Leadworth Consulting Limited

1. Introduction and background

Leadworth Consulting Limited ("LWC" or "Leadworth"), a company duly registered in Nigeria (RC: 2021777), is committed to maintaining the highest standards of data protection and privacy. Together with our global partners, we prioritize the security of the personal information entrusted to us by our clients, job applicants, website visitors, and other third parties with whom we engage.

This Privacy Policy outlines our practices regarding the collection, use, and disclosure of personal data acquired through our digital platforms and professional engagements.

1.1. Consent and compliance

By accessing our website or providing personal information whether in person, via email, telephone, or other electronic means—you acknowledge and consent to the data processing practices described in this policy.

We are dedicated to full transparency and compliance with relevant data protection frameworks, including:

The Nigeria Data Protection Act (NDPA) 2023
The General Data Protection Regulation (GDPR) (EU) 2016/679

Where applicable, we may provide supplemental notices at the point of data collection to highlight specific uses of your information, offering you the opportunity to opt-in or opt-out of certain processing activities.

1.2. Scope of this policy

To ensure clarity and accessibility, this policy is structured to cover the following key areas:

Data Collection: The types of personal information we may collect from you.
Utilization of Data: How your information is used to facilitate our services.
Information Sharing: The circumstances under which we disclose data to third parties.
Data Security: The technical and organizational measures we employ to protect your information.
Your Rights: How to access your data, update your preferences, or opt-out of marketing communications.
Cookies: Our policy regarding tracking technologies.
Complaints: Your right to lodge a formal grievance regarding data handling.
Policy Updates: Procedures for notifying you of changes to this document.

2. Information we may collect

2.1. General data collection

We may collect and process personal information through the following channels:

Correspondence: Records of communications via post, telephone, live chat, email, or other electronic means.
Voluntary Submissions: Information provided during inquiries, registrations, or the employment application process, including your name, professional title, and contact details.
Transaction Records: Details of engagements and transactions conducted through our website or our Partners, and the subsequent fulfillment of services.
Website & Analytics: Technical data regarding your visits to our website, including but not limited to IP addresses, domain names, browser versions, operating systems, traffic and location data, and the specific resources accessed via cookies and tracking technologies.

2.2. Specialized service delivery

Leadworth Consulting is a primary HR Consulting, Organizational Competence Development, and Data Privacy Compliance firm. In the course of delivering our recruitment, outsourcing, and career development services, we process data in the following ways:

a. Indirect collection (public sources)

To facilitate recruitment and background verification, we may aggregate information regarding your academic and professional history—including current and former employers and job titles—from publicly available sources. This includes search engines, corporate websites, and professional networking platforms where you have chosen to make your profile public.

We have installed CCTV cameras at strategic locations throughout our office to monitor building access and enhance security. In accordance with privacy regulations, clear signage is posted at all entrances to notify visitors. In addition, all guests are required to provide their details in our data protection compliance visitor register to assist with our ongoing movement monitoring and security protocols.

b. Direct submissions

We collect detailed personal information provided by you, such as:

Full name and contact information (address, telephone, email).
Comprehensive academic and professional history as contained in a CV or resume.
Financial information (e.g., bank account details) where required for platform access or specific service participation.

c. Background verification & compliance

As part of our commitment to industry best practices and client instructions, we may conduct background checks to verify your identity and financial data. By engaging our services, you consent to screening against:

Sanction, regulatory, and law enforcement lists.
Criminal record databases.
Negative media reports to prevent fraud and mitigate professional risk.

3. Utilization of personal information

We utilize your personal information for specific business and legal purposes. Under the Nigeria Data Protection Act (NDPA) 2023 and the GDPR, we are required to specify the legal "grounds" (justifications) for processing your data.

3.1. Service delivery for client employees & candidates

To provide effective HR and compliance services to our clients, we process the information described in Section 2 to perform background checks and verification exercises.

Verification Scope: We conduct these exercises strictly in accordance with applicable data protection laws.
Authorization: Processing for these purposes occurs only after you have provided explicit consent to us and/or the relevant Data Controller.

3.2. Legal bases for processing

The following justifications represent the legal grounds upon which Leadworth processes your information:

Consent: Where you have granted clear and unambiguous permission for us to process your data for a specific purpose (typically collected via a formal consent form).
Contract Performance: Where processing is necessary to fulfill a contract we have with you, or to take specific steps at your request before entering into a contract.
Legal Obligation: Where processing is required for Leadworth to remain compliant with statutory and regulatory laws in Nigeria or other relevant jurisdictions.
Legitimate Interests: Where processing is necessary for our legitimate business interests (or those of a third party), provided these interests are not overridden by your fundamental rights or freedoms.
Legal Claims: Where your information is required to establish, exercise, or defend legal claims or proceedings.

3.3. Third-party data

If you provide personal information to us regarding another individual (a "Data Subject"), you represent and warrant that you have obtained the necessary prior consent from that individual. You are responsible for ensuring they are aware of the terms of this Privacy Policy and how their data will be utilized by Leadworth.

4. Transmission, storage and security

4.1. Security measures

Leadworth prioritizes the integrity and confidentiality of your data. We have implemented robust physical, electronic, and managerial procedures designed to safeguard the information we collect.

Access Control: Access to personal data is strictly limited to employees, partners, and clients who have a legitimate "need-to-know" to fulfill business obligations. These parties process data only under our direct instructions and are bound by stringent confidentiality agreements.
Payment Security: All financial transactions and payment data are processed using industry-standard encryption protocols.
Breach Protocols: We have established formal procedures to address any suspected personal data breach. In the event of a high-risk security incident, we will notify you and the relevant regulatory authorities as required by law.

4.2. Internet communications

While we maintain commercially reasonable safeguards in accordance with the NDPA and GDPR, no method of transmission over the internet or electronic storage is 100% secure.

User Responsibility: You are encouraged to take appropriate precautions when transmitting data to us online. By providing your personal data, you acknowledge the inherent security risks associated with internet-based communication.
Third-Party Interactions: We urge you to exercise caution when sharing personal information with third-party partners. Only provide sensitive data when absolutely necessary for the service being rendered.

4.3. Data storage and retention

All personal information is stored on secure servers and managed under our internal security standards.

Retention Policy: We retain your personal information only for as long as is necessary to fulfill the purposes for which it was collected, or to satisfy legal, regulatory, or reporting requirements.
Dual-Purpose Data: If data is used for two distinct purposes, we will retain it until the purpose with the longer duration expires; however, we will cease all processing for the shorter-term purpose once its specific timeframe has elapsed.
Data Disposal: Once your information is no longer required for business or legal purposes, it is either permanently deleted, securely destroyed, or anonymized (rendered non-identifiable) for long-term analytical use.

5. Disclosure of information

Leadworth Consulting may disclose your personal information to third parties under specific circumstances, ensuring such sharing is always conducted within the framework of the NDPA and other relevant privacy laws.

5.1. Authorized disclosures

We are permitted to disclose your information in the following instances:

Recruitment and Placement: If you are a candidate, we may disclose your professional profile and relevant data to potential employers and recruiters to facilitate employment opportunities on your behalf.
Verification Services: We exchange necessary information with our clients and partners during the execution of background checks, academic verifications, or professional screenings.
Legal and Safety Requirements: We may disclose data if required by law, or when such disclosure is necessary to protect the property, safety, or legal rights of Leadworth Consulting, our clients, or the general public.

5.2. Third-party service providers

We may engage reputable third-party organizations to perform specialized functions on our behalf. These services include, but are not limited to:

Payment processing and financial transactions.
Background screening and identity verification.
Search engine optimization and digital analytics.
Marketing and advertising activities.
Cv analysis for prospective applicants and job seekers.

5.3. Data protection standards for third parties

When we share your information with third-party service providers, we implement the following safeguards:

Contractual Compliance: Any third party granted access to your data is contractually prohibited from using it for any purpose other than the specific service they are performing for Leadworth.
Security Assurance: We take all reasonable steps to ensure that third parties handle your data safely and securely, in full alignment with your rights and our statutory obligations under the NDPA 2023.

6. Your rights and contact information

6.1. Marketing preferences

You have the right to opt-out of receiving marketing communications from us. We will typically inform you (before collecting your data) if we intend to use your information for such purposes. You can exercise your right to prevent marketing processing by:

Checking the relevant "opt-out" boxes on our data collection forms.
Clicking the "unsubscribe" link in any marketing email.
Contacting us directly at any time via the details provided in Section 6.6.

6.2. Your statutory rights

Under the NDPA 2023 and GDPR, you possess specific rights regarding your personal information. Subject to certain legal conditions, you may request that we:

Information Access: Provide further details on how we utilize your personal data.
Data Portability: Provide a copy of the personal information you have shared with us in a structured format.
Rectification: Update or correct any inaccuracies in the personal information we hold.
Erasure ("Right to be Forgotten"): Delete personal information for which we no longer have a lawful ground to process.
Withdrawal of Consent: Terminate specific processing activities where consent was the primary legal basis.
Objection: Object to processing based on "Legitimate Interests," unless our compelling grounds for processing override your individual rights.
Restriction: Limit the processing of your data while a formal complaint or inaccuracy is being investigated.
Account Deactivation: Close your account and cease active use of your data.

6.3. Exercising your rights

To exercise any of the rights listed above, please submit a formal request to info@leadworthconsulting.com.

Identity Verification: For your protection, we may require proof of identity before fulfilling your request.
Response Timeline: We aim to respond to all legitimate requests within one month.
Exemptions: Please note that these rights are not absolute. We may decline requests where processing is necessary to safeguard public interest (e.g., crime prevention) or to maintain legal privilege.

6.4. Data accuracy

We rely on the information you provide to remain accurate and complete. If your professional or contact details change, please notify us promptly at the contact address below to ensure our records remain up to date.

6.5. How long your data is retained

We retain data for not more than five (5) years, and this is determined by the purposes for which your data was collected. Thereafter, we securely dispose of it in accordance with our data retention policies (see our Data Retention Policy).

6.6. Contact and complaints

If you have questions regarding this Privacy Policy or Leadworth Consulting's data handling practices, please contact our Data Protection Officer (DPO):

Email: info@leadworthconsulting.com
Subject Line: Attention: Data Protection Officer

If you remain unsatisfied with our response or believe our processing of your data does not comply with the law, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC). You may also contact us through our website.

7. Cookies policy

We use secure cookies and similar technologies to improve your experience and analyze site traffic. We do not sell personal information collected via our website. For full details on how we use cookies and data privacy in tracking, see our Cookies Policy.

8. Complaints and data accuracy

You have the right to lodge a formal complaint at any time with the Nigeria Data Protection Commission (NDPC). However, Leadworth Consulting values the opportunity to resolve your concerns directly. We encourage you to contact us in the first instance so we may address any grievances regarding your data privacy.

To ensure your data remains protected, it is vital that the information we hold is accurate and current. Please notify us immediately of any changes to your personal details during your professional relationship with us.

9. Amendments to this policy

As our services evolve and technology advances, we may update the content of our website and our use of cookies without prior notice. Consequently, this Privacy Policy may be modified periodically. We encourage you to review this page regularly to remain informed about how we protect and utilize your personal information.

10. User acknowledgment

By accessing our website and utilizing our services, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy.

11. Dispute resolution and governing law

11.1. Amicable settlement

In the event of a dispute arising out of or relating to this Privacy Policy, both parties agree to use their best efforts to negotiate in good faith to reach an amicable settlement.

11.2. Continuity of obligations

The existence of a dispute shall not suspend or affect the ongoing obligations of Leadworth Consulting to protect your data as outlined in this policy.

11.3. Jurisdiction

This Privacy Policy, including any non-contractual claims or disputes, shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria.