SERAP Urges Tinubu to Order Probe of INEC Voter Register  

The Socio-Economic Rights and Accountability Project (SERAP) has asked President Bola Tinubu to direct the Nigeria Data Protection Commission (NDPC) to independently investigate suspected artificial intelligence-generated photographs and alleged alterations to personal information in the preliminary voters’ register released by the Independent National Electoral Commission (INEC).

In a letter dated October 31, 2026, and signed by its Deputy Director, Kolawole Oluwadare, SERAP urged Tinubu to instruct NDPC Chief Executive Officer Vincent Olatunji to establish the scope of the irregularities, determine whether the Nigeria Data Protection Act 2023 was violated and identify those responsible.

The organisation also called for measures to ensure that affected voters can verify and correct their information without being unlawfully excluded from the electoral process.

SERAP’s demand follows INEC’s acknowledgement of questionable registration records and suspected AI-generated photographs discovered during the nationwide display of the preliminary register between October 9 and 15.

The commission, in a statement on October 27, said it had begun reviewing the suspicious entries and was investigating possible technical or procedural lapses. It also noted that the online version of the register did not reflect all ongoing data-cleanup activities.

INEC said the preliminary register was not the final certified version and pledged to complete verification and corrections before the final register is certified on December 15, 2026.

SERAP said the reported irregularities raised concerns about the accuracy of the register, the security of Nigerians’ personal information and the reliability of the database ahead of the 2027 general elections.

It called on the NDPC to conduct a forensic examination of INEC’s voter-registration systems to determine whether personal data had been unlawfully accessed, altered or processed and whether the commission had fulfilled its legal obligations.

The organisation said the investigation should establish the number and geographical spread of affected records, when and how the irregularities occurred, and whether authorised access credentials were misused.

SERAP stressed that the NDPC’s independent investigation was necessary, arguing that INEC’s internal review could not replace the data protection commission’s statutory responsibilities.

It cited Sections 24 and 39 of the Nigeria Data Protection Act, which require personal information to be processed accurately and securely and protected against unauthorised access, loss or alteration.

The organisation also referenced Section 65, which defines a personal data breach to include security failures resulting in, or likely to result in, unlawful alteration, loss or unauthorised access to personal information.

SERAP said Section 40 requires data controllers to notify the NDPC of breaches likely to threaten individuals’ rights and freedoms within 72 hours of becoming aware of them. It added that affected individuals must also be informed where a breach poses a high risk to their rights.

The group further called for corrective measures, stronger security safeguards and accessible procedures through which affected Nigerians could confirm and amend their voter information.

It urged the NDPC to make its findings and recommendations public, subject to legal protections, and ensure accountability if violations were established.

The letter, read in part: “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.”

“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 NDPC should exercise its statutory powers independently and without delay. Any investigation must establish the facts, protect affected voters and ensure that those responsible for any unlawful conduct are held accountable.

“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 to compel your government, the NDPC, INEC and other relevant authorities to comply with our requests in the public interest.”

“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 persons or institutions responsible.

“The introduction of questionable records, including photographs suspected to have been artificially generated, raises legitimate concerns about the accuracy and reliability of the register and the safeguards protecting its integrity.

“SERAP is concerned that the reported irregularities may involve the unlawful alteration or processing of personal data, possible misuse of authorised access credentials and failures to ensure the accuracy, integrity and security of personal data held and processed by INEC.

“SERAP urges you to ensure that the NDPC conducts 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.

“SERAP further urges you to ensure that the NDPC determines whether the incidents constitute a personal data breach under section 65 of the Act and whether INEC has complied with its applicable notification and record-keeping obligations.

“Where violations are established, appropriate corrective measures should be required, including stronger security safeguards and accessible procedures for affected voters to verify and correct their records without wrongful exclusion.

“The NDPC should publish its findings and recommendations, subject to lawful protections, and ensure accountability where wrongdoing is established.”

SERAP warned that irregularities in INEC’s database could undermine public confidence in the electoral process and expose eligible voters to wrongful exclusion.

It also said the matter raised constitutional and human rights concerns, citing Section 37 of the Nigerian Constitution, which guarantees privacy, as well as provisions of the African Charter on Human and Peoples’ Rights and the International Covenant on Civil and Political Rights protecting political participation and voting rights.

The organisation urged the authorities to address the concerns transparently and before the final register is certified, warning that failure to do so could weaken confidence in the electoral process.

SERAP gave the government seven days from receipt or publication of its letter to respond, adding that it would consider legal action and other lawful measures if its demands were not addressed.

“The reported irregularities also raise concerns about Nigerians’ constitutional and international human rights, including the rights to privacy and political participation.

“Section 37 of the Nigerian Constitution 1999 (as amended) guarantees the right to privacy. Article 13 of the African Charter on Human and Peoples’ Rights and Article 25 of the International Covenant on Civil and Political Rights protect citizens’ rights to participate freely in government and to vote in genuine elections.

“These rights require effective safeguards to ensure that eligible voters are not arbitrarily prevented from exercising their 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 reported irregularities must be treated with the seriousness they deserve.

“INEC has indicated that it will complete the necessary verification and data-cleanup exercises before certification of the final Register of Voters. It is therefore essential that the reported irregularities are independently investigated and effectively addressed before the register is finalised.

“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 protection of personal data, the integrity of electoral institutions and the effective exercise of political rights are mutually reinforcing obligations under the Nigerian Constitution and international human rights law.

“A failure to address the reported irregularities transparently and effectively risks undermining public confidence in the electoral process and the rights of Nigerians to participate freely in public affairs,” it added.