SERAP Seeks Probe Of AI-Generated Photos, Altered Records In INEC Voters Register

The Socio-Economic Rights and Accountability Project (SERAP) has called for an independent investigation into suspected AI-generated photographs and alleged manipulation of personal data in the Independent National Electoral Commission’s (INEC) preliminary Register of Voters ahead of the 2027 general elections.

SERAP specifically urged President Bola Tinubu to direct the National Commissioner and Chief Executive Officer of the Nigeria Data Protection Commission (NDPC), Dr Vincent Olatunji, to investigate the alleged irregularities, determine whether they breach data protection laws and identify those responsible.

The organisation, which made the demand in an open letter dated October 31, 2026, and signed by its Deputy Director, Kolawole Oluwadare, warned that the reported manipulation of voter registration records could undermine the electoral register’s integrity, compromise Nigerians’ personal data and expose eligible voters to wrongful exclusion.

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The call follows INEC’s October 27 acknowledgement of concerns about suspected AI-generated photographs in the preliminary register published on its website.

The commission said it identified questionable registration records during the nationwide display of the preliminary register from October 9 to 15, 2026, and flagged some for further examination.

INEC also said it was investigating the circumstances surrounding the suspicious photographs, including possible technical or procedural lapses, while taking corrective measures.

The commission had further explained that the online register did not reflect all ongoing data-cleaning activities and maintained that the preliminary register was not the final certified version.

It stated that verification, adjudication and data-cleaning exercises would be completed before the final Register of Voters is certified on December 15, 2026.

However, SERAP argued that INEC’s internal review was insufficient, saying the NDPC must independently investigate the allegations under its statutory data-protection mandate.

The civil society organisation urged the commission to conduct a forensic examination of INEC’s voter-registration database and related systems to establish the nature and extent of the irregularities, the number and geographical distribution of affected records, when and how they were created or altered, and who was responsible.

It also called for an investigation into whether registration officers or others misused authorised access credentials to introduce questionable records, stressing that having official access credentials does not automatically make every subsequent action lawful.

SERAP further urged the NDPC to determine whether personal data had been unlawfully accessed, altered or processed and whether INEC had complied with the Nigeria Data Protection Act 2023.

Citing Sections 24 and 39 of the Act, the organisation said personal data controllers must ensure the accuracy, integrity and security of information in their custody and protect it against unlawful alteration, loss and unauthorised access.

It also cited Section 65, which defines a personal data breach as including a security breach that results, or is likely to result, in the unlawful alteration, loss, disclosure of or access to personal data.

According to SERAP, Section 40 requires data controllers to notify the NDPC within 72 hours of becoming aware of a breach likely to pose risks to individuals’ rights and freedoms. They must also notify affected individuals if the breach is likely to result in a high risk and maintain records of such incidents.

The organisation said the NDPC should establish whether the reported incidents triggered these obligations and require appropriate corrective measures if violations are confirmed.

It also called for accessible procedures that would allow affected Nigerians to verify and correct their voter-registration details without unfair disenfranchisement.

SERAP said the alleged irregularities raised concerns beyond data protection, particularly about the constitutional rights to privacy and political participation.

It 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 in public affairs and vote in genuine elections.

The organisation warned that any compromise of the voter-registration database could erode public confidence in the electoral process and affect eligible Nigerians’ ability to exercise their democratic rights.

It therefore urged the NDPC to publish its findings and recommendations, subject to lawful protections, and ensure that anyone found responsible for wrongdoing is held accountable.

SERAP asked that the measures be taken within seven days of receipt or publication of its letter, warning that it would consider legal action and other lawful measures against the federal government, NDPC, INEC and other relevant authorities if its demands were not addressed.

It said an independent investigation and effective corrective measures were particularly urgent given INEC’s December 15 deadline to certify the final register, which will be used for the 2027 general elections.