrate consent, administer the programme and meet safeguarding, legal and accountability requirements |
|
Safeguarding and emergency records |
For the period reasonably necessary to protect participants and meet applicable legal, safeguarding and organisational requirements |
|
Volunteer, mentor and recruitment records |
For the duration of the relevant process and an appropriate period thereafter, unless longer retention is justified or consent is obtained |
|
Donation and accounting records |
For the period required by applicable law and legitimate financial/accounting requirements |
|
Communications and enquiries |
For as long as reasonably necessary to respond to and administer the enquiry and any resulting relationship |
|
Media and impact records |
For as long as reasonably necessary for the purpose for which the media was collected, subject to applicable consent, withdrawal rights and legal requirements |
|
Newsletter/marketing data |
Until you unsubscribe or withdraw consent, subject to limited suppression records |
|
Event registration data |
For the period reasonably necessary to administer the event and related records |
|
Technical/security data |
For a period reasonably necessary for security, auditing, troubleshooting and legitimate organisational purposes |
Where information is no longer required, we will take reasonable steps to securely delete, destroy or anonymise it, unless we are required or permitted by law to retain it.
about you and, where applicable, obtain a copy.
personal data.
lawful reason for us to continue processing it.
on legitimate interests, subject to applicable law.
processing of your personal data be restricted.
consent at any time. Withdrawal does not affect the lawfulness of processing
carried out before withdrawal.
a structured, commonly used and machine-readable format and request its
transmission to another controller.
Protection Commission (NDPC) where you believe your data protection rights have
been infringed.
Requests concerning your personal data should be directed to LVCDI using the contact details provided on the Website. We will acknowledge your request within 72 hours where reasonably practicable and aim to fulfil it within 30 days, subject to applicable law and any lawful extension or verification requirements.
Where we rely on consent to process personal data -for example, certain marketing communications, photographs, video, testimonials or non-essential cookies – we will request consent appropriately.
You may withdraw consent at any time where processing is based on consent.
Withdrawal of consent does not affect processing that was lawful before withdrawal.
Where a child is involved, LVCDI will apply the consent and authorisation requirements applicable to children’s personal data, including parental or guardian involvement where required by law.
We take reasonable technical and organisational measures to protect personal data, including:
No method of transmission or storage is 100% secure. While we work to protect your data, we cannot guarantee absolute security.
If a data breach affecting your personal data occurs, we will:
If you have questions about this Privacy Policy, wish to exercise your data protection rights, or have a privacy-related concern, please use the contact details or contact facility made available on the LVCDI Website.
Where LVCDI publishes a designated privacy or data protection contact, requests may be directed to that contact.
LVCDI’s activities are directed substantially towards young people and may involve children and teenagers. We recognise the heightened privacy and safeguarding considerations that apply to children’s personal data.
The LVCDI Website is not intended to enable children to submit unnecessary personal data. However, in the course of our programmes and activities, it may be necessary for LVCDI to process personal data relating to a child or young person.
If you believe that a child has provided personal data to us without an appropriate lawful basis or that a child’s privacy or safety may be at risk, please contact LVCDI using the details provided on the Website.
We may update this Privacy Policy from time to time to reflect:
Where changes are material, we may provide additional notice through the Website, email or other appropriate communication channels where reasonably practicable.
