Draft for legal review. This notice describes what the platform actually does today. It has not yet been reviewed by a lawyer. Items in [square brackets] are decisions JO must make. Do not rely on it as final until it has been checked by a qualified Nigerian data-protection lawyer.
1. Who we are
JO Education Consultant (“JO”, “we”, “us”) decides why and how your personal data is used, so we are the data controller. Address: Orohgold Shopping Complex, DSC, Warri, Delta State, Nigeria. Email: enquires@joeducationconsultant.com.ng. Phone and WhatsApp: +234 706 418 2042. [Name a person responsible for data protection, and register with the Nigeria Data Protection Commission if JO is required to.]
2. What we collect
If you contact us through the website
Your name, email address, phone or WhatsApp number, preferred destination, the service you are interested in, your study level, any occupation or course you mention, and your message.
If you take the migration assessment
- Destinations and occupation field you choose, and your job title.
- Date of birth, country of residence, nationality, marital status and, where relevant, whether your partner has a skills assessment or English evidence.
- Qualifications: level, field, institution, country, graduation year, certifications.
- Work experience: job title, employment type, country, start date, years of experience (total and inside each destination), duties, apprenticeship and trade details where relevant.
- English test type, component and overall scores and test date.
- Existing skills assessments, registrations, education credential assessments, job offers, employer sponsorship and nominations.
- The report we generate from your answers, and the version of the rules used.
If you create an account
Your name, email, optional phone number, a password (stored only as a one-way hash), your assessments, documents you upload, consultation requests, notifications we send you, and records of your consent choices (what you agreed to, which version of this notice, when, and your IP address and browser details at that time).
Documents you upload
When we ask, or when you choose, you may upload identity documents, transcripts, employment evidence, English test results and similar files (PDF, JPG or PNG). These can be highly sensitive. Please upload only what is asked for.
Security and technical records
Sign-in events, uploads and downloads, staff access to your assessment and documents, and the IP address attached to those events. We keep these to protect your account and to show who accessed what.
3. Why we use it, and our legal basis
| Purpose | Basis (Nigeria Data Protection Act 2023) |
|---|---|
| Produce your preliminary assessment and report | Your consent, and steps you ask us to take |
| Staff review, follow-up questions, document requests, consultations | Your consent, and steps you ask us to take |
| Run your account, send service emails (verification, password reset, requests, updates) | Steps you ask us to take; our legitimate interest in running the service |
| Answer website enquiries | Your consent; our legitimate interest in responding |
| Keep the service secure, detect misuse, keep an audit trail | Our legitimate interest; legal obligations |
| Occasional updates about migration changes | Your consent only (optional, withdraw any time) |
| Meet legal and regulatory duties | Legal obligation |
[Lawyer to confirm the basis for each purpose.]
4. How the assessment works (automated processing)
Your answers are compared with rules that JO staff enter from official government sources and approve. The result is a preliminary indication, not an eligibility decision. It has no legal effect on you, only governments decide visas, and a JO staff member can review it. Where a rule has not been verified, the report says “manual review” instead of guessing. You can ask for a person to review your assessment at any time.
5. Who sees your data
- JO staff who need it to review and support you. Staff access is logged.
- Service providers that run the platform: our web hosting provider (Hostinger) and email delivery for the messages we send. [Confirm and list all processors, and that each is bound by a data-processing agreement.]
- Government bodies, assessing authorities or education providers only when you ask us to act for you, and only the information needed.
- Authorities where the law requires it.
We do not sell your data and we do not use it for advertising. The website loads its fonts and images from our own servers, so your visit is not shared with font or image companies. If you tap a WhatsApp link, WhatsApp handles that conversation under its own terms.
6. Where it is stored, and transfers abroad
Data is stored on our hosting provider’s servers [confirm the country and region]. If those servers are outside Nigeria, data is transferred there under safeguards that give it adequate protection, as the Act requires. [Lawyer to confirm the transfer wording.]
7. Cookies
We use only the cookies the service needs to work. We do not use analytics, advertising or tracking cookies.
| Cookie | Purpose | Lasts |
|---|---|---|
| Session cookie | Keeps you signed in and protects forms | Until you close the browser or sign out (idle limit 2 hours) |
| XSRF-TOKEN | Protects forms from forgery | Session |
| jo_guest | Lets you resume and read your own assessment before you create an account. It is a random code; only a one-way hash is kept on our side | 30 days |
| Remember-me cookie | Only if you tick “Keep me signed in” | About 13 months (400 days) |
8. How long we keep it
- Assessments you start but never submit, and never attach to an account: deleted automatically after 30 days.
- Submitted assessments, reports, documents and account data: kept until you ask us to delete them. [JO to decide a fixed maximum, for example 24 months after your last activity, and apply it.]
- Backups: rolling, kept for about 14 days, so deleted data disappears from backups within about two weeks.
- When you ask for deletion we erase your account, assessments and answers, reports, notes, uploaded files, consultations, notifications and consent records, except what we must keep by law. Security logs that remain contain no personal details of yours once your account is erased.
9. Your rights
Under the Nigeria Data Protection Act 2023, and similar laws elsewhere, you may:
- ask what we hold about you and get a copy;
- correct information that is wrong (you can edit your details in your applicant space);
- ask us to erase your data (use “Delete my account” in your applicant space or email us);
- restrict or object to some uses, including marketing, and withdraw your consent at any time (the consent panel in your applicant space records each change);
- ask for your data in a portable format;
- ask for human review of your assessment;
- complain to the Nigeria Data Protection Commission, or the data-protection authority where you live.
We will reply within [30] days. We may need to confirm who you are first.
10. Security
We protect your data with encrypted connections (HTTPS), hashed passwords, private file storage that is not reachable from the public website, access limited to staff, an audit trail of staff access and downloads, and automatic rate limits against guessing and abuse. No system is perfectly secure. If a breach is likely to harm you we will tell you and the regulator as the law requires.
11. Children
The service is for people aged 18 or over. We do not knowingly collect data from children.
12. Changes
If we change this notice in a way that matters, we will update the version number above and ask for your consent again where the law requires it. Each consent you give is saved against the version you saw.
13. Contact
Questions, requests or complaints: enquires@joeducationconsultant.com.ng, or write to JO Education Consultant, Orohgold Shopping Complex, DSC, Warri, Delta State, Nigeria.