The Socio-Economic Rights and Accountability Project (SERAP) has urged President Bola Tinubu to direct the Nigeria Data Protection Commission (NDPC) to independently investigate suspected artificial intelligence-generated photographs, alleged alterations of personal data and other questionable records found in the preliminary Register of Voters published by the Independent National Electoral Commission (INEC).
SERAP made the demand in a letter dated October 31, 2026, signed by its Deputy Director, Kolawole Oluwadare, following INEC’s acknowledgement that questionable registration records and suspected AI-generated photographs had been identified in the preliminary register.
The organisation asked Tinubu to direct the National Commissioner and Chief Executive Officer of the NDPC, Dr Vincent Olatunji, to conduct what it described as a prompt, thorough, independent and effective investigation into the circumstances surrounding the records.
SERAP said the investigation should establish the nature and extent of the irregularities, determine whether any personal data breach occurred under the Nigeria Data Protection Act 2023, identify those responsible and ensure that affected Nigerians are able to verify and correct their records without being wrongly excluded from the electoral process.
“The reported irregularities raise serious concerns about the security and integrity of Nigerians’ personal data and the reliability of the voter register ahead of the 2027 general elections,” SERAP said.
It added that Nigerians should not have to worry that their personal information could be altered, manipulated or accessed without appropriate safeguards.
SERAP’s intervention followed an October 27 statement by INEC acknowledging public concerns over suspected AI-generated photographs appearing in the preliminary Register of Voters.
INEC said 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.
The electoral commission said it had commenced a review and corrective action and was examining how the suspicious photographs appeared, including the possibility of technical or procedural lapses.
INEC also explained that the version published online represented the original preliminary register and did not reflect all the data-cleanup activities already underway.
The commission stressed that the document was not the final certified Register of Voters and said verification, adjudication and data-cleanup exercises would be completed before certification of the final register on December 15, 2026.
SERAP, however, maintained that INEC’s internal review could not replace an independent investigation by the NDPC under its statutory data-protection mandate.
“INEC’s acknowledgement of questionable records and suspected AI-generated photographs makes 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,” the organisation said.
It called for an independent forensic examination of the affected database and systems to determine whether personal data were unlawfully accessed or altered and whether INEC complied with the Nigeria Data Protection Act 2023.
According to SERAP, the investigation should establish the number and geographical distribution of affected records, when and how the questionable entries were created or altered, and the persons or institutions responsible.
The organisation also expressed concern over reports that authorised access credentials might have been used in connection with some irregular records.
SERAP said the use of authorised credentials would not by itself establish that subsequent access to or processing of voter information was lawful or within the scope of an officer’s authority.
It urged the NDPC to determine whether the reported incidents amounted to a personal data breach under Section 65 of the Nigeria Data Protection Act 2023 and whether applicable notification and record-keeping requirements were followed.
SERAP also cited Sections 24 and 39 of the Act on the accurate and secure processing of personal data, as well as Section 40, which provides for notification to the NDPC where a breach is likely to pose risks to the rights and freedoms of individuals.
Where violations are established, SERAP called for corrective measures, stronger security safeguards and accessible procedures through which affected voters could check and correct their information without being unfairly excluded.
It also urged the NDPC to publish its findings and recommendations, subject to lawful restrictions, and ensure accountability where wrongdoing is established.
SERAP linked the integrity of the voter register to Nigerians’ rights to privacy and political participation, citing Section 37 of the 1999 Constitution, Article 13 of the African Charter on Human and Peoples’ Rights and Article 25 of the International Covenant on Civil and Political Rights.
“The integrity and accuracy of the Register of Voters are indispensable to the effective exercise of the rights to participate in public affairs and to vote in genuine elections,” the organisation said.
It warned that any unlawful alteration or manipulation of voters’ personal information could undermine public confidence in the electoral process and expose eligible Nigerians to the risk of wrongful exclusion.
SERAP consequently gave the President seven days from the receipt or publication of its letter to take the requested steps.
“We would be grateful if the requested measures are taken within seven days of the receipt and/or publication of this letter. If we have not heard from you by then, SERAP shall consider appropriate legal actions and other lawful measures,” it said.
The organisation maintained that the reported irregularities should be independently investigated and addressed before INEC certifies the final voter register.
“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,” SERAP added.
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