Dragnet Solutions Limited
Dragnet Solutions Limited (‘Dragnet’, ‘we’, ‘us’, or ‘our’) is a recruitment services company incorporated in Nigeria. We are the Data Controller for all personal data processed through the e-recruiter platform.
e-recruiter is an internal recruitment management platform used by Dragnet’s recruitment and HR teams to manage vacancy listings, receive candidate applications, process CVs, conduct AI-assisted candidate screening, and manage candidate workflows. Selectively, clients of Dragnet may also access the platform to review shortlisted candidates.
This Privacy Notice explains what personal data we collect about you when you apply for a position through e-recruiter, why we collect it, how it is used, who we share it with, how long we keep it, and what rights you have under the Nigeria Data Protection Act 2023 (NDPA).
For the purpose of this Policy, personal data refers to any information relating to an identified or identifiable natural person (a data subject), and processing means any operation performed on personal data, including collection, storage, use, sharing, or deletion.
This Policy is effective as of May 2026 and applies to all users of the e-recruiter platform whose personal data is processed through e-recruiter. Please read this Notice carefully before submitting your application. By accessing or using e-recruiter, you acknowledge that you have read, understood, and agreed to this Policy.
When you submit an application through e-recruiter, we collect:
In addition to the data you provide, e-recruiter generates the following derived data about you during the screening process:
e-recruiter is not designed or intended to collect special category personal data, including health information, biometric data, racial or ethnic origin, political opinions, religious beliefs, or criminal records. You should not include such information in your CV or application responses.
Where special category data is inadvertently submitted as part of a CV upload, we are implementing technical controls to detect and reject such content before it is processed. Until those controls are fully operational, please ensure your CV does not contain such information.
Under the Nigeria Data Protection Act 2023, we are required to have a lawful basis for every processing activity involving your personal data. The table below sets out the legal basis for each activity:
| Processing Activity | Lawful Basis (NDPA 2023) |
|---|---|
| Receiving and managing your application | Performance of a contract / pre-contractual steps at your request |
| CV parsing via Azure Document Intelligence (OCR) | Performance of a contract |
| AI-assisted screening and scoring of your application | Consent: you will be asked to confirm this on the application form before submission |
| Communicating with you about your application | Performance of a contract |
| Sharing your profile with Dragnet clients for candidate review | Legitimate interests of the data controller, balanced against your rights |
| Retaining records for regulatory and compliance purposes | Legal obligation |
| Analytics to improve recruitment processes (anonymised data only) | Legitimate interests |
We use your personal data for the following purposes only:
We will not use your personal data for any purpose that is incompatible with the purposes listed above without first notifying you and, where required, obtaining your consent.
e-recruiter uses artificial intelligence to assist with the screening and ranking of candidates. This section explains how that works and what it means for you.
When you submit your application and CV, the text content of your CV is extracted using Microsoft Azure Document Intelligence (an OCR service) and then sent to an AI language model (Qwen2.5, hosted by RunPod Inc. in the EU) for analysis. The model generates a candidate score, a ranking position, and a written assessment based on the content of your application and CV relative to the requirements of the vacancy. These AI outputs are stored in the e-recruiter platform and presented to a Dragnet recruiter as decision-support information.
No fully automated decision is made about your application. Every AI-generated score and assessment is reviewed by a Dragnet recruiter before any decision is taken to progress or reject your application. The AI output is a tool to assist the recruiter, not a substitute for human judgement.
You have the right to object to your application being processed by the AI screening tool. You can exercise this right in two ways:
Choosing to opt out of AI screening does not disadvantage your application. Your application will receive the same consideration as any other.
If you consent to AI-assisted screening on the application form, you may withdraw that consent at any time by emailing compliance@dragnet-solutions.com. Withdrawal of consent does not affect the lawfulness of any processing carried out before withdrawal.
Your application and profile are accessible to authorised members of the Dragnet recruitment and HR teams involved in managing the relevant vacancy. Access is restricted on a need-to-know basis.
Where Dragnet is recruiting on behalf of a client organisation, shortlisted candidate profiles may be shared with that client for the purpose of candidate review and selection. This is done on the basis of Dragnet’s legitimate interest in providing recruitment services to its clients, and in line with applicable data sharing agreements.
The following third-party processors handle your data on our behalf under binding Data Processing Agreements (DPAs):
| Processor | What They Process | Location | Safeguard |
|---|---|---|---|
| Microsoft Azure (VM hosting) | Hosts the e-recruiter platform and stores all candidate data in PostgreSQL on a Dragnet-controlled server | EU region | Microsoft Azure DPA in place |
| Azure Document Intelligence (Microsoft) | Extracts text from your uploaded CV file (OCR processing) | EU region | Microsoft Azure DPA in place |
| RunPod Inc. | Processes extracted CV text and application data for AI screening and ranking inference | EU-RO-1, Romania (EU) | RunPod DPA to be executed before go-live |
No candidate personal data is stored in third-party databases. All data is stored on a Dragnet-controlled Azure VM. RunPod processes data in GPU memory only; data is not persisted on RunPod infrastructure after each inference request completes.
We may disclose your personal data to regulatory or governmental authorities where required by Nigerian law, court order, or legal process.
Dragnet does not sell, rent, or trade your personal data to any third party.
Both third-party processors used by e-recruiter operate within EU regions. Azure Document Intelligence processes in the EU, and RunPod operates from EU-RO-1 (Romania), an EU member state. Both processors are bound by GDPR-aligned Data Processing Agreements.
There are no transfers of your personal data outside the EU/EEA at this stage. In the event that processing arrangements change in the future, Dragnet will ensure to implement appropriate safeguards including encryption, Standard Contractual Clauses (where applicable), and adequacy assessments before any such transfer takes place.
We retain your personal data only for as long as is necessary for the purpose for which it was collected. The retention schedule below applies to all candidate data in e-recruiter:
| Data Status | Retention Period | Action at End of Period |
|---|---|---|
| Active application (vacancy open) | Duration of the vacancy | Retained and actively processed |
| Unsuccessful candidate | 6 months from the date of rejection | Secure deletion from PostgreSQL and file storage |
| Vacancy closed / campaign ended | 12 months from the vacancy close date | Secure deletion of all associated applications |
| Successful candidate (offered and accepted) | Transferred to HR records at point of hire | Deleted from e-recruiter after handover to HR is confirmed |
| CV and uploaded files | Same schedule as the associated application | Deleted with the application record |
At the end of the applicable retention period, your personal data is securely deleted from the PostgreSQL database and file storage. You may also request earlier deletion of your data, see Section 9 on your rights.
Under the Nigeria Data Protection Act 2023, you have the following rights in relation to your personal data held on e-recruiter:
| Right of Access | Request a copy of all personal data we hold about you, including your AI-generated score and assessment. |
| Right to Rectification | Request correction of any inaccurate or incomplete personal data in your application. |
| Right to Erasure | Request deletion of your application and all associated data, subject to any overriding legal obligations. |
| Right to Restrict Processing | Request that we limit how we use your data in certain circumstances. |
| Right to Data Portability | Request a copy of your application data in a structured, machine-readable format (JSON export available). |
| Right to Object | Object to processing based on legitimate interests, or to AI-assisted screening (see Section 5). |
| Right to Withdraw Consent | Withdraw consent for AI screening at any time without affecting prior processing. |
| Right Not to be Subject to Automated Decisions | Request human-only review of your application at any time. AI scores will not be used in any hiring decision where you have exercised this right. |
Dragnet implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or disclosure. Measures in place for e-recruiter include:
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, Dragnet will notify the NDPC within 72 hours and will notify affected individuals without undue delay, in accordance with the NDPA.
The e-recruiter platform uses session cookies that are strictly necessary to maintain your login state during your session. These cookies do not track you across other websites and are deleted when you close your browser or log out.
No third-party advertising or analytics cookies are used on the e-recruiter platform.
e-recruiter is intended for use by individuals who are legally permitted to seek employment in their jurisdiction. We do not knowingly process personal data from individuals under the age of 18. If you are under 18, you must obtain written consent from your parent or legal guardian before submitting an application. Applications submitted by or on behalf of minors without such consent will be removed.
If you have any questions, concerns, or requests regarding this Privacy Policy or how your personal data is handled on e-recruiter, or if you wish to exercise any of your data protection rights, please contact our Data Protection Officer (DPO) at: compliance@dragnet-solutions.com
We will acknowledge all requests within 72 hours and resolve them within 30 days. There is no fee for exercising your rights.
If you are not satisfied with how we have handled your personal data or with our response to a rights request, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC):
| Regulator | Nigeria Data Protection Commission (NDPC) |
| Website | www.ndpc.gov.ng |
| info@ndpc.gov.ng |
We would appreciate the opportunity to resolve your concern before you approach the NDPC. Please contact our DPO in the first instance.
Dragnet may update this Privacy Notice from time to time to reflect changes in our processing activities, legal requirements, or platform features. Where changes are material, we will notify affected individuals via the platform or by email before the changes take effect.
The current version, along with its effective date and revision number, will always be published on the e-recruiter platform. We encourage you to review this Policy periodically. Continued use of e-recruiter following the publication of a revised Policy constitutes acceptance of the updated terms.
By submitting an application through e-recruiter, you confirm that you have read and understood this Privacy Policy and give your consent to the collection and processing of your personal data in accordance with this Policy.
© 2026 Dragnet Solutions Limited. All rights reserved.