Recruitment Privacy Policy
OPay Digital Services Limited
Last updated: June 2026 · Governed by Nigeria Data Protection Act, 2023 (NDPA)
1. Introduction
OPay Digital Services Limited (“OPay”, “we”, “us”, or “our”) is committed to protecting the privacy and personal data of individuals who engage with our recruitment and talent acquisition processes.
This Recruitment Privacy Policy explains how we collect, use, store, share, and otherwise process the personal data of job applicants, potential candidates, interns, trainees, and any other individuals applying for employment with OPay.
This Policy is issued in accordance with applicable data protection laws, including the Nigeria Data Protection Act, 2023 (“NDPA”), regulations issued by the Nigeria Data Protection Commission (“NDPC”), and other relevant data protection and employment laws applicable to OPay’s operations.
By applying to OPay, participating in our recruitment process, or engaging with our talent acquisition platforms, you acknowledge that your personal data will be processed in accordance with this Policy.
2. Definitions
For the purpose of this Policy, the following terms have the meanings set out below:
3. Personal Data We Collect
OPay collects and processes personal data that is necessary and proportionate for recruitment and hiring purposes. This includes:
Identification & Contact Information
- Full name, personal email address, phone number, residential address, and location details used for identity verification and communication.
Professional & Employment Background
- Curriculum Vitae (CV) and resume details, employment history, academic qualifications, certifications, professional memberships, skills, work experience, salary expectations, notice period, and portfolio or project links relevant to assessing suitability for a role.
Evaluation & Assessment Data
- Interview notes, recorded video responses (where applicable), assessment scores, technical test results, case study submissions, and structured feedback from interviewers and assessors.
Background Verification & Screening Data
- Professional reference checks, employment history confirmations, educational verification results, regulatory screening outcomes, sanctions and watchlist screening results, and integrity-related checks.
Technical & Portal Usage Data
- IP address, device identifiers, browser type, portal usage data, timestamps, and system activity logs when interacting with our digital recruitment platforms.
Site Security Data
- CCTV footage and visitor log records captured when attending in-person interviews or selection events at OPay offices.
Sensitive Personal Data (Where Permitted)
- Strictly for lawful purposes, such as disability information for workplace accessibility accommodation, health-related fitness information required for specific roles, or criminal background records for regulated financial positions.
4. Sources of Personal Data
We collect personal data through multiple legitimate channels:
Directly from you: When you submit an application, upload your CV, participate in interviews, complete assessments, or communicate with our talent acquisition team.
From professional third parties: Recruitment agencies, professional referees, previous employers, academic institutions, and credential/background screening verification partners.
Public and professional networks: Publicly available professional profiles such as LinkedIn, GitHub, or relevant professional portfolios.
Regulatory authorities: Relevant regulatory bodies, government databases, and statutory registers where legally authorized for verification and compliance.
5. Purposes of Processing
OPay processes personal data strictly for legitimate recruitment, employment, regulatory, and operational purposes:
Application Management & Evaluation: Assessing qualifications, reviewing CVs, conducting interviews, administering tests, and determining suitability against role requirements.
Candidate Communication: Scheduling interviews, providing application status updates, and issuing recruitment offers or notifications.
Pre-employment Verification: Conducting background screening, credential validation, reference checks, and integrity assessments.
Regulatory & Legal Compliance: Fulfilling statutory obligations applicable to OPay as a regulated financial institution, including Anti-Money Laundering (AML), Counter-Financing of Terrorism (CFT), fraud prevention, and NDPC compliance.
Onboarding & Integration: Facilitating employment contract documentation, IT provisioning, and system onboarding for successful applicants.
Dispute Resolution & Record Keeping: Maintaining audit trails, managing potential recruitment disputes, and retaining records for legitimate statutory periods.
6. Legal Basis for Processing
OPay processes personal data on one or more lawful bases under the Nigeria Data Protection Act, 2023 (NDPA):
Contractual Steps: Processing is necessary to take steps at your request prior to entering into an employment contract.
Legal & Regulatory Obligations: Processing is necessary for compliance with mandatory legal, regulatory, and financial sector obligations.
Legitimate Interests: Processing is necessary for legitimate recruitment administration, talent pipeline development, fraud prevention, security, and internal workforce planning, provided these interests do not override your fundamental rights.
Consent: Where required by law (such as for sensitive personal data or specific background verifications), we will obtain your explicit consent.
7. Background Verification and Screening
OPay conducts background verification checks for selected roles, particularly positions involving access to sensitive systems, customer data, financial operations, or regulatory responsibilities.
These checks may include verification of employment history, academic credentials, professional certifications, identity verification, reference checks, and screening against relevant sanctions or regulatory watchlists.
Where required by applicable law, we will obtain your consent prior to conducting such checks. All screening activities are carried out in a proportionate, lawful, and strictly confidential manner.
8. Recruitment Assessments and Automated Tools
OPay may utilize recruitment tools and technologies to assist candidate evaluation, including applicant tracking systems, skills assessment platforms, and scoring assistance tools.
Such tools are used to assist decision-making but do not replace human judgment. Final hiring decisions involve meaningful human review.
Where automated processing has a material effect on candidates, we ensure compliance with applicable data protection requirements, including transparency and the right to human review.
9. Data Retention
We retain candidate personal data only for as long as necessary to fulfill the purposes for which it was collected:
Successful Candidates: Your recruitment records will be transferred to and maintained as part of your employee personnel file in accordance with our internal HR retention policies.
Unsuccessful Candidates: Where an application is unsuccessful, we retain recruitment records for up to eighteen (18) months following the recruitment decision to manage potential disputes, maintain audit compliance, and fulfill statutory requirements.
Talent Pool Retention: Where you have provided express consent to join our Talent Pool, we may retain your profile and CV for future job opportunities for a longer period. You may withdraw your consent to be in the talent pool at any time.
10. Data Security
OPay implements appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, loss, or destruction.
These safeguards include role-based access control, industry-standard encryption, multi-factor authentication, secure network perimeter defenses, continuous monitoring, and strict confidentiality agreements for all personnel and service providers.
While we apply rigorous security standards, no electronic transmission or digital storage system can be guaranteed to be 100% impenetrable. We maintain incident response procedures to address any suspected data security events promptly.
11. Candidate Rights
Under the Nigeria Data Protection Act (NDPA) and applicable regulations, you have specific rights concerning your personal data:
Right to Access: You may request confirmation and a copy of the personal data we hold about you.
Right to Rectification: You may request the correction of inaccurate or incomplete personal data.
Right to Erasure: You may request the deletion of your personal data where retention is no longer legally justified.
Right to Restrict or Object: You may object to or request restrictions on specific processing activities under certain conditions.
Right to Withdraw Consent: Where processing relies on consent, you may withdraw your consent at any time without affecting previous lawful processing.
Right to Lodge a Complaint: You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data protection rights have been infringed.
12. Contact Information & Data Protection Officer
If you have questions, inquiries, or wish to exercise your data protection rights regarding recruitment data, please contact our Data Protection Officer:
Data Protection Officer
OPay Digital Services Limited
Email: [email protected]
Contact: [email protected]
13. Changes to This Policy
OPay reserves the right to update this Recruitment Privacy Policy from time to time to reflect changes in legal, regulatory, or operational requirements.
Any updates will be published on our recruitment platforms with a revised effective date and will take effect immediately upon publication.