Data Protection Policy
How CANWYF meets its duties as a data controller under the Nigeria Data Protection Act 2023.
Last updated: October 2026 · Owner: Board of Trustees
1. Scope and roles
- Controller. CANWYF (IT No. 7915762) is the data controller for all personal data processed through canwyf.org and the iTONA platform, including farmer, plot, visit, harvest, credential, chapter and membership records.
- Processor. Green Francis Limited hosts and maintains the iTONA platform as CANWYF's data processor under a written licence and data processing agreement. It acts only on CANWYF's documented instructions, may not use CANWYF data, including anonymised or aggregated data, for its own purposes, may not engage a sub-processor or transfer data outside Nigeria without CANWYF's written authorisation, and must report any breach to CANWYF within 72 hours.
- Accountability. The Board of Trustees is accountable for this policy. The Executive Director is responsible for day-to-day compliance. Because the Executive Director also founded the processor, the Chair of the Board oversees CANWYF's audits of the processor.
- People who handle data: staff, coordinators, chapter officers and volunteers, each only as far as their role needs, and each bound to confidentiality.
2. Principles
CANWYF processes personal data lawfully, fairly and transparently; only for purposes explained to the person; no more than is needed; accurately; for no longer than needed; and securely. CANWYF does not sell personal data.
3. Lawful basis
| Processing | Basis |
|---|---|
| Enrolment, credential records, visits and harvests | Consent, recorded at enrolment |
| Public verification by reference number | Consent |
| Sharing a farmer's contact details with a buyer | Consent, for each introduction |
| A named public profile on the impact page | Separate, optional consent |
| Fraud checks on visits (GPS distance, duplicate detection) | Legitimate interests |
| Aggregate and anonymised programme reporting | Legitimate interests |
| Enquiries, pledges and supporter records | Consent and legitimate interests |
| Website statistics | Legitimate interests |
| Records kept to meet legal or audit duties | Legal obligation |
A one-way code made from a National Identification Number, plot boundaries and voice recordings are treated as requiring particular care. CANWYF does not collect data revealing religion, political opinion, health or ethnicity.
4. Farmer consent at enrolment
Consent is taken in person by the coordinator, in Ekiti Yoruba or English, before anything is recorded. The coordinator reads the notice below, answers questions, and records the farmer saying their name and agreeing. Each of the three choices at the end is recorded separately, and the farmer may say no to any of them and still be enrolled. The version of the wording used is stored with the record.
Enrolment notice (version 2026-10)
"CANWYF is a non-profit organisation. To enrol you in iTONA we will record your name, phone number, photograph, your crops, the GPS boundary of the farm you work, and visits and harvests over time. CANWYF keeps this information and is responsible for it. It is never sold.
Enrolment and verification are free. Nobody may ask you for money for them. If anyone does, tell us.
Your record will first show as Provisional. Your chapter's elected Seal Council will later decide whether to seal it. If you are a coordinator's family member, another person will record your details.
You can see your record, correct it, or withdraw at any time by telling your coordinator, your chapter Secretary or CANWYF.
Three choices, each yes or no: (1) May anyone with your reference number check your credential on canwyf.org? (2) If you list produce, may we give buyers your phone number? (3) May we show your name and photograph on our public impact page?"
Farmers enrolled before this version are asked again, using this wording, at the chapter meeting where the change to Provisional status is explained.
5. Recording rules that protect data quality
- Every record names the person who recorded it.
- No coordinator may record evidence for their own plot, household or immediate family. The platform is being changed to refuse such a record automatically; until then the rule is enforced by review.
- Credential status changes are logged with who made them, when and why, and the log is shown on verification. The platform is being changed so that the log cannot be edited or deleted.
6. Processors and other recipients
CANWYF uses processors only under written terms that meet the Act. Current recipients, and what each receives, are listed in the privacy notice. Any new processor is approved by the Executive Director and recorded; any processor in which a trustee has an interest is approved by the Board with that trustee recused.
7. Transfers outside Nigeria
Personal data is transferred outside Nigeria only on a basis permitted by Part VIII of the Act, and farmers' enrolment records only with CANWYF's written authorisation to the processor.
8. Retention
- Enrolment, credential and audit-log records: membership plus six years.
- Consent recordings: as long as the consent is relied on.
- Enquiries and pledges: two years from last contact.
- Website statistics: two years.
- Data collected for the retired wallet feature (mobile money numbers and family beneficiary details): deleted.
9. Rights requests
Requests for access, correction, deletion, restriction, portability, objection or withdrawal of consent may be made to a coordinator, a chapter Secretary or by email to info@canwyf.org. They are logged and answered within one month, free of charge. Entries in the credential log are not deleted while the record is retained; a correction note is added instead.
10. Security
- Encrypted connections for the website, the platform and the field app.
- Two-step verification for administrators; role-based access; access logs.
- Identity numbers stored only as one-way codes.
- Daily backups with restricted access; secrets kept out of source code.
- Annual review of who has access.
11. Breaches
Anyone who suspects a personal data breach reports it to the Executive Director at once. Where a breach is likely to put people at risk, CANWYF notifies the Nigeria Data Protection Commission within 72 hours of becoming aware of it and tells the people affected without undue delay, in a way they can understand. Every breach is logged with what happened and what was done.
12. Review
The Board reviews this policy every year, and whenever the platform starts collecting a new kind of personal data.
13. Contact and complaints
Community Advocacy Network for Women, Youth and Farmers, 32 Orisumbare Street, Nova Road 6, Adebayo, Ado-Ekiti, Ekiti State.
Email: info@canwyf.org
Regulator: Nigeria Data Protection Commission, ndpc.gov.ng