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SERAP asks President Bola Tinubu to direct the Nigeria Data Protection Commission (NDPC) to conduct an independent investigation into suspected AI-generated photographs and questionable records in INEC’s preliminary Register of Voters.
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The organisation wants a forensic examination of INEC’s voter database to establish the extent of the irregularities, identify those responsible and determine whether registration officers abused their official access credentials.
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SERAP raises concerns over possible violations of the Nigeria Data Protection Act 2023 and the constitutional rights of Nigerians to privacy and political participation ahead of the 2027 general elections.
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The organisation gives the Federal Government seven days to act, threatening legal action against the government, NDPC, INEC and other relevant authorities if its demands are ignored.
November 1, (THEWILL) – The Socio-Economic Rights and Accountability Project (SERAP) has urged President Bola Tinubu “to direct Dr Vincent Olatunji, National Commissioner/Chief Executive Officer of the Nigeria Data Protection Commission (NDPC) to promptly, thoroughly, independently and effectively investigate the reported introduction of suspected artificial intelligence (AI)-generated photographs, alleged alterations to personal data and other questionable records in the preliminary Register of Voters published by the Independent National Electoral Commission (INEC).”
The organisation also wants the investigation to establish the extent of the alleged irregularities, determine whether Nigerians’ personal information was unlawfully accessed or altered, identify those responsible and ensure that affected voters can verify and correct their records without being unfairly excluded from the electoral process.
SERAP made the demands in a letter dated October 31, 2026, and signed by its Deputy Director, Kolawole Oluwadare, following INEC’s acknowledgement of suspected AI-generated photographs and questionable registration records identified during the nationwide display of the preliminary Register of Voters from October 9 to 15, 2026.
In the letter, SERAP said the reported irregularities raised serious concerns about the security and integrity of Nigerians’ personal data and the reliability of the voters’ register ahead of the 2027 general elections.
“The security and accuracy of the voter register are fundamental to the protection of Nigerians’ personal data and their right to participate in public affairs. Nigerians should not have to worry that their personal information could be altered, manipulated or accessed without proper safeguards”, it said.
The organisation said INEC’s acknowledgement of questionable records and suspected AI-generated photographs made an independent investigation particularly important.
“The public needs to know what happened, whether the law was breached and what measures are being taken to prevent a recurrence”, SERAP said.
It urged the NDPC to exercise its statutory powers independently and without delay, stressing that the investigation must establish the facts, protect affected voters and ensure that anyone found responsible for unlawful conduct is held accountable.
SERAP requested that the Federal Government ensure the implementation of its demands within seven days of receiving or the publication of the letter.
It warned that failure to receive a response within the stipulated period would prompt it to consider legal action and other lawful measures to compel the Federal Government, NDPC, INEC and other relevant authorities to act in the public interest.
Demands Forensic Investigation Of Voter Database
SERAP said the proposed investigation should establish the nature and extent of the reported irregularities, including the number and geographical distribution of affected records, when and how they were created or altered, and the individuals or institutions responsible.
It expressed concern that the introduction of questionable records, including photographs suspected to have been artificially generated, raised legitimate questions about the accuracy and reliability of the register and the safeguards put in place to protect its integrity.
According to the organisation, the alleged irregularities may involve unlawful alteration or processing of personal data, possible misuse of authorised access credentials and failures to ensure the accuracy, integrity and security of personal information held and processed by INEC.
It, therefore, urged Tinubu to ensure that the NDPC conducts an independent forensic examination of the affected database and systems to establish whether personal data were unlawfully accessed or altered and whether INEC complied with the Nigeria Data Protection Act 2023.
SERAP also wants the commission to determine whether the incidents constitute a personal data breach under Section 65 of the Act and whether INEC fulfilled its applicable notification and record-keeping obligations.
Where violations are established, it urged the NDPC to require appropriate corrective measures, including stronger security safeguards and accessible procedures through which affected voters can verify and correct their records without being wrongfully excluded.
The organisation further called on the data protection commission to publish its findings and recommendations, subject to lawful protections, and ensure accountability where wrongdoing is established.
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INEC Acknowledges Suspicious Photographs, Questionable Records
SERAP recalled that INEC, in a statement issued on October 27, 2026, acknowledged public concerns over “suspected AI-generated photographs appearing in the Preliminary Register of Voters” published on its website.
The commission disclosed that during the physical display of the register nationwide from October 9 to 15, “a number of questionable registration records were identified and flagged for further examination”.
INEC said it had commenced a review of the records and was taking appropriate corrective action.
The commission also acknowledged that the online publication did not reflect all ongoing data-cleanup activities, adding that it was examining the circumstances surrounding the suspicious photographs, including possible technical or procedural lapses.
INEC maintained that the preliminary register was not the final certified register and promised to complete the necessary verification, adjudication and data-cleanup processes before certifying the final Register of Voters on December 15, 2026.
SERAP, however, said INEC had reportedly acknowledged the existence of questionable voter-registration records and indicated that some registration officers might have used their official access credentials to introduce irregular records, including photographs suspected to have been generated using artificial intelligence.
While acknowledging INEC’s ongoing review, the organisation insisted that an independent investigation by the NDPC was necessary to establish the full circumstances, determine the extent of the irregularities and ensure accountability.
It maintained that an internal review by INEC could not substitute for the NDPC’s independent exercise of its statutory data-protection mandate.
SERAP said the reported irregularities were particularly concerning because INEC’s voter-registration database contains the personal data of millions of Nigerians and is fundamental to the exercise of their constitutional and democratic rights.
It warned that unlawful alteration, manipulation or compromise of the information could undermine public confidence in the electoral process, affect the accuracy and reliability of the voters’ register and expose eligible voters to the risk of wrongful exclusion.
Cites Data Protection Law, Constitutional Guarantees
SERAP said the Nigeria Data Protection Act 2023 empowers the NDPC to investigate possible violations, obtain relevant information and documents, and require compliance by data controllers and processors.
It specifically cited Sections 24 and 39 of the Act, which require personal data to be processed accurately and securely and protected against unlawful alteration, loss or unauthorised access.
The organisation also referred to Section 65, which defines a personal data breach to include a security breach leading, or likely to lead, to the unlawful alteration, loss, unauthorised disclosure of or access to personal data.
On notification requirements, SERAP cited Section 40 of the Act, which requires data controllers to notify the NDPC of a breach likely to pose a risk to individuals’ rights and freedoms within 72 hours of becoming aware of it.
It said the law also requires data controllers to communicate the breach to affected individuals where it is likely to result in a high risk and maintain records of personal data breaches.
SERAP said the Federal Government had a responsibility to ensure that Nigerians’ personal data held by INEC were adequately protected against unlawful access, alteration, manipulation and disclosure.
It added that the reported involvement of registration officers with authorised access to the database made it particularly important to establish whether adequate safeguards were in place and whether such safeguards had been circumvented or misused.
The organisation stressed that the use of authorised credentials did not, by itself, establish that subsequent access or processing was lawful or within the scope of an officer’s authority.
It further said the reported irregularities raised concerns about Nigerians’ constitutional and international human rights, particularly the rights to privacy and political participation.
SERAP cited Section 37 of the 1999 Constitution, as amended, which guarantees the right to privacy, as well as Article 13 of the African Charter on Human and Peoples’ Rights and Article 25 of the International Covenant on Civil and Political Rights, which protect citizens’ rights to participate freely in government and vote in genuine elections.
According to the organisation, these rights require effective safeguards to ensure that eligible voters are not arbitrarily prevented from exercising their political rights.
It maintained that the integrity and accuracy of the Register of Voters were indispensable to the effective exercise of Nigerians’ rights to participate in public affairs and vote in genuine elections.
With INEC scheduled to complete its verification and data-cleanup exercises before certifying the final register, SERAP said the reported irregularities must be independently investigated and effectively addressed before the process is concluded.
It insisted that Nigerians must be able to trust that the register on which the 2027 general elections will be conducted is accurate, reliable and adequately protected against manipulation.
The organisation said the protection of personal data, the integrity of electoral institutions and the effective exercise of political rights were mutually reinforcing obligations under the Nigerian Constitution and international human rights law.
It warned that failure to address the reported irregularities transparently and effectively could undermine public confidence in the electoral process and Nigerians’ right to participate freely in public affairs.
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