This is an exciting opportunity to leverage your substantial privacy, data protection and information security knowledge, expertise and passion in a collaborative, fast-paced and engaged setting that continuously strives for excellence, customer satisfaction, compliance, innovation, and industry leadership at a dynamic time in the world of privacy, the payments industry, and PayPal’s history.
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As Product Privacy Counsel you will help ensure PayPal businesses collect, processes and safeguard personal data, and communicate with our customers, in compliance with applicable laws, rules and regulations, such as GLBA, FCRA, FACTA, California Financial Information Privacy Act, CA`N-SPAM, TCPA, TSR, CASL, Luxembourg’s Data Protection Law, Luxembourg’s Banking Secrecy Law, the EU Data Protection Directive, EU E-Privacy Directive, Singapore’s Personal Data Protection Act, PCI-DSS, security breach notification statutes, and other applicable national, state/provincial, and international privacy data protection, and consumer protection-related laws, rules and regulations as well as self-regulatory codes of conduct and company policies.
As Privacy Counsel you will use your privacy, data protection, information security and program management expertise in areas such as:
• Helping develop, implement, maintain, assess, and monitor public-facing privacy policies and other user disclosures and consents so that they are accurate, clear, user-friendly and compliant, and meet business requirements, as well as internal policies and standards.
• Advising on collecting, sharing, accessing, analyzing, and safeguarding personal information
• Reviewing and advising on new and enhanced mobile and on-line products and services, technology, marketing programs and communications, and new business initiatives.
• Helping drive focus on Privacy by Design and Security by Design, particularly in the product design and review process
• Conducting privacy impact assessments
• Implementing ongoing privacy compliance monitoring and self-testing activities
• Drafting and negotiating privacy and data protection-related provisions of complex commercial and technology contracts, including for strategic business partnerships, outsourcing, data processing, joint ventures, M&A transactions and business dispositions; conducting due diligence and on-going monitoring.
• Identifying privacy and data protection-related risks and suggesting mitigation measures throughout PayPal businesses globally
• Driving and helping ensure compliance with Privacy by Design and Security by Design requirements
• Creating and delivering effective training and enhance awareness around privacy and data protection policies, practices, requirements, opportunities and risks that foster colleagues’ understanding of how privacy and data protection affects their job responsibilities, our customers, and business operations and strategy
• Mapping and analyzing data flows across the data lifecycle
• Supporting PayPal’s Customer Service Organization on inquiries and concerns related to privacy and data protection, including data subject access requests
• Helping perform due diligence around business partners and services providers and identifying appropriate mitigation strategies
• Proactively working with privacy and data protection regulators, ensuring positive and productive relationships and a well regarded and compliant global privacy program
• Coordinating with PayPal’s government relations group to proactively monitor and review privacy and data-protection related legislation.
• Working closely with PayPal’s Corporate Communications and Marketing teams to help ensure that PayPal’s privacy, security and consumer protection practices and commitments are clearly and accurately communicated
• Helping ensure that PayPal colleagues, policies and practices keep up-to-data on changes to applicable privacy, data protection, information security and bank secrecy-related laws, rules and regulations, emerging technologies, and the growth and innovation of our businesses
• Responding to regulatory inquiries related to privacy and data protection matters and preparing regulatory filings if needed
• Developing and maintaining collaborative relationships with, and provide privacy and data protection subject matter expertise to, PayPal’s global legal team; and the product, compliance, information security, risk, technology, marketing, enterprise risk management, corporate development, human resources, finance, tax internal audit organizations; and teams within PayPal that collect, access or use personal information
• Demonstrating in-depth knowledge of cutting edge technology issues and their privacy and data protection implications with emphasis on mobile technologies and mobile payments
• Demonstrating in-depth knowledge of marketing practices and their privacy and data protection implications, including OBA, as well as understanding of applicable marketing and consumer protection laws
• Providing legal support for PayPal’s data incident response program
• Helping strategize, design, and implement privacy and data protection-related solutions for all areas of PayPal as a member of PayPal’s global privacy team
• Identifying and executing on opportunities to continuously improve our privacy policies and practices
• Serving as privacy and data protection subject matter expert and liaison for PayPal’s business in the LATM and APAC regions and in emerging markets
Job Description:
J.D. or equivalent law degree required; admitted to the Bar and licensed to practice law
Minimum of 10 years direct legal experience required
5 years actively advising global businesses as in-house counsel and/or as outside counsel on privacy, data protection and information security issues required and preferred
Experience advising clients in the financial services, mobile payments, e-commerce, internet and technology industries preferred; knowledge of data management and analytics, advertising, and/or retail industries helpful
Public company experience helpful
Consulting experience and Regulatory experience helpful
Sound and practical legal and business judgment and critical thinking; collaborative and proactive approach to consulting and problem solving
Excellent communications skills
Highest standards of and commitment to ethics and integrity
Ability to build relationships and trust across the organization
Demonstrated ability to work autonomously as well as part of a team, to effectively coach and mentor others (including non-attorneys), a sense of humor and resiliency especially under tight deadlines and while managing multiple priorities
Depending on the position, experience managing staff and leading teams, including virtual ones
Ability to identify, understand and respond to business and technical requirements
M&A experience and experience integrating new business units desirable
Demonstrated use of, proficiency with, and passion for PayPal products and services
CIPP, CISSP, CISA and/or other relevant certifications desirable
Ability to travel if needed for the business
Fluency in English; multiple languages is a plus
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