Americas Privacy Counsel

The Role

Principal Accountabilities: Driving Privacy Compliance and Strategy, Reporting to the Global Head of Privacy Legal and Deputy Global Privacy Officer, the Americas Lead Privacy Counsel is a key contributor to the Privacy Legal and Regulatory Function in establishing and maintaining privacy compliance standards and WTW’s global privacy program for the Americas, principally through the duties and responsibilities set forth below.  Prior privacy and legal experience are required.

Principal Duties/Responsibilities: Leading Privacy Initiatives and Ensuring Compliance

In respect of the region in which the Americas Privacy Lead Counsel is responsible, (“the Relevant Business”), to lead and support the following activities:

1. Identify, Plan, and Apply

• Act as designated country privacy officer for the United States and Canadian group DPO, which includes maintaining awareness of changes to privacy laws, performing gap analyses when required, and implementing required changes as needed in coordination with business teams and corporate functions

• Serve as the legal lead resource (and where required, DPO) in the region on data protection and privacy matters involving privacy laws in the U.S. (i.e., CCPA, other state privacy laws, HIPAA, GLBA), Canada (i.e., PIPEDA and provincial laws), and elsewhere globally and in the Americas (i.e., GDPR, LGPD), including Bermuda and the Cayman Islands.

• Negotiate data protection terms (including HIPAA business associate agreements) for client and supplier agreements in accordance with WTW standard positions.

• Support ongoing maintenance and development of data protection standards and procedures for suppliers and clients in the form of playbooks, standard positions, and other collateral and guidance materials for non-privacy teams within the Office of General Counsel. 

• Advise business and corporate function stakeholders regarding privacy requirements related to collection and processing of personal data with regard to, for example, deidentification of personal data, cross border data transfers, data privacy rights requests, etc. 

• Provide support and guidance on privacy terms as needed in response to RFPs, bids, and strategic business partnerships. 

• Advise the business and fellow legal department members on legal compliance requirements for the Americas applicable to the privacy and management of the personal information of clients, suppliers, employees, and other individuals with whom the company interacts.

• Other duties as assigned by the Global Head of Privacy Legal and Deputy Global Privacy Officer.

2. Support

• Support the design, establishment and maintenance of WTW’s global data privacy program and compliance standards to comport with privacy-legal compliance requirements for Americas, working in close collaboration with the Global Head of Privacy Legal and Deputy Global Privacy Officer.

• Act as point of contact for local privacy regulators and client DPOs.

• Support and work with Privacy Operations as and when required to address data subject requests, project risk assessment, and similar efforts.

• Support Privacy Incident Response as needed by assisting local privacy and legal teams with data security incident investigations.

• Support junior resources on the Privacy Team and non-privacy legal team in negotiation of supplier and client agreements.

• Support and drive implementation projects related to new privacy laws (including new U.S. state privacy laws).

• Oversee and support Americas country privacy officers and act as Chair for the Americas Privacy Working Group and the BDO Privacy Working Group. 

• Support business and corporate functions on the mitigation of data privacy risks identified on privacy impact assessments of WTW’s products and service offerings in the Americas. 

• Support the development and delivery of relevant privacy awareness and training initiatives to build privacy awareness into WTW’s corporate culture.

3. Monitor

• Maintain awareness of changes to privacy laws in countries of responsibility, performing gap analyses when required, and implement required changes as needed in coordination with business teams and corporate functions

• Assess the impact of new and existing regulations or laws on WTW’s existing operations and offerings; provide advice to the relevant business teams to foster privacy by design and alignment with applicable legal requirements and corporate data protection policies and standards. 

• Monitor the approval of new privacy and AI regulations and laws in the region, and cascade information as needed within the Privacy Team and to other WTW stakeholders.

• Remain current on legal, regulatory developments affecting data protection and privacy in Americas.

• Ensure regular and timely reporting on privacy Key Performance Indicators (KPIs) (e.g., standardized metrics as directed by the Privacy Team) and Key Risk Indicators (KRIs) (e.g., PIAs) in the region from DPOs.

4. Engagement

• Engage with the larger Privacy Team globally on matters as required.

• Provide guidance to colleagues on privacy requirements such as (as applicable) privacy impact assessments, records of data processing, data subject requests, privacy by design, privacy audits, and security incidents / personal data breaches requiring notification to privacy regulator(s).

• Chair quarterly Privacy working group meetings for the Americas DPOs and with key business compliance partners.

• Along with the larger Privacy team, provide privacy awareness, engagement, training, and education to legal staff, management and business colleagues relating to data privacy and protection in the Americas, including key legal issues, laws and regulations, corporate policies and other relevant matters. 

Experience / Requirements

• The role requires an experienced lawyer with demonstrable leadership, ability to work independently on assigned matters, and interpersonal skills sufficient to function successfully in a highly visible and challenging position.

• Qualified practicing lawyer with a law degree from an accredited Law School.

• 6 – 8 years’ post qualification experience as a practicing lawyer preferably with a global corporation, in the insurance or consulting industries preferred.

• The preferred candidate holds a privacy certification (CIPP, CIPT or CIPM from the IAPP or similar) and has Spanish language proficiency.

• Detailed knowledge of data protection/privacy requirements, laws and regulations in the Americas and globally, including CCPA, other U.S. state privacy laws, GLBA, HIPAA, PIPEDA, and GDPR  along with experience of providing advice relating to information technology service providers and vendors.

• The ability to work collaboratively and to engage and influence in a complex, global multinational, matrix organization.

• Strong interpersonal and influencing skills which can be applied to both internal and external relationships, with the ability to reconcile compliance requirements with business needs as far as is possible.

• Technology background helpful but not required.

• Excellent written and oral communication skills.

• Adept at analyzing and interpreting laws and regulations.

• Attention to detail.

• Exemplary personal and professional integrity and business ethics.

• Exercises discretion and maintains confidentiality of sensitive information.

• Ability to make autonomous decisions that are strategically of a high level of risk to the organization

This position will remain posted for a minimum of three business days from the date posted or until sufficient/appropriate candidate slate has been identified.
 

Compensation and Benefits 

Base salary range and benefits information for this position are being included in accordance with requirements of various state/local pay transparency legislation. Please note that salaries may vary for different individuals in the same role based on several factors, including but not limited to location of the role, individual competencies, education/professional certifications, qualifications/experience, performance in the role and potential for revenue generation (Producer roles only).

Compensation 

The base salary compensation range being offered for this role is $75,000 - $130,000 USD annually.

This role is also eligible for an annual short-term incentive bonus. 

Company Benefits 

WTW provides a competitive benefit package which includes the following (eligibility requirements apply):

• Health and Welfare Benefits: Medical (including prescription coverage), Dental, Vision, Health Savings Account, Commuter Account, Health Care and Dependent Care Flexible Spending Accounts, Group Accident, Group Critical Illness, Life Insurance, AD&D, Group Legal, Identify Theft Protection, Wellbeing Program and Work/Life Resources (including Employee Assistance Program)
• Leave Benefits: Paid Holidays, Annual Paid Time Off (includes state/local paid leave where required), Short-Term Disability, Long-Term Disability, Other Leaves (e.g., Bereavement, FMLA, ADA, Jury Duty, Military Leave, and Parental and Adoption Leave), Paid Time Off (only included for Washington roles)

• Retirement Benefits: Qualified contributory pension plan (if eligible) and 401(k) plan with annual nonelective company contribution. Non-qualified retirement plans available to senior level colleagues who satisfy the plans’ eligibility requirements.

   

 Pursuant to the San Francisco Fair Chance Ordinance and Los Angeles County Fair Chance Ordinance for Employers, we will consider for employment qualified applicants with arrest and conviction records.

If the position allows for flexible working: 

At WTW, we trust you to know your work and the people, tools and environment you need to be successful. The majority of our colleagues work in a ”hybrid” style, with a mix of remote, in-person and in-office interactions dependent on the needs of the team, role and clients. Our flexibility is rooted in trust and “hybrid” is not a one-size-fits-all solution.

We understand flexibility is key to supporting an inclusive and diverse workforce and so we encourage requests for all types of flexible working as well as location-based arrangements. Please speak to your recruiter to discuss more.

EOE, including disability/vets