Introduction

FirstCentral Credit Bureau Limited (“FirstCentral”) provides services based on credit information about individuals and businesses. The collection, retention and use of that information is guided by the Credit Reporting Act, 2017 (the “Act”) and the Central Bank of Nigeria’s Guidelines on the Licensing, Operations, and Regulations of Credit Bureaus and Credit Bureau Related Transactions in Nigeria, 2013 and any amendment thereto(the “Guidelines”). Both the Act and the Guidelines are referred to as “Regulations”. This Privacy Policy applies to all credit and personal information collected by FirstCentral.

Please carefully read our privacy policy to understand how we will treat your credit information and the personal information you provide while visiting our website (“Website”).

Our Commitment

We acknowledge that information is the foundation for providing you with superior service and protecting the privacy of your personal information is of the highest importance to us. We believe that responsible stewardship of the information entrusted to us is crucial in developing and maintaining the public trust which in turn is essential for our business. We use security technologies to safeguard credit information and other information provided to us.

We are sensitive to your privacy concerns, and are committed to letting you know what kind of personal information including credit information, information provided to us by credit providers is being collected and how the information is being used.

This Privacy Policy provides information as to how we manage your personal and credit information including:

a. the kinds of credit information that we collect and how we collect that information;

b. the kinds of credit information that we hold, and how we hold that information;

c. the kinds of personal information that we usually derive from the information we hold;

d. the purposes for which FirstCentral collects, holds, uses and discloses credit information;

e. how you can access a copy of the credit information we hold;

f. how you can seek the correction of such information and your rights to correct; and

g. how you can complain if we don’t meet our legal obligations and how we deal with such complaints.

Sources and Collection of Credit Information

For the purposes of our operation, FirstCentral collects credit information from Credit Information Providers and furnishes this information to Credit Information Users. We can only disclose your credit information to a Credit Information User for a permissible purpose.

This information may include:

• details of your financial and credit dealings with both financial and non-financial companies

• prior instances of non-payment or collection activities;

• name (and change of name), address (and change of address) and other contact details ;

• queries of your credit information made by credit information users;

• Details of any means of identification.

There may be circumstances when we collect additional details from you for the purposes of servicing your request, for example contact details. We would request that if you have a matter with us which is outstanding and your contact details change, that you contact us to furnish us with such changes.

Section 27 of the Act defines Credit information Provider to include the following;

a. Banks, specialized banks and other financial institutions

b. Leasing companies

c. Insurance companies

d. Cooperative societies and institutions that offer credit to medium, small and micro enterprises

e. Utility companies including electricity companies, telecommunications companies, and water corporations;

f. Asset management companies

g. Credit Reporting Management System (CRMS)

h. Suppliers of goods and providers of services on a post-paid, deferred or installment payment basis

i. Other entities that in their ordinary course of business have relevant information that complies with Permissible Purpose and serves the purpose of the credit bureau, with a proviso that the Central Bank of Nigeria may issue directives or guidelines adding or removing any person mentioned above.

Permissible Purpose is defined in Section 7 of the Act to include the following:

a. Considering an application for credit by any person or considering a person’s qualification to act as a guarantor for any credit;

b. Reviewing, renewing, restructuring or monitoring of existing credit facilities;

c. Carrying out employment checks on employees or prospective employees

d. Assessing the credit worthiness of a prospective tenant in any lease or tenancy;

e. Underwriting, reviewing, renewing insurance policies or analyzing insurance claims

f. Considering applications for credit contracts or other post-paid services

g. Taking actions in respect of debt collection, enforcement of a monetary judgment or enforcement of any other debt;

h. Satisfying a request by a data subject to validate the correctness or otherwise of credit information held by a credit bureau in respect of such data subject;

i. Providing credit scoring services by credit bureau

j. Complying with any court order to provide credit information or where a person is required by applicable law to provide credit information in respect of any other person;

k. Complying with the directive of a regulatory authority or public body to provide credit information;

l. Carrying out know-your-customer checks on any person for any permissible purpose or a may be required by law;and

m. Such other purposes as the Central Bank of Nigeria may specify or direct.

FirstCentral Credit Bureau may collect your personal information to enable us:

• to provide our products and services to those parties who are authorised under the Act and/or the Guideline to access your credit information;

• to provide you with your credit report when you ask us to do so;

• to test the accuracy of the process by which your information is provided to us, updated and loaded into our systems.

There may be circumstances when we collect additional details from you for the purposes of servicing your request, for example contact details. We would request that if you have a matter with us which is outstanding and your contact details change, that you contact us to furnish us with such changes.

Data Security

FirstCentral takes reasonable steps to protect all data it holds against loss, unauthorised access, use, modification or disclosure and any other misuse.

Once collected, FirstCentral holds information in our secured database. Our database is only accessible by our authorised personnel who are specially trained in security and data handling policies and protocols to our business standards and the credit information retention and reporting obligations under the Act and the Guideline.

FirstCentral recognize and acknowledge the importance of keeping the personal information and data that it holds secure and protected from unauthorised access. To do this, industry standard security and encryption processes and technology are utilised to ensure that access to information is only provided to those personnel who need to have access in order to perform their role. Access is also provided to users and subscribers of the products and services we offer within the framework prescribed by the Act and Guideline.

How your information becomes a credit report

FirstCentral uses the credit information it holds to prepare your credit report. The credit report may include:

a. your identification details including name, (former names) and address (former addresses);

b. details of any defaults reported to us;

c. comprehensive credit information including details of late or missed payments reported to us;

d. the number of queries made on your credit reporting information by Credit Information Users.

Access to your credit information

You are entitled to request access to review the credit information we hold in respect of you.

To request access you should sign up on Snap Check or send us a request with the following details:

a. proof of your identity;

b. if you have authorised a third-party to act on your behalf:

i. Your identification document;

ii. proof of identity of the third-party whom you have authorised; &

iii. a written statement signed by you authorising the identified third-party to receive the information on your behalf.

Complaint/Corrections

FirstCentral prides itself on the level of customer service we provide and takes every effort to ensure our compliance with the Regulations.

If you believe that information we hold about you may not be up-to-date, accurate or complete, you may apply to us for a correction of that information. To make a correction request you should:

a. apply for access to your credit reporting information to ascertain that information is not up-to-date, accurate or complete;

b. note the specific information you seek to correct and provide all reasonable details of why you believe the information is not correct, complete or up-to-date, accurate or complete;

c. attach all relevant materials which support your belief that the relevant information is not correct, complete or up-to-date, accurate or complete.

On receipt of your complaint we will investigate and use all reasonable endeavours to resolve the issue within the time stipulated by the Regulations. We may require further information or details from you to complete our investigation of your complaint. Depending on the nature of the correction we may require further information from or the assistance of another party such as the Credit Information Provider to investigate or resolve the correction request.

Data Retention Period

By the provisions of § 5 of the Act, we are mandated to maintain credit information for a period of not less than 6 years form the date on which such credit information was provided to it or, if later, from the date on which we last provided such information to a Credit Information User, after which such credit information shall be archived for a further period of 10 years and may thereafter be destroyed.

Website use and telephone or postal contact

We may also collect personal information from you when you contact us. Collection of personal information in these circumstances is for the purpose of dealing with your enquiry, identifying you, ensuring only those authorised can access our information services or for contacting you and your personal information will not be used or disclosed for any other purpose, except where FirstCentral is required to do so by law or regulation.

Contact us

If you have any queries relating to your credit and/or personal information held by FirstCentral or this policy, please contact us: By telephone: +2348178377643 By email: info@firstcentralcreditbureau.com By post: FirstCentral Credit Bureau Limited 14 Sumbo Jibowu Street, South West Ikoyi, Lagos.