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Senior Manager, Global Data Privacy (m/f / D)

Brookfield

Position Purpose

The Senior Manager, Global Data Privacy, is responsible for supporting the implementation of all strategies and operational plans as instructed by the Global Head, Data Privacy and Regional Data Privacy Head, EU, with a heavy focus on the European region but supporting all regions globally as required. This will be an enterprise-wide role responsible for all CSL Group entities including Behring, Seqirus and Vifor.

In this role, the incumbent is also responsible for supporting the Regional Data Privacy Heads in the development of regional strategies for execution of the data privacy program, which includes for the identification, implementation, and adherence to CSL’s data privacy policies and procedures in the various regions. The incumbent in this role will act as a data privacy advisor and business partner to the CSL enterprise in all regions, with a heavy focus on Europe, and advise and support the business in ongoing data privacy risk identification, management, controls and mitigations. The role will proactively and regularly identify opportunities for improvement in the data privacy area including technology (in collaboration with IT) and recommend those to the Global Head of Data Privacy and Regional Data Privacy Head, EU. It will support the design, establishment and maintenance of routines that are both globally prescribed and locally established within all regions globally, to manage, monitor and analyse regulatory/enforcement and business changes as well as considering ‘best practices’ in the industry to proactively anticipate any impacts to CSL, and then address accordingly.

The role assesses and communicates information regarding data privacy with sites, functions, and businesses as directed by the Global Head of Data Privacy and the Regional Data Privacy Head, EU and to support the other Regional Heads. It develops and implements controls and risk-based approaches toward data privacy compliance in accordance with CSL’s Risk Appetite Statement and in accordance to the data privacy laws.

Responsibilities:

  • Recommends, directs and supports implementation of strategies and operational plans and maintenance of CSL’s Data Privacy policies and procedures, with a heavy focus in the EU region and within the global framework. Responsibilities include recommending, initiating, facilitating and promoting activities to foster data protection and privacy awareness across all CSL Group entities including Behring, Seqirus and Vifor.
  • Serves as Data Privacy advisor and business partner globally, with a heavy focus in the EU region, under the supervision of the Regional Data Privacy Head, EU.
  • Supports strategies, operational plans and program initiatives to ensure that data privacy controls and processes are adopted, implemented and documented to promote compliance with data privacy laws, regulations and policies globally.
  • Assists with Data Privacy risk assessment across key sites, functions and offices with a heavy focus in the EU region, while ensuring global consistency, in conjunction with the Regional Data Privacy Heads and Global Lead Head of Data Privacy. Performs initial and periodic data privacy risk assessments related to ongoing privacy compliance monitoring activities in coordination with the Regional Data Privacy Heads and Global Head of Data Privacy, and as applicable, with the EREC Monitoring and Assurance team.
  • Advises and supports the business in determining the current risk of a given processing activity, provides support for the business on appropriate risk acceptance and supports identifying controls to mitigate such risk, under the supervision of the Regional Data Privacy Head, EU and in consultation with other Regional Data Privacy Heads.
  • Initiates, facilitates and promotes activities to foster Data Privacy awareness within CSL as required across the regions, with a heavy focus on EU. Collaborates with the business and functions (in consultation with the Global Head of Data Privacy) to actively participate in global activities to improve cross-geographical and cross-functional awareness and to share best practices in Data Privacy.
  • Provides guidance to the business, with a heavy focus in the EU region so that processing activities utilizing personal information are secure and comply with CSL policies. This includes partnering with the business so that Data Privacy by Design & Default (DPbDD) principles and checks are built into all aspects of operations wherever and whenever personal data is collected, used, disclosed, retained, transferred, and/or disposed. This includes Supplier Assessments, Project Requests and Approval, System Design, System Access Control and Data Privacy Impact Assessments.
  • Proactively and regularly identifies opportunities for improvement in the data privacy area including technology (in collaboration with IT) and implements in accordance with agreed plans. In consultation with Regional Data Privacy Head, EU and other Regional Heads, establishes, maintains and sets routines/cadence to manage, monitor and analyse regulatory/ enforcement and business changes as well as consider ‘best practices’ in the industry.
  • Routinely scans regulatory, enforcement, environment, trade, and business news, as well as competitor activity and actual/emerging industry trends and related information/materials to proactively anticipate any impacts to data privacy or opportunities for improvements at CSL.
  • Swiftly escalates to appropriate Regional Data Privacy Head to enable swift reaction to changes in business conditions or events that may impact CSL’s data privacy or present a risk to the business. 
  • Performs impact analysis to policies, standards and procedures.
  • Monitors, recommends solutions by anticipating regulatory direction and action of data privacy authorities and supports the implementation of changes and processes based on trends and corrective actions for the regions, while ensuring global consistency, in consultation with the Global Head of Data Privacy.
  • Develops and establishes appropriate privacy and confidentiality contractual language, consent forms, and information notices and materials reflecting current CSL legal practices and global regulatory requirements. Ensures that the contract requirements and privacy obligations as required are considered and provides stakeholders with advice and guidance (including counsel) on data privacy contract requirements and obligations.
  • Supports the business so that approved Data Subject Requests (DSRs) in the regions are executed as appropriate and in a timely manner and that any document and evidence of DSR evaluation, execution, and response are appropriately stored and can be retrieved in the regions. Recommends any technological advances or process improvement for the DSR process to the Global Head of DP.
  • Supports training and educating the business to execute data privacy impact assessments (DPIAs) and that they are processed in accordance with regulatory requirements and considerations (global and relevant laws). Ensures that the DPIAs are recorded and stored in designated repository.
  • Directs and ensures implementation of approved process for receiving, documenting, tracking, investigating, and taking action on all data privacy breaches and complaints concerning CSL’s privacy policies and procedures in coordination and collaboration with Ethics & Compliance (E&C) and Cyber Security.
  • Supports establishing detailed action plans in compliance to the local and global laws to remediate data breaches and incidents in a timely manner, capturing agreed actions in accordance with EREC and Data Privacy frameworks, policies and procedures and follows up on execution of agreed actions by relevant business stakeholders to close issues.
  • Regularly measures/reports on key data privacy and risk appetite statement measures in accordance with the global strategy and frameworks/policies, to report to the Data Privacy Governance Committee. Includes supporting the Global Head of DP with assessment of the risk appetite statements and risk measures considering any proposed changes, additions or deletions, with a focus on leading measures. 
  • Acts as a thought leader on data privacy matters and is visible as such internally through initiating, facilitating and promoting activities to foster Data Privacy awareness across the regions, with a heavy focus on EU.
  • Provides guidance and training to all employees, contractors, and other appropriate third parties to the regions with a heavy focus on EU, and globally on regional Data Privacy principles as needed.
  • Supports the Global Head of Data Privacy in other projects and responsibilities, as assigned, that may be global in nature or region specific.

Qualifications:

  • Bachelor’s degree in Law or advanced degree in relevant field
  • Certification in Data Privacy preferred for example, International Association of Privacy Professional certification
  • 7+ in a life sciences, technology or manufacturing organization with 3 or more years of operational application of Data Privacy laws
  • Expertise in data protection laws
  • Knowledge of interpreting and applying global Data Privacy laws and regulations, with expertise in countries specific to the EU region
  • Capacity to act independently and collaborate with the global Data Privacy Team
  • Experience interacting with regulators and regulatory agencies (preferred)
  • Practical experience of implementing data privacy projects globally or regionally (preferred)
  • Fluency in English AND German (oral and written communication)

Our Benefits

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About CSL Behring

CSL Behring is a global leader in developing and delivering high-quality medicines that treat people with rare and serious diseases. Our treatments offer promise for people in more than 100 countries living with conditions in the immunology, hematology, cardiovascular and metabolic, respiratory, and transplant therapeutic areas. Learn more about CSL Behring.

We want CSL to reflect the world around us

As a global organisation with employees in 35+ countries, CSL embraces diversity and inclusion. Learn more about Diversity & Inclusion at CSL.

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Confirmed 16 hours ago. Posted 30+ days ago.

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