Nigeria Data Protection Act 2023

Privacy notice

This explains what we collect about you, why, who can see it, and how to make us stop. It describes what the system actually does, not what we intend it to do.

Version 1.0. Applies to Unity Campus Services delivered through the DoktorConnect platform. Unity is a private scheme that complements TISHIP, the government student health insurance programme; it is not operated by government.

1. Who is responsible

Josmol Human Capital Resources Ltd, trading as DoktorConnect, of ADOL House (beside GTB), Plot 15 CIPM Road, Alausa, Ikeja, Lagos, is the data controller for your health record.

Your institution is the data controller for the roster it gives us — your name, matriculation number, department and level — because that is its record of you as a student. We process that roster on its instructions in order to know who is covered.

Data protection contact: hello@doktorconnect.com · +234 704 770 0006.

2. What we collect

What	Where it comes from
Name, matriculation number, department, level	Your institution's roster
Email and password	You, when you activate
Phone number, blood group, genotype, allergies, long-term conditions	You, if you choose to add them
Blood pressure, glucose, BMI and other measurements	Your campus health centre, at a wellness check
Symptoms, duration and severity	You, when you use the symptom checker
Mood screening answers and score (PHQ-9)	You, if you take the screen
Barrier assessment answers and profile (MQ)	You, if you take the assessment
Consultation and referral records	Created when you request care
Location	Your device — only while a journey, a share or an emergency alert is active

3. Why, and on what legal basis

To provide the service you were enrolled in — contractual necessity. Your school has purchased cover for you, and we cannot deliver it without knowing who you are.
To provide clinical care — your consent, and the provision of health care under the Act. You give it by using the symptom checker, requesting a consultation, or completing an assessment. Every one of those is something you choose to start.
To send you notices — public health and campus safety information. You can opt out of text messages at any time by replying STOP; genuine emergency instructions are the one exception.
To report anonymised statistics to your institution and to health authorities — legitimate interest in public health. These are counts only, described in section 5.
To pass an application to a partner service — your explicit consent, given separately for each service, each time.

4. Who can see your health information

Your institution cannot see your symptoms, your consultations, your mood screening or your barrier profile. Neither can your health centre's administration, your HMO, or anyone at DoktorConnect. This is enforced by the database's own access rules, which refuse those reads. It is not a policy we could quietly change without changing the system.

Who	What they can see
You	Everything in your record
The clinician taking your case	What you wrote in that request, and the clinical basics you chose to record
Your campus health centre	That you are covered, the clinical basics you recorded, and a referral you addressed to them. Not your symptom history, not your mood screen, not your barrier profile
Your institution	How many students enrolled and how many were screened. Never who, never what
Your HMO	Only a referral a clinician escalated to them, with the reason. Not your name
DoktorConnect staff	Counts and anonymised aggregates. No staff account can read an individual's symptoms, mood screen or barrier profile

Statistics published to your institution are computed by a server process and any group smaller than ten students is withheld entirely rather than rounded, because a percentage from a group of six identifies people.

5. Location

We do not keep a record of where you have been. Your position is used only while a journey check-in, a location share or an emergency alert is active. It is written into that one record, overwritten as it changes, and deleted when the journey ends, the share expires or the alert is closed. There is no history, and no one — including us — can ask the system where you were last week.

The people you choose are sent your position by text message. They do not get an account that can look you up.
Campus security can see a live emergency alert at your own institution, and only while it is open.
Location sharing is always time-limited. There is no permanent option.
Turning location off in your phone's settings stops all of it. The service works without it.

Raising an alert notifies the contacts you chose. It does not call the police, and nobody at DoktorConnect monitors alerts.

6. Who else we share with

Clinicians in our network, to provide the consultation you asked for.
Cornerstone Insurance Plc, if you make an insurance claim — the information needed to assess that claim, and nothing else.
Partner services (credit, payments, training), only if you apply, only the fields listed on that application, and never any health information. Applying for money cannot affect your care, and nothing in your health record can affect what you are offered.
Technology providers who process data on our written instructions: Google Firebase (hosting and database), Africa's Talking (text messages), and Meta (WhatsApp messages).
Public health authorities, where an outbreak signal requires it — as counts and patterns, never as a list of students.

We do not sell your data, and we do not allow advertisers to target you using it.

7. Where your data is held

Data is stored on Google Cloud infrastructure and may be processed outside Nigeria. Transfers are made under the safeguards required by sections 41 and 43 of the Act. We will inform your institution and the Nigeria Data Protection Commission of any transfer arrangement that materially changes.

8. How long we keep it

What	Kept for
Your health record and passport	While you are a member, and afterwards under the medical records retention period, so the record remains available to you
Consultations and referrals	As clinical records, under the same retention period
Journey check-ins	Deleted within 7 days of closing
Location shares	Deleted when they expire
Emergency alerts	Deleted after 30 days
Roster entries	While your institution's contract runs

9. Your rights

Under the Nigeria Data Protection Act 2023 you may ask us to:

Give you a copy of what we hold about you
Correct anything that is wrong
Delete your record, subject to clinical retention requirements
Stop a particular use, including any messaging
Give you your data in a portable form, or send it to another provider
Withdraw a consent you gave, at any time, without affecting your cover

Write to hello@doktorconnect.com. We answer within 30 days. If you are not satisfied you may complain to the Nigeria Data Protection Commission.

Withdrawing consent does not remove your cover. Your school paid for it and it remains yours.

10. Security and breaches

Data is encrypted in transit and at rest, and access is restricted by role in the database itself rather than only in the software. If a breach occurs affecting your data we will notify your institution and the Commission within 72 hours, as section 43 requires, and tell you where the risk to you is significant.

11. Changes

If we change what we collect or who can see it, we will publish an updated notice here and tell you in the app before the change takes effect.