Document text
[YOUR FULL NAME]
[YOUR ADDRESS]
Phone number used on the app: [PHONE NUMBER]
E-mail: [E-MAIL]
Date: [DD/MM/YYYY]
To:
The Complaints Desk / Customer Service Manager
[NAME OF LENDING COMPANY] (trading as [NAME OF THE LOAN APP])
[COMPANY ADDRESS, IF KNOWN]
E-mail: [COMPLAINTS E-MAIL SHOWN IN THE APP OR ON ITS WEBSITE]
Attention: The Data Protection Officer — [DPO E-MAIL, IF SHOWN IN THE PRIVACY POLICY]
Copy to: Federal Competition and Consumer Protection Commission (FCCPC) — lenderstaskforce@fccpc.gov.ng [DELETE IF YOU WILL ONLY ESCALATE LATER]
Sent by: [E-MAIL / IN-APP COMPLAINT CHANNEL / COURIER]
Subject: Formal complaint and Notice to Address Grievance — harassment and unlawful use of my personal data and my contacts' data — Loan ID [LOAN ID]
Dear Sir/Madam,
1. I am a customer of [NAME OF THE LOAN APP]. I took a loan of ₦[AMOUNT] on [DD/MM/YYYY], Loan ID [LOAN ID], repayable on [DD/MM/YYYY]. [CHOOSE ONE: The loan has been fully repaid on [DD/MM/YYYY]. / The outstanding amount according to your app is ₦[AMOUNT], which I [ACCEPT / DISPUTE because ___]. / I am in arrears and I am ready to agree a repayment plan.]
2. Since [DD/MM/YYYY], persons acting for your company have contacted people in my phone contacts and/or sent messages about me, as set out below:
No. Date and time Number or account used by your agent Person contacted (relationship to me) What was said or sent
1 [DD/MM/YYYY HH:MM] [PHONE NUMBER / WHATSAPP / SMS SENDER ID] [NAME — e.g., my employer, my mother] [SHORT DESCRIPTION — e.g., called me a thief and a fraudster]
2 [DD/MM/YYYY HH:MM] [PHONE NUMBER] [NAME] [SHORT DESCRIPTION]
3 [DD/MM/YYYY HH:MM] [PHONE NUMBER] [NAME] [SHORT DESCRIPTION]
[OPTIONAL: Your agents have also called me [NUMBER] times on [DD/MM/YYYY], used abusive language and threatened to [DESCRIBE THREAT].]
3. My contacts are not parties to my loan and did not consent to you processing their phone numbers. Using my contact list to shame me and to pressure people around me is not a fair or lawful way to recover a debt. It is contrary to:
a. the Digital, Electronic, Online, or Non-Traditional Consumer Lending Regulations, 2025, which require you to treat consumers fairly (regulation 18), to conduct your business in a responsible, professional and ethical manner (regulation 19(a)) and to comply with the Nigeria Data Protection Act, 2023 (regulation 21(a)); and to your declaration to the FCCPC that your apps will not access customers' call logs, contacts and photos/gallery and that your recovery practices comply with the law (Schedule 1, Form 001 and Schedule 2, Form 002 to the Regulations); and
b. the Nigeria Data Protection Act, 2023, including my rights under sections 34, 35 and 36.
4. Under the Nigeria Data Protection Act, 2023, I hereby:
a. withdraw my consent to any access to, or processing of, my phone contacts, call logs, photos/gallery and any other data on my phone not strictly needed for my loan (section 35);
b. object to any further processing of my personal data and my contacts' data for debt recovery through third parties (section 36);
c. request confirmation of what personal data you hold about me and my contacts, the purposes, and every person or company (including recovery agents) you have shared it with (section 34(1)(a));
d. request the erasure of my contact list, call logs and photos, and of any of my contacts' data you hold, and that you ensure the erasure of the same data by every recovery agent or other third party you shared it with (section 34(1)(d) and (2) of the Act; Article 38(3) of the NDP Act General Application and Implementation Directive, 2025).
5. I request that you, within the time required:
a. immediately stop contacting any person other than me about my loan;
b. stop sending messages that describe me as a thief, fraudster or criminal, and send a correction to each person listed in paragraph 2 [OPTIONAL];
c. give me a statement or history of my use of your services — the amount borrowed, every charge and interest applied, and all payments made (regulation 21(b) — within 24 hours of this demand);
d. resolve this complaint within 48 hours of receipt, as required by regulation 22(d) of the Regulations and paragraph 43 of the FCCPC's DEON Consumer Lending Guidelines, 2025, and give me a complaint reference number; if you need more time, tell me in writing why — the complaint must still be resolved within 14 days of receipt (paragraph 44 of the Guidelines);
e. communicate your decision on the data requests in paragraph 4 within 30 days, as provided in the Data Subject's Standard Notice to Address Grievance (Schedule 9 to the NDP Act General Application and Implementation Directive, 2025).
6. Nothing in this letter is a refusal to pay any amount that is lawfully due. [OPTIONAL: I propose to pay the balance of ₦[AMOUNT] as follows: ___.] Please communicate with me only, by [E-MAIL / SMS / PHONE] at the contacts above, between [TIME] and [TIME].
7. If you do not resolve this complaint within the time above, I will escalate it to the Federal Competition and Consumer Protection Commission (lenderstaskforce@fccpc.gov.ng / complaints.fccpc.gov.ng) and lodge a complaint with the Nigeria Data Protection Commission, without further notice to you.
Yours faithfully,
______________________________
[YOUR FULL NAME]
Enclosures:
1. Screenshots of the messages sent to me and to my contacts (with dates and numbers)
2. Call log screenshots showing the numbers and times
3. Statements from contacts who were called or messaged [IF AVAILABLE]
4. Proof of loan and repayments (app screenshots / bank statement)
NOTES BEFORE SENDING — delete this part
Send the letter through the complaint channel shown in the app or on the lender's website, and by e-mail if available. Keep the date and time you sent it — your deadlines run from there.
Check the lender on the FCCPC list of approved digital lenders (fccpc.gov.ng → Registration of Digital Money Lenders). If the app is not on the list, say so in paragraph 7 and report it to the FCCPC at once.
The DEON Regulations do not cover loans from banks and microfinance banks licensed under the Banks and Other Financial Institutions Act. If your loan app belongs to a bank or microfinance bank, send this complaint to the bank and escalate to the Central Bank of Nigeria (cpd@cbn.gov.ng) instead of the FCCPC; keep paragraph 4 (data protection applies to everyone).
Collect evidence before you block numbers: screenshots with the date, time and sender visible.
Write only what really happened, and do not threaten anyone in return. If you owe money, say so — a fair offer to pay makes your complaint stronger.
If anyone threatens violence, report it to the police as well.
Field labels in [SQUARE BRACKETS, CAPITALS] must be completed or deleted. Alternatives are separated by a slash. © Layers (layers.md), licensed under CC BY 4.0 (https://creativecommons.org/licenses/by/4.0/). Template, not legal advice.
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