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Compliance and Ethics Counsel Associate Manager, Data Privacy The candidate will be part of the Data Privacy team in Legal and supports the company Data Protection Officer (DPO) and Geographic Units (GU) Privacy and Security Leads. The role reports to the Compliance and Ethics Counsel Associate Director, who is company’s Data Protection Officer. Individuals with relevant data privacy experience at a global company in the technology and IT sector are preferred. Understand the triggers and requirements for performing Data Protection activities and processes for executing these (for example, privacy reviews, Data Protection Impact Assessments and recording of processing activities) and manage and perform such activities. Provide advice to the GU Privacy and Security Leads, on how to support client facing and internal teams on DP activities such as contract negotiations, new offerings, internal projects, client contracts, M&A activity, individual complaints and requests for exercise of individual rights and on IS activities. Participate in the management of data security incidents in accordance with company processes, in alignment with other relevant stakeholders (for example as advised or requested by company’s Computer Incident Response Team (CIRT)). Manage and maintain required processes for the Data Privacy Center of Excellence. Support the Compliance and Ethics Counsel Managers and DPO in driving DP risk management and improvement. Work with stakeholders (e.g. Information Security (IS), account teams, other corporate functions) on DP law, compliance and risks as required (for example by providing input on any changes to scope in controls or processes required as a result of new local laws). Manage the handling of individual rights requests. Implement essential elements of the GDPR and other Data Protection laws by inputting into policies, plans and processes. Provide Data Protection support for global information systems. Recognize and appropriately deal with conflicts of interest and other concerns. Be involved in Data Protection regulatory and auditory requirements. Help monitor compliance by reviewing information provided by central audit and monitoring teams (for example Internal Audit and Security Assessments team); assist GU Privacy and Security Leads in interpreting such information. Manage requests from regulators – information, inspection, audit – and any enforcement action. Support GU Privacy and Security Leads in ensuring that local filings/notifications of systems and data processing are maintained and any required authorizations obtained. Provide input into global and local DP training and awareness programs as requested by the DPO. Support the Compliance and Ethics Counsel Managers and DPO in requiring GU Privacy and Security Leads to actively promote local engagement (including with senior leadership) on Data Protection topics, for example by delivering training and awareness programs based on globally packaged materials. Actively foster and promote a DP culture within the organization. Be able to speak knowledgably on Data Protection to client facing and internal teams and direct their queries appropriately and be able to speak at external conferences and events. Keep up to date with Data Protection topics such as regulatory guidance and enforcement action, activities of relevant industry and standards associations etc. Report on company’s global Data Protection programs. Advise the Compliance and Ethics Counsel Managers, DPO and GU Privacy and Security Leads in reporting on agreed Data Protection topics to leadership, local boards, and regulators as required. Proactively raise trends, potential threats, concerns or other information within Legal, IS and other stakeholders as appropriate.
Qualification and Experience
The candidate must be filled by a qualified lawyer with at least 3-5 years’ relevant experience in the data privacy (DP) field. Should have Law degree. CIPP, CIPM, CIPT, CISSP and/or CISM preferred or willingness to obtain within a short period. Preferred experience: Experience in DP program design and management; Expertise in European and other DP laws and practices and an in-depth understanding of the GDPR; Project management experience; Experience in preparing and delivering trainings; Experience working with fragmented data to report meaningful metrics and identify actionable insights; Experience with privacy and security risk assessment and best practices, privacy certifications/seals, and information security standards certifications. Demonstrated experience of communicating effectively with leadership, business teams, data subjects, data protection authorities and other controllers and processors across national boundaries and cultures. Should have ability to work independently and collaboratively across various levels. Must have English anguage proficiency – other languages may be an advantage (in particular Spanish or Portuguese) (for example, in order to be able to communicate with regulators).
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