Privacy Policy

1. Overview

The Solid Minerals Advanced Regulation & Tracking System (SMARTS) is operated by the Ministry of Solid Minerals Development (“the Ministry”). This policy explains how SMARTS collects, processes, stores, and shares information in support of national mining regulation, revenue assurance, safety, environmental stewardship, and stakeholder engagement. SMARTS complies with the Nigeria Data Protection Act (NDPA), 2023 and other relevant laws governing public sector data management.

2. Data We Collect

SMARTS processes information provided directly by users and data generated through integrated systems and field instrumentation:

• Registration & Licensing Data: names, contact details, government-issued identifiers, corporate documents, and licences submitted by operators, consultants, and agencies.
• Operational & Compliance Data: production reports, inspection outcomes, incident submissions, community engagement records, environmental impact statements, and remediation updates.
• Telemetry & Geospatial Streams: IoT sensor readings, satellite imagery, drone captures, GPS coordinates, and device diagnostics from connected mining sites.
• Financial & Revenue Data: royalty payments, tax remittances, levies, export manifests, invoicing details, reconciliations, and variance reports.
• System Usage Data: authentication logs, role-based access records, device details, and performance metrics generated when authorised users interact with SMARTS.

3. Purpose of Processing

Data collected through SMARTS is used solely to deliver statutory mandates and legitimate regulatory functions, including to:

• Digitise licensing, permits, and regulatory filings for operators in the solid minerals sector.
• Monitor operational activities, safety conditions, community impact, and environmental performance in real time.
• Reconcile production, logistics, and revenue flows to eliminate leakages and optimise national income.
• Generate dashboards, analytics, and risk indicators for ministries, state governments, investors, and development partners.
• Support inspections, enforcement, dispute resolution, and emergency response coordination.
• Maintain historical records, audit trails, and evidence repositories for policy-making and legal compliance.

4. Legal Basis

The Ministry processes SMARTS data under the legal authorities conferred by relevant federal legislation governing mining, environmental protection, taxation, anti-corruption, and public finance. Processing is anchored on public interest, compliance with legal obligations, performance of a task carried out in the public interest, and, where applicable, the consent of participating operators or stakeholders.

5. Data Security & Governance

SMARTS employs layered safeguards to protect sensitive information:

• Encryption for data in transit and at rest, role-based access controls, and multi-factor authentication.
• Network segmentation, continuous threat monitoring, incident detection, and vulnerability management.
• Comprehensive audit logging, tamper-evident records, and automated compliance checks.
• Governance policies covering data classification, retention, disposal, and disaster recovery.
• Regular privacy and security reviews with independent assessments where appropriate.

6. Data Sharing & Disclosure

SMARTS shares information on a need-to-know basis with authorised entities, including:

• Federal and state government agencies responsible for mining regulation, revenue collection, security, environmental protection, and justice.
• Development partners, auditors, or consultants engaged under confidentiality agreements to support SMARTS deployment.
• Law enforcement agencies subject to valid legal requests or court orders.
• Communities, investors, or the public when regulations require transparency (e.g. environmental disclosures), ensuring sensitive data is anonymised before release.

SMARTS does not sell personal data and does not share information for marketing purposes.

7. Cross-Border Transfers

Where data hosting or processing requires infrastructure outside Nigeria, SMARTS ensures transfers comply with NDPA guidelines and that receiving providers implement equivalent safeguards. Contracts and technical controls govern all third-party processing.

8. Retention & Disposal

Records within SMARTS are retained according to statutory requirements, regulatory needs, and archival value. Operational data linked to inspections or enforcement may be stored for the lifetime of an asset or licence. Telemetry and system logs are retained for defined periods (typically 12–36 months) to support analytics, investigations, and system integrity before secure disposal or anonymisation.

9. Data Subject Rights

Individuals and organisations interacting with SMARTS may exercise rights granted under the NDPA, including:

• Confirmation whether data relating to them is being processed.
• Access to personal or corporate data submitted through SMARTS.
• Requests for rectification of inaccurate or incomplete records.
• Objections to processing in circumstances permitted by law.
• Requests for erasure where legal grounds allow (subject to record-keeping obligations).

Requests should be submitted through the SMARTS Programme Office using the contact details below. Responses will be provided within statutory timelines.

10. Children & Vulnerable Persons

SMARTS does not intentionally collect personal data from individuals under 18 years of age except when legally mandated (for example, community engagement records). Any inadvertent collection will be rectified promptly upon notification.

11. Updates to this Policy

This policy may be updated periodically to reflect legislative changes, technology enhancements, or new SMARTS capabilities. Significant updates will be communicated through official Ministry channels and within the SMARTS platform.