Data Privacy & Spatial Telemetry Sovereignty Charter
1. Legal Architecture: Data Controller vs. Data Processor
Bastion Technologies Infrastructure Ltd ("Bastion", "we", "us", or "our") provides defense-grade mission-critical situational command, telemetry fusion, and Parallel Vote Tabulation (PVT) infrastructure to accredited political parties, democratic campaigns, sovereign candidates, and certified election monitoring missions.
Data Controller Status: Under Section 24 of the Nigeria Data Protection Act (NDPA) 2023, the subscribing Political Party, Campaign Directorate, or Candidate Organization is the sole Data Controller. The Campaign Controller determines the purpose, scope, and legitimate basis for deploying field operatives, observers, and personnel.
Data Processor Status: Bastion acts strictly and exclusively as a Data Processor executing technical processing under the explicit, documented instructions of the Campaign Controller.
The Campaign Controller warrants that all personnel onboarded onto the Bastion platform (including Lions, Bisons, Hawks, Tortoises, Spiders, Beavers, and Eagles) have executed authorized deployment agreements consenting to physical location verification and duty-bound telemetry collection during election monitoring operations.
2. Spatial Telemetry & Baseband Cellular Diagnostics
Bastion utilizes a proprietary dual-vector geospatial tracking engine combining Satellite GNSS/GPS and Cellular Base Station (BTS) Location-Based Services (LBS). We process the following categories of telemetry:
- High-Precision Satellite GNSS: Real-time latitude, longitude, elevation, velocity, bearing, and horizontal accuracy dilution when the device possesses unobstructed satellite line-of-sight.
- Cellular Base Transceiver Station (BTS) Metadata: Mobile Country Code (MCC: 621), Mobile Network Code (MNC), Location Area Code (LAC), Cell Tower Identifier (CID), and Received Signal Strength Indication (RSSI / RSRP in -dBm).
- Handset Diagnostic State: Battery percentage remaining, power connection status, operating system release, hardware device fingerprint, and mock-location detection flags.
Strict Telecommunication Non-Interception Affirmation
Bastion expressly affirms that it does not intercept, monitor, record, or tap telecommunications content, private phone calls, SMS conversations, or instant messaging payloads of any individual. All cellular network metadata (Cell Tower ID and signal strength) is non-invasive radio telemetry reported directly by the user's mobile device via standard telecommunication APIs under lawful operational consent, in strict adherence to the Cybercrimes (Prohibition, Prevention, etc.) Act 2015 and NCC Regulations.
3. Operational Purpose & Temporal Geofence Windows
Spatial telemetry and agent location data are processed strictly for the following four statutory and operational objectives:
Enabling rapid vectoring of Quick Reaction Forces (Falcon QRF / MOPOL / NSCDC) when an operative triggers an emergency distress beacon (SOS) under physical assault or abduction threat.
Confirming physical presence inside the 50-meter Polling Unit boundary to satisfy the evidentiary threshold required by Section 84 of the Nigerian Evidence Act 2011.
Detecting route deviations greater than 500 meters during the transit of Form EC8A result sheets and ballot boxes from polling centers to Ward Collation Centers.
Detecting location-spoofing attacks (Fake GPS apps) to prevent fraudulent result fabrication by compromised agents away from their assigned posts.
Strict Temporal Boundary: Telemetry collection automatically activates at the start of operational deployment (05:00 on election morning) and ceases immediately upon the verified completion of official collation handover. Outside operational deployment windows, passive background tracking is completely disabled.
4. Evidence Act 2011 §84 Compliance & Hash Sealing
To guarantee admissibility before the Presidential, Governorship, and National/State Assembly Election Petitions Tribunals under Section 84 of the Evidence Act 2011:
- Every telemetry packet, Form EC8A photographic upload, voter count submission, and command directive is stamped with an immutable, cryptographically generated SHA-256 digital fingerprint:Hash = SHA256(Tenant_ID ∥ User_ID ∥ Latitude ∥ Longitude ∥ Cell_BTS_ID ∥ Timestamp_UTC ∥ Device_Fingerprint)
- Audit logs are written to append-only storage volumes with write-once-read-many (WORM) semantics. No administrative override or developer access can modify historical timestamped evidence.
- Upon conclusion of election activities, the Campaign Legal Officer (Tortoise) can export a certified Certificate of Electronic Compliance admissible in judicial tribunals.
5. Zero-Knowledge Multi-Tenant Data Isolation
Bastion operates under an air-gapped tenant architecture:
- Cryptographic Tenant Separation: Every campaign command is assigned an isolated cryptographic tenant workspace. Data generated by Campaign A is mathematically segregated from Campaign B and cannot be accessed across tenant boundaries.
- Non-Commercialization Warranty: Bastion warrants that it will never sell, lease, rent, monetize, or utilize campaign intelligence, polling figures, or voter registries for commercial advertising, public opinion profiling, or third-party behavioral targeting.
- State Surveillance Shield: Data stored on Bastion servers will not be disclosed to law enforcement or government entities absent a valid, unappealable order issued by a court of competent jurisdiction in Nigeria.
6. Statutory Retention Window & Cryptographic Purge
In strict compliance with Section 285(6) of the Constitution of the Federal Republic of Nigeria 1999 (as amended), which mandates that election petitions must be heard and determined within 180 days:
Primary Custody Period (180 Days): All raw telemetry, incident submissions, and Form EC8A photographs are locked in immutable cold archive for 180 days post-election to provide unalterable evidentiary defense for active tribunal petitions.
Automated Cryptographic Zeroization: Following the expiration of 180 days (or upon final judgment of the Supreme Court of Nigeria), the Command's authorized Lion (Principal) may initiate an irreversible cryptographic erasure under DoD 5220.22-M standards, overwriting and destroying all tenant cryptographic keys.
7. Data Subject Rights & Compliance Contact
Pursuant to Part V of the Nigeria Data Protection Act 2023, data subjects maintain rights of access, rectification, objection, and complaints regarding their personal data: