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SERAP Files Suit Against CBN Over KYC Social Media Policy

Published

3 years ago

23/07/2023

By Adedapo Adesanya

Socio-Economic Rights and Accountability Project (SERAP) has filed a lawsuit against the Central Bank of Nigeria (CBN) over its proposed Know-Your-Customer (KYC) social media policy.

The suit filed on behalf of SERAP by its lawyers, Mr Kolawole Oluwadare and Ms Blessing Ogwuche, said “the failure to delete the patently unlawful provisions in the Central Bank of Nigeria (Customer Due Diligence) Regulations directing banks to obtain information on customers’ social media handles for the purpose of identification.”

The CBN had last month issued a circular mandating banks and other financial institutions to implement and comply with the mandatory provisions on customers’ social media handles in the CBN Regulations. This raised a late of complaints from Nigerians as well as government agencies.

In the suit number FHC/L/CS/1410/2023 filed last Friday at the Federal High Court in Lagos, SERAP is seeking: “an order of mandamus to direct and compel the Central Bank of Nigeria to withdraw its directive dated 20th June 2023 to banks and other financial institutions to obtain information from customers’ social media handles.”

SERAP, through the suit, is also seeking: “an order of mandamus to compel the CBN to delete the unlawful provisions of Section 6 of its Customer Due Diligence Regulations, 2023 for being inconsistent with Section 39 of the Nigerian Constitution 1999 [as amended] and Article 9 of the African Charter on Human and Peoples’ Rights.”

SERAP is also seeking: “an order restraining the CBN from carrying out or giving effect to the unlawful provisions of Section 6 of its Customer Due Diligence Regulations, 2023, directing banks and other financial institutions to obtain information from customers’ social media handles.”

In the suit, SERAP is arguing that: “The mandatory requirement of social media handles or addresses of customers does not serve any legitimate aim. Such information may be used to unjustifiably or arbitrarily restrict the rights to freedom of expression and privacy.”

SERAP is also arguing that, “Unless the reliefs sought are granted, the CBN will implement and enforce the unlawful directive in contravention of citizens’ rights to freedom of expression and privacy.”

According to SERAP, “There are other means of identification such as passport, driver’s licence, Bank Verification Number (BVN), and Tax Identification Number (TIN), which banks and other financial institutions already require their customers to provide.”

SERAP is also arguing that, “The additional requirement of obtaining details of a customer’s social media handle or address fails to meet the requirements of legality, necessity, and proportionality.”

The group further argued that, “The fact that there are sufficient means of identification for CBN, banks and other financial institutions to rely on to meet the requirement of Know Your Customer also heighten concerns of overreach, and confer far-reaching discretion on banks and financial institutions.”

“Obtaining information on customers’ social media handles or addresses as means of identification is more intrusive than necessary.”

“According to Section 6(a)(iv) of the CBN Regulations, banks and other financial institutions ‘shall identify their customer and obtain information on the social media handle of the customer.’ Section 6(b)(iii) contains similar provision.

“The purported mandatory requirement would inhibit Nigerians from freely exercising their human rights online. If obtained, such information may also be misused for political and other unlawful purposes.

“The CBN Regulations and directive to banks and other financial institutions would impermissibly restrict the constitutional and international rights to freedom of expression, privacy and victims’ right to justice and effective remedies.

“Requiring social media handles or addresses of customers as a means of identification would have a disproportionate chilling effect on the effective enjoyment by Nigerians of their rights to freedom of expression and privacy online.

“The requirement of necessity implies an assessment of the proportionality of the grounds, with the aim of ensuring that the excuse of ‘regulations on customer due diligence’ is not used as a pretext to unduly intrude upon the rights to freedom of expression and privacy.

“The CBN Regulation does not demonstrate how the use of social media handle or address as a means of identification would serve to improve banks and other financial institutions’ ability to implement and comply with the laws and regulations relating to customer due diligence.

“The Directive by the CBN, which does not in any event carry the force of law, also fails to provide any explanation as to how social media handles or addresses can facilitate compliance with regulations relating to customer due diligence.

“Obtaining the details of customers’ social media handles or addresses would unduly interfere with the rights to freedom of expression and privacy. It would also be disproportionate to any purported legitimate aim that the CBN seeks to achieve.

“The cumulative effect of any attempt to access details of customers’ social media handles or addresses would be to undermine the letter, substance and spirit of the rights to freedom of expression and privacy of Nigerians.

“The effective enjoyment of these fundamental rights constitutes a fundamental pillar for building a democratic society and strengthening democracy.

“The positive obligations of Nigeria to ensure the rights to freedom of expression and privacy will only be fully discharged if individuals are protected against violations by institutions like the CBN.

“The Nigerian Constitution guarantees in Section 39 the right to freedom of expression and in Section 37, the right to privacy.

“Article 19 of the International Covenant on Civil and Political Rights and Article 9 of the African Charter on Human and Peoples’ Rights also guarantee the right to freedom of expression. Article 17 of the Covenant also guarantees the right to privacy.

“In particular, Article 19(1) of the Covenant establishes the right to freedom of opinion without interference. Article 19(2) establishes Nigeria’s obligations to respect and ensure ‘the right to freedom of expression,’ which includes the freedom to seek, receive and impart information and ideas of all kinds, regardless of frontiers.

“Under article 19(3), restrictions on the right to freedom of expression must be ‘provided by law’, and necessary ‘for respect of the rights or reputations of others’ or ‘for the protection of national security or of public order (ordre public), or of public health and morals.

“The principles of legality, necessity, and proportionality apply to the right to privacy in the same manner as they do to freedom of expression and other fundamental freedoms.

“Restrictions to the rights to freedom of expression and privacy that do not comply with the elements of legality, legitimate purpose, and necessity and proportionality shall be deemed unlawful,” it read in part.

No date has been fixed for the hearing of the suit.

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Adedapo Adesanya

Adedapo Adesanya is a journalist, polymath, and connoisseur of everything art. When he is not writing, he has his nose buried in one of the many books or articles he has bookmarked or simply listening to good music with a bottle of beer or wine. He supports the greatest club in the world, Manchester United F.C.

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Salary Benchmarking To Ensure Competitive Compensation

Published

2 days ago

20/02/2026

Dipo Olowookere

Salary benchmarking is the systematic process of comparing an organization’s pay rates, bonus programs, and total rewards against market standards. This article walks through why benchmarking matters, how to prepare and run an analysis, the best data sources and tools, and how to turn findings into defensible pay structures and ongoing processes.

Why Salary Benchmarking Matters For Online Businesses And Agencies

Without benchmarking, organizations risk three costly outcomes: underpaying (leading to high turnover and loss of institutional knowledge), overpaying (inflating fixed costs and reducing agility), or misallocating compensation across roles (creating internal inequities and morale problems).

For agencies that pitch retainer-driven services, predictable labor costs tied to market rates enable healthier margins and clearer pricing decisions. For in-house ecommerce teams, benchmarking supports workforce planning when launching new product lines or scaling paid acquisition efforts.

Finally, benchmarking is not only financial: it signals professionalism to candidates.

Key Data Sources And Tools For Accurate Benchmarks

High-quality benchmarking blends public data, commercial platforms, and human intelligence.

Public Government And Aggregated Salary Data

Bureau of Labor Statistics (BLS) or national equivalents provide reliable occupational wage ranges, useful for baseline comparisons and compliance checks.

Industry Surveys, Salary Platforms, And Niche Reports

Platforms such as Payscale, Glassdoor, LinkedIn Salary, and specialized reports for marketing and tech roles give role- and location-specific distributions.

Recruiter Intelligence And Peer Networks

Recruiters and hiring agencies provide real-time insight into candidate expectations and accepted offers. Professional networks, Slack communities, and agency owner peer groups can also offer current market anecdotes that databases miss.

Internal Payroll Data And Turnover Metrics

Historical payroll, hiring velocity, offer-acceptance rates, and exit interview themes help normalize market data against internal realities. Using multiple inputs helps find a defensible midpoint.

How To Conduct A Benchmark Analysis Step By Step

A repeatable process keeps benchmarking actionable and defensible.

Gather data from at least three sources: one government/aggregate, one commercial salary platform, and one recruiter/peer input.
Normalize data for location and experience. Convert salaries to equivalent cost-of-living or remote-adjusted values if the company has distributed teams.
Adjust for total compensation. Include expected bonus, commissions, equity, and benefits to compare total rewards, not just base pay.
Build a comparison table with target percentiles (25th, 50th, 75th) for each role and highlight gaps vs. current pay.
Prioritize changes. Use a matrix that weighs business impact, retention risk, and budget feasibility to recommend immediate, near-term, and deferred adjustments.

This framework produces a clear narrative: where pay is behind, how much closing the gap will cost, and which adjustments will most protect revenue and client delivery.

Translating Benchmark Results Into Pay Structures And Budgets

Benchmark results must become predictable pay structures.

Normalize Data For Location, Experience, And Role Level

Apply consistent location multipliers and level definitions (junior, mid, senior, lead) so internal fairness stands up to scrutiny.

Build Pay Bands, Ranges, And Target Percentiles

Create bands with minimums, midpoints, and maximums tied to the chosen target percentiles. Bands help managers make consistent offer decisions and reduce bias.

Model Total Cost Of Hire And Budget Impact

Factor in employer taxes, benefits, onboarding costs, and ramp time. Present scenarios that show both absolute costs and return-on-investment when a higher-paid senior reduces client churn or improves campaign ROI.

Design Salary Bands, Bonus Structures, And Noncash Benefits

Consider sales- or performance-linked bonuses for account managers and revenue-attributed roles. Align Compensation To Performance, Retention, And Career Paths

Tie movements within bands to objective competency milestones (e.g., “strategic link acquisition that improves DR by X points” or “reduced time-to-rank for client cohort”), creating transparent merit progression that drives retention.

Communicating, Implementing, And Ensuring Pay Equity

Change management is as important as the numbers.

Gain Leadership Buy-In And Set Change Management Steps

Present benchmarking findings with clear ROI scenarios and phased implementation options. Leadership will respond to cost/benefit clarity, show how targeted raises stabilize revenue-generating roles.

Communicate Changes To Employees And Handle Pushback

Be transparent about methodology and timelines. Provide managers with scripts explaining why adjustments are happening and how employees can progress to higher bands.

Document Compliance, Pay Equity, And Recordkeeping Practices

Maintain audit-ready records of data sources, decision rationales, and salary matrices. Regularly run pay-equity checks by gender, race, and tenure to avoid legal and moral risks.

Thoughtful communication reduces rumors and ensures raises are seen as strategic investments, not arbitrary rewards.

Ongoing Monitoring: KPIs, Review Cadence, And Market Adjustments

Benchmarking isn’t a one-off. It requires monitoring and simple KPIs.

Track Competitive Positioning, Turnover, And Time To Fill

KPIs should include average comp vs. market percentile, voluntary turnover by role, offer-acceptance rate, and time-to-fill for critical positions. These metrics signal when the market has shifted.

Schedule Regular Reviews And Trigger-Based Market Rechecks

A typical cadence is an annual formal benchmark with quarterly spot checks for priority roles. Trigger-based rechecks, when turnover spikes, when offer-acceptance drops below a threshold, or when the market is disrupted, keep pay competitive between formal cycles.

With a small set of KPIs and a clear review cadence, agencies and online businesses can avoid reactive panic hires and keep compensation aligned with strategy and market reality.

Conclusion

Salary benchmarking equips online businesses and agencies to hire and retain the right talent without sacrificing profitability. When done well, benchmarking clarifies where to invest, makes offers defensible, and reduces turnover among roles that materially affect client outcomes and rankings.

General

BPP Confirms N1.1trn Savings from Procurement Reforms in 2025

Published

2 days ago

20/02/2026

Adedapo Adesanya

By Adedapo Adesanya

The Bureau of Public Procurement(BPP) said the ongoing procurement reforms saved the federal government over N1.1 trillion between January and December 2025.

The Director-General of the bureau, Mr Adebowale Adedokun, revealed this while defending the agency’s 2026 budget before the Senate Committee on Public Procurement in Abuja on Thursday.

The bureau also reported reduced contract approval timelines, additional cost savings, and tougher sanctions imposed on erring contractors and non-compliant government officials.

Mr Adedokun appealed for increased budgetary allocation in 2026 to enhance service delivery, create jobs, and strengthen institutional capacity for procurement oversight.

He further revealed that the bureau received N4.032 billion in 2025 and sought higher funding to reinforce anti-corruption efforts under the administration of President Bola Tinubu.

Earlier, the Chairman of the Senate Committee, Mr Olajide Ipinsagba, a lawmaker from Ondo North, underscored the bureau’s strategic role in driving socioeconomic development and promoting fiscal discipline.

Mr Ipinsagba assured the agency of legislative support while urging strict accountability and prudent utilisation of public funds allocated for its operations.

BPP reforms were committed to deepening transparency, compliance, and efficiency in Nigeria’s public procurement system. Some of them include adherence to a 21-day timeline, as mandated by the Public Procurement Act 2007. Also, the BPP is required to review cases, issue a written decision within 21 working days of receiving the complaints, and state the corrective actions, reasons for rejection, or remedies granted.

There are also plans to streamline approval processes, standardise documentation, and automate workflows to ensure timely and transparent procurement decisions.

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FCT Council Elections: Police Impose 12-Hour Curfew

Published

2 days ago

20/02/2026

Adedapo Adesanya

By Adedapo Adesanya

The Federal Capital Territory (FCT) Command of the Nigeria Police Force (NPF) has announced a 12-hour restriction on movement across Abuja and its environs ahead of the council elections scheduled for Saturday, February 21, 2026.

In a statement, the Police Public Relations Officer of the FCT Command, Mrs Josephine Adeh, said the movement will be restricted to ensure security and the smooth conduct of the polls.

“The Commissioner of Police, FCT Command, Miller G. Dantawaye, psc., has announced a restriction of movement across the Federal Capital Territory from 6:00 AM to 6:00 PM on Saturday, 21st February, 2026, in view of the scheduled Area Council Elections,” the statement read.

The police clarified that the restriction will apply to all residents, except essential service providers and duly accredited election officials.

The command also called on residents to remain peaceful and cooperate with security agencies.

“The FCT Police Command urges residents to remain peaceful, law-abiding, and cooperate with security agencies to ensure a safe, free, and credible electoral process,” the statement added.

Meanwhile, the FCT Minister, Mr Nyesom Wike, declared Friday a work-free day ahead of the council elections.

In a broadcast, Mr Wike said the decision, approved by President Bola Tinubu, is to enable residents to travel to their communities to vote.

In contrast to the police announcement, the minister declared a separate restriction of movement across the FCT from 8:00 p.m. on Friday to 6:00 p.m. on Saturday, directing security agencies to ensure compliance.

Mr Wike urged residents to turn out in large numbers and conduct themselves peacefully, expressing optimism that the polls would produce leaders who would promote development and stability in the territory.

In the meantime, the Independent National Electoral Commission (INEC) says preparations for the elections are at an advanced stage, with strong voter participation recorded during the PVC collection exercise.

INEC disclosed that 1,587,025 Permanent Voter Cards (PVCs) have been collected across the FCT, representing a 94.4 per cent collection rate out of the 1,680,315 registered voters.

Security agencies have assured residents of adequate deployment across the territory to maintain order, as authorities emphasise the need for a peaceful, free, and credible electoral process.