As Presented by the President, Nigeria Computer Society (NCS) “Safeguarding Digital Sovereignty in the Age of Global Cooperation: Nigeria’s Data Privacy Imperatives in the Context of the FIRS–France MoU”
Executive Summary
On 10 December 2025, the Federal Inland Revenue Service (FIRS) signed a Memorandum of Understanding (MoU) with France’s tax authority, the Direction Générale des Finances Publiques (DGFiP), to strengthen digital tax administration, technical cooperation, and institutional capacity. This development has sparked wide national discourse on data privacy, digital sovereignty, national security, and the role of international partnerships in Nigeria’s digital economy.
As the Nigeria Computer Society (NCS), representing the technical, professional, and ethical standards of the Nigerian ICT community, we underscore the urgency of aligning such international agreements with national data protection principles, digital sovereignty rights, and global best practices in data governance.
1.Context and Background
The FIRS–France MoU aims to promote efficient tax administration, digital transformation, and sharing of institutional knowledge between Nigeria and France. The collaboration was framed by FIRS as focusing on technical assistance, capacity building, and advisory support, without granting France access to Nigerian taxpayer data, systems, or infrastructure. However, several stakeholders — including political parties, civil society groups, and regional forums — have expressed serious concerns that such arrangements may undermine Nigeria’s economic sovereignty, risk foreign access to critical data, and position Nigeria in a vulnerable digital dependence posture.
2.Nigeria’s Data Privacy and Legal Framework
Nigeria’s digital data governance stems from multiple legal instruments, including:
-Nigeria Data Protection Regulation (NDPR) 2019, and
-Nigeria Data Protection Act (NDPA) 2023, which set out principles for lawful collection, processing, transfer, and protection of personal and sensitive data.
These frameworks protect individual and organisational data, mandate data minimisation, consent, purpose limitation, and require robust security safeguards for cross-border data flows.
However, gaps remain concerning data sovereignty — particularly regarding data generated by public institutions, government operational data, and international sharing or processing of such data beyond national jurisdiction.
3.Digital Sovereignty and Imperatives
Digital sovereignty refers to a nation’s rights and ability to:
-Control and govern its data and digital infrastructure,
-Protect its citizens’ data from unauthorised foreign access,
-Set and enforce national policies on data localisation, cross-border transfers, and digital operational standards.
Therefore, true digital sovereignty ensures that external collaborations do not result in de facto foreign control, leverage, or influence over strategically important systems and datasets.
4.Key Concerns with the FIRS-France MoU
4.1 Transparency and Public Trust
The MoU was concluded without proactive public disclosure of its full contents or detailed terms. This lack of transparency has heightened public suspicion and eroded trust in the government’s handling of data-sensitive agreements.
4.2 Potential for Data Exposure
Even though FIRS insists no foreign access to taxpayer data or operational systems is granted, concerns persist that advisory and technical collaboration could pave the way for indirect access, metadata exposure, or future expansions not subject to rigorous safeguards.
4.3 National Security and Economic Sovereignty
Opposition voices — including the Northern Elders Forum and political parties — have warned that the agreement might compromise Nigeria’s economic sovereignty, hinting at risks of digital or economic influence disguised as cooperation.
4.4 Local Ecosystem and Capacity Development
While the MoU emphasizes cooperation, there are concerns that it may marginalise local tech providers and weaken incentives to develop homegrown digital solutions. Though FIRS states continued collaboration with Nigerian firms, ongoing vigilance is essential.
5.Principles for Nigeria’s Data Privacy and Digital Sovereignty
As the NCS, we uphold the following principles:
1.National Ownership of Data: Public data, especially that pertaining to citizens and government operations, must remain under Nigerian juridical control.
2.Transparency and Public Accountability: All MoUs involving data-related cooperation must be fully disclosed, debated, and subject to public consultation.
3.Compliance with Nigerian Law and Sovereign Rights: Agreements must adhere strictly to the NDPA and relevant national security policies, with explicit safeguards against foreign jurisdictional claims.
4.Data Localization and Protection: Critical tax and economic data should be stored and processed under Nigerian jurisdiction, with limited cross-border transfer only upon strict conditions and adequate legal safeguards.
5.Mutual, Equitable Partnerships: International cooperation must be mutually beneficial, bolster local capacity, and avoid asymmetries that favour foreign technical control.
6.Practical Recommendations
6.1 Establish a National Data Sovereignty Policy
The government should prioritise a comprehensive national data sovereignty framework that:
-Clarifies conditions for cross-border data sharing,
-Regulates foreign entities’ access to public sector data,
-Sets protocols for data audit trails, encryption standards, and sovereignty preservers.
6.2 Parliamentary and Public Oversight
Before ratification or operationalisation, legislative review and public hearings should be held for any MoU that potentially impacts data privacy or national digital infrastructure. This should involve the National Assembly, relevant ministries, and technical experts.
6.3 Strengthen Local Capacity
Invest in building local expertise in digital tax infrastructure, including:
-Funding indigenous software and platform development,
-Incentivising partnerships between government and Nigerian tech companies,
-Providing training and capacity-building programmes for civil servants.
6.4 Data Protection Impact Assessments (DPIAs)
Mandate DPIAs for every international data collaboration to:
-Evaluate privacy risks,
-Document mitigation plans,
-Ensure compliance with NDPA and international best practices.
6.5 Secure Governance Mechanisms
Establish governance bodies — such as a National Data Protection Commission with sovereignty oversight mandates — to monitor compliance, enforce violations, and adjudicate disputes involving foreign partners.
6.6 Strategic Public Communication
Proactive engagement with citizens on data privacy and digital sovereignty, including explainers, impact assessments, and official clarifications, will build trust and reduce misinformation.
7.Conclusion
Nigeria stands at a pivotal point in its digital and economic transformation. International cooperation — such as the FIRS–France MoU — can enhance institutional capacity and global integration, but must never compromise data privacy, national sovereignty, or the rights of Nigerian citizens. The Society calls for transparent processes, strong legal foundations, robust data governance, and sovereignty-anchored policies to ensure that Nigeria’s digital future is secure, equitable, and domestically controlled.
The Nigeria Computer Society affirms that it is closely monitoring developments related to this and similar agreements and remains committed to providing independent, professional, and non-partisan technical advice in the national interest. The Society stands ready to collaborate with government institutions to further strengthen Nigeria’s digital sovereignty, cybersecurity posture, and digital economy outcomes.
Read Also: Andrew Agbo Abu Elected Chairman of Nigeria Computer Society (NCS) FCT Chapter
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