Issued under the Nigeria Data Protection Act 2023 (NDPA) and the General Application and Implementation Directive 2025 (GAID).
| Document title | Powergas Recruitment Privacy Notice |
|---|---|
| Version | 1.0 |
| Effective date | 24th of July 2026 |
Powergas Global Investment Nigeria Limited RC 1088277 and Powergas Ebedei Limited RC 1437848, together "Powergas", "we", "us" and "our", of 21 Adeniyi Jones, Ikeja, Lagos State, Nigeria, are the data controllers in respect of the personal data described in this Notice.
This Notice explains how we collect and use personal data about you when you apply to work with us, and what rights you have in respect of that data. It is issued in accordance with the Nigeria Data Protection Act 2023 (the "NDPA") and the Nigeria Data Protection Act General Application and Implementation Directive 2025 (the "GAID").
We ask you to read this Notice before you submit an application. It should be read alongside the Powergas Privacy Notice, which contains further information about our security measures, our transfers of data outside Nigeria, and the ways in which you may exercise your rights. If you are engaged by us, we will provide you with a separate privacy notice covering the processing of your personal data during the engagement.
Our Data Protection Officer, designated under section 32 of the NDPA, may be contacted at info@powergas.com, or by post to The Data Protection Officer, Powergas, 21 Adeniyi Jones, Ikeja, Lagos State, Nigeria. Please direct any question about this Notice, and any request to exercise your rights, to the Data Protection Officer.
We collect the personal data set out below in the course of our recruitment process. Not all of it will be relevant to every role or every stage.
| Category | Examples |
|---|---|
| Identity and contact data | Your name, title, date of birth, gender where you volunteer it, postal address, email address and telephone number |
| Application data | Your curriculum vitae, cover letter, application form responses, the role you have applied for, and how you heard about the vacancy |
| Qualification and career data | Your educational history, degrees, professional qualifications and memberships, certifications, licences, training records and employment history |
| Right to work and immigration data | Your nationality, and where relevant your passport, visa, work permit or residence permit details and copies of those documents |
| Assessment data | Notes and scores from interviews, panel assessments, presentations, technical exercises, psychometric and aptitude tests, and the outcome of each stage |
| Reference data | The references we obtain from your previous employers and the referees you nominate, and the content of those references |
| Verification and screening data | The results of checks we carry out to confirm your identity, qualifications, employment history, professional standing and, where lawful and proportionate to the role, criminal record, credit standing, sanctions listings and adverse media |
| Remuneration and engagement data | Your current and expected remuneration, notice period, availability and any conditions attaching to your candidacy |
| Health data | Information about your health, disability or medical condition, where relevant to a reasonable adjustment required for the recruitment process, or to a pre-engagement medical or fitness-to-work assessment required for a role in our operational environment |
| Correspondence data | The content of your correspondence with us about your application |
| Technical data | Where you apply through the Website, the technical and usage data described in the Powergas Privacy Notice and Cookie Notice |
We obtain most of this personal data directly from you, through your application and through your participation in our recruitment process. We may also obtain personal data about you from:
Sensitive personal data is defined in section 65 of the NDPA and includes data revealing race or ethnic origin, religious or similar beliefs, health status, sex life, political opinions or affiliations, trade union membership, and genetic and biometric data. It attracts additional protection under section 30 of the NDPA and we process it only where a lawful condition in that section applies.
It remains common practice in Nigeria for a curriculum vitae to include state of origin, local government area, religion, marital status, number of children and a photograph. We do not require any of that information and it forms no part of our assessment of your suitability for a role. We ask you not to include it. Where you do include it, we will disregard it for selection purposes and we will delete it or redact it from our records where it is practicable to do so.
The only sensitive personal data we actively seek is health information, and we seek it only for two purposes: to make any adjustment you need in order to participate fairly in the recruitment process, and, for roles in our plants, stations and field operations, to establish fitness to work safely in that environment through a pre-engagement medical assessment. In each case we will tell you what we need, why we need it and what will be done with it, and we will limit the information passed to the recruiting manager to the outcome and any adjustments required, rather than the underlying medical detail.
| Purpose | Data used | Lawful basis (section 25 NDPA) |
|---|---|---|
| To receive, acknowledge and administer your application | Identity and contact data, application data, correspondence data | Taking steps at your request prior to entering into a contract; and our legitimate interest in operating an orderly recruitment process |
| To assess your skills, qualifications and suitability for the role and to make a selection decision | Application data, qualification and career data, assessment data | Taking steps at your request prior to entering into a contract; and our legitimate interest in recruiting suitable personnel |
| To obtain and consider references | Reference data, identity and contact data | Taking steps at your request prior to entering into a contract; and our legitimate interest in verifying the information on which we rely |
| To verify your identity, qualifications, employment history and professional standing | Verification and screening data, qualification and career data, right to work data | Compliance with a legal obligation; and our legitimate interest in ensuring that the information supplied to us is accurate and that our personnel are properly qualified |
| To confirm your right to work in Nigeria and to comply with immigration requirements | Right to work and immigration data | Compliance with a legal obligation to which we are subject |
| To carry out background, sanctions, adverse media and, where lawful and proportionate to the role, criminal record and credit checks | Verification and screening data | Compliance with a legal obligation; and our legitimate interest in protecting our people, assets and operations, and in meeting the integrity requirements applicable to our sector |
| To make reasonable adjustments to the recruitment process | Health data | Your explicit consent; and compliance with our legal obligations in relation to equal treatment |
| To assess fitness to work safely in an operational environment | Health data | Compliance with our legal obligations under health and safety legislation; and, where required, your explicit consent |
| To negotiate and prepare a contract of employment or engagement with you if your application is successful | All relevant categories | Taking steps at your request prior to entering into a contract |
| To keep your details for consideration for future vacancies | Identity and contact data, application data, qualification and career data | Your consent, which you may withdraw at any time |
| To monitor the diversity and effectiveness of our recruitment process, on an aggregated or anonymised basis | Aggregated or anonymised data derived from the above | Our legitimate interest in ensuring that our recruitment process is fair and effective |
| To establish, exercise or defend legal claims arising from the recruitment process | All relevant categories | Our legitimate interest in protecting our legal position; and compliance with a legal obligation, where applicable |
Where we rely on your consent, you may withdraw it at any time by contacting our Data Protection Officer. Withdrawal will not affect the lawfulness of anything done before it, and it will not prejudice any live application you have made on any other basis. Where we rely on our legitimate interests, we have balanced those interests against your interests, rights and freedoms, and you may object to the processing as described in paragraph 8.
Providing the personal data described in paragraph 2 is necessary in order for us to consider your application. If you decline to provide it, or provide it only in part, we may be unable to assess your application or to progress it to the next stage.
We do not make recruitment decisions about you based solely on automated processing, including profiling. Where any technology is used to sort, filter or rank applications, its output is reviewed by a member of our recruitment team before any decision is taken, and no candidate is rejected without human consideration. If this position changes we will tell you before it applies to your application, and we will implement the safeguards required by section 37 of the NDPA, including your right to obtain human intervention, to express your point of view and to contest the decision.
Access to your personal data within Powergas is limited to those who need it in order to carry out the recruitment process. This includes our human resources team, the recruiting manager and interview panel for the relevant role, and, where approval is required, the relevant members of management. We share your personal data outside Powergas only with the following recipients:
| Recipient | Purpose |
|---|---|
| Companies within the Powergas group | Where the role sits within, or is being recruited in conjunction with, another group company, or where group-level approval of the appointment is required |
| Recruitment agencies and executive search firms | Where they have introduced you to us or are assisting us with the recruitment, and only to the extent necessary for that purpose |
| Background screening and verification providers | To carry out the checks described in paragraph 3, acting as our data processors |
| Your nominated referees and previous employers | To obtain references, and only after we have told you that we intend to do so |
| Occupational health and medical service providers | To carry out any pre-engagement medical or fitness-to-work assessment, subject to medical confidentiality |
| Information technology, hosting, email and applicant tracking providers | To host and operate the systems through which applications are received and managed, acting as our data processors |
| Professional advisers | Our legal advisers, auditors and insurers, where necessary and subject to duties of confidentiality |
| Regulators, courts and public authorities | Where we are required or permitted to disclose personal data by law, by court order or by lawful regulatory request |
Every processor engaged by us acts only on our documented instructions and under a written contract containing the provisions required by section 29 of the NDPA. We do not sell your personal data and we do not disclose it to third parties for their own marketing purposes.
Some of the systems used in our recruitment process, and some of our service providers, are located outside Nigeria or use infrastructure located outside Nigeria. Where your personal data is transferred outside Nigeria, we do so only where the conditions in sections 41 to 43 of the NDPA and the corresponding provisions of the GAID are satisfied, including where the recipient is subject to a law, binding corporate rules, contractual clauses, a code of conduct or a certification mechanism affording an adequate level of protection, or where another lawful ground for the transfer applies. Further detail is set out in the Powergas Privacy Notice, and you may request information about the safeguards applied to a particular transfer from our Data Protection Officer.
| Circumstance | Retention period | Rationale |
|---|---|---|
| Your application is unsuccessful and you have not consented to our retaining your details | Twelve (12) months from the date we notify you of the outcome | To allow us to respond to any query or challenge concerning the recruitment decision and to demonstrate the fairness of the process |
| Your application is unsuccessful and you have consented to our retaining your details for future vacancies | Twenty-four (24) months from the date of your consent, after which we will delete your details unless you renew your consent | The consent you have given, which you may withdraw at any time |
| You withdraw your application | Six (6) months from the date of withdrawal | To record that the application was withdrawn and by whom |
| Your application is successful and you are engaged by us | The recruitment file is transferred to your personnel file and retained in accordance with our employee data retention schedule | Employment record-keeping obligations, which will be explained to you in the employee privacy notice |
| Health data collected for adjustments or fitness to work | Deleted once the purpose is spent, save where it must be retained as part of a statutory occupational health record | Data minimisation and applicable occupational health requirements |
| Records relating to a dispute, claim or investigation arising from the recruitment process | Until the matter is finally determined and the applicable limitation period has expired | Establishment, exercise or defence of legal claims |
At the end of the applicable period we delete your personal data securely, or irreversibly anonymise it so that it can no longer be associated with you, and retain it in that anonymised form only for statistical analysis of our recruitment process.
You have the rights described in the NDPA in respect of your personal data, namely the right to be informed, the right of access, the right to rectification, the right to erasure, the right to restrict processing, the right to object, the right to data portability, the right to withdraw consent, and rights in relation to decisions taken solely by automated means. These rights are described in full in paragraph 11 of the Powergas Privacy Notice.
Two points are worth noting in the recruitment context. First, the right of access extends to interview notes and assessment records that relate to you, although we may redact information that identifies or relates to another person, including a referee, where it would be unreasonable to disclose it without that person’s consent. Second, exercising any of these rights will never of itself count against your application, and no candidate is disadvantaged for having made a request.
To exercise a right, contact our Data Protection Officer at info@powergas.com. There is no fee. We may ask you to verify your identity. We will respond without undue delay and in any event within one (1) month, extendable by up to a further two (2) months where the request is complex, in which case we will tell you within the first month.
If you are dissatisfied with the way your personal data has been handled, please contact our Data Protection Officer in the first instance. You may also serve a Standard Notice to Address Grievance on us under Article 47 of the GAID, at the email or postal address above. You may in addition, and at any time, complain to the Nigeria Data Protection Commission at info@ndpc.gov.ng or through www.ndpc.gov.ng, and you may enforce your right to privacy before a Federal or State High Court.
Important Warning: Powergas does not ask any candidate to pay a fee at any stage of its recruitment process, whether for an application, an interview, a test, a medical examination, training, processing or the issue of an offer. We do not request payment details, bank account particulars or Bank Verification Numbers as part of the assessment of an application. If you receive a communication purporting to come from Powergas that asks you for money or for such details, please do not respond to it and please report it to us at info@powergas.com.
We keep this Notice under review and will update it as our recruitment process or the law changes. The current version is available at www.powergas.com. Where a change is material and affects a live application, we will bring it to your attention directly.
The Data Protection Officer
Powergas
21 Adeniyi Jones, Ikeja, Lagos State, Nigeria
Email: info@powergas.com
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