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Chief Privacy Officer


Job Number:38743622
Company Name:Toyota Financial Services
Job Location:Greater Los Angeles, CA US
Job Category:Accounting & Finance
 

Chief Privacy Officer
Title: Chief Privacy Officer
Location: US-CA-Greater Los Angeles-Torrance
Other Locations:

Toyota Financial Services
Our people are the driving force behind our success and we're moving forward!
Join a dynamic company known for rapid growth and solid success.

The Chief Privacy Officer (CPO) reports directly to the Chief Compliance Officer. The CPO is responsible for developing and overseeing all activities related to the Enterprise Privacy Compliance Program including Privacy Policies, Procedures, Strategies, Consulting and Training. This role leads and manages the Privacy team that supports TMCC (Credit), TMIS (Insurance), TFSS (Broker Dealer), and TCPR (Puerto Rico) and provides guidance to TFSB (Bank), TCCI (Canada), TSM (Mexico), BTB (Brazil), TCA (Argentina), and TSV (Venezuela).

The CPO is accountable for developing and implementing the Enterprise Privacy Strategy and its decentralized Privacy Support Model. The CPO develops and implements the Enterprise Privacy Due Diligence Program. The CPO is also responsible for ensuring transparency, providing oversight, strengthening controls and providing consistent management compliance reporting. This resource will build relationships throughout the organization with all levels of management. The CPO will manage the Senior Privacy Team Lead, the Senior Privacy Administrator and the contingent/consultant/intern team to effectively meet the overall objectives.

MAJOR RESPONSIBILITIES:
40% Accountable for establishment, promotion, implementation, maintenance and management the overall Enterprise Privacy Compliance Program and Strategy
* Develop, implement and manage the Enterprise Privacy Strategy to ensure compliance with applicable state, federal laws and regulations.
* Liaise with regulatory agencies, including but not limited to: FTC, CFPB, State Financial Services Regulators, and State and Federal Attorneys General. Manage federal and state regulatory examinations related to Privacy, Data Protection, Do Not Call and Credit Reporting. Interact with regulators, provide documentation, communicate with on-site examiners and respond to written requests for information.
* Act as primary contact for external and/or internal audits related to Privacy and Data Protection. Provide documentation, assist in audit process, develop needed action plans, and execute remediation efforts.
* Collaborate and provide guidance and subject matter expertise to internal and external Litigation Counsel related to litigation. Communicate with internal and external Counsel, Consultants and TMS Counsel to facilitate timely responses.
* Lead and manage the Privacy Department and build privacy bench strength and capabilities within the department and throughout enterprise.
* Develop and implement information privacy and data protection policies and procedures in accordance with applicable laws and regulations..
* Work with legal counsel, business management, corporate functions, and committees across the company to ensure that the company has and maintains appropriate information privacy and confidentiality consents, authorization forms, and information notices and materials consistent with requirements.
* Maintain applicable knowledge of information privacy and data security laws and regulations and accreditation standards, and monitor advancements in information privacy technologies to ensure organizational adaptation and compliance.
* Responsible for internal and external communications about, and responses to, information security and privacy-related incidents.
* Oversee content and guide delivery of information privacy and data security training programs to associates, business partners, contingent workers and consultants through support of the Privacy Manager and partnership with HR Organizational Development.
* Participate in the development and implementation of ongoing monitoring/testing to confirm compliance with regulatory requirements and internal policies and procedures.
* Oversee the implementation of Policies, Procedures, Practices and mandatory training.
* Lead the creation of self-assessment scorecards for internal department and external business partner use for initial due diligence analysis. Develop due diligence review calendar. Train the Privacy Manager to conduct reviews and implement the program.
* Manage, monitor and oversee performance of periodic due diligence reviews of internal departments, access control and external business partners to ensure accuracy and adequacy of self-assessments, SAS 70 Audit Reports and legal/financial compliance requirements.
* Evaluate self-assessment scorecards, enhance relationships and collaborate with Band 5 Managers and Business Intelligence (BI) Data Stewards/Data Governance to educate and influence the business units on operational due diligence responsibilities in advance of selecting future business partners. Perform on-going evaluations of outsourced business partners with access to TFS Confidential and TFS Protected Data.
* Drive change through influence with BI Corporate Data Stewards, Enterprise Privacy Consultants and Enterprise Compliance team members to strengthen enterprise knowledge, ownership, responsibility and accountability for Data Privacy within Business Units.
* Partner with Internal Audit, Information Security and Vendor Management Officer to ensure that high risk vendors, internal departments and high risk trends may be identified in their audit for assessments. Partner with the business on remediation efforts.
* Oversee launch of pre-approved Data Sharing Guidelines for Corporate Customer Data Operations and BI Data Stewards to manage their understanding, prioritization and approval processes.
* Architect and oversee the implementation of enterprise privacy portfolio reporting to ensure business unit awareness of customer privacy elections. Consider impacts of opt-out behavior on current and future programs.
* Liaise with U.S. and International outside Counsel and industry resources regarding information privacy and data security compliance matters.
* Represent TFS in relevant industry conferences and panel presentations
* Liaise with Enterprise Compliance and Enterprise Fraud Manager on program development.

35% Manages TFS day-to-day Enterprise wide Privacy Operations and risks
* Accountable for enterprise-wide consultative services as Privacy SMEs for bank, financial, insurance, risk and Global Treasury products, services and affiliates. Strive to fulfill compliance and overall business objectives while defining requirements and evaluating risks for consideration including:
* Data classification and access control
* Business and/or technology projects
* New business opportunities and/or proposed process enhancements
* Policies, procedures, Desk Guide and SOP Changes
* Ad hoc Inquiries
* Serve in a leadership role in Privacy and Data Security regulatory projects in collaboration with the business to fulfill operational and compliance requirements.
* Collaborate with BTS to ensure system and network compliance with Federal and State Privacy, Information Security and other applicable laws.
* Oversee compliance with Federal and State Do-Not-Call regulations and incorporate restrictions into business projects seeking cross-sell opportunities.
* Look for and implement Kaizen opportunities.
* Actively participate in the weekly Security Incident Response Team meetings. Review risk decisions and make recommendations.
* Oversee execution of breach incident communications to customers and internally impacted business units.
* Build awareness of and transparency with Senior Management surrounding existing and future enterprise-wide privacy risks and propose alternatives for their consideration.
15% Vendor Management and Due Diligence Reviews
* Negotiate pricing and improved risk mitigation through National Contracts, in collaboration with Legal and VMO, and management of external business partners providing enterprise-wide services for:
* Privacy print services, including development and approval of initial, annual, and on-demand Privacy Policy notifications and incident communications.
* Manage and sign off on all (at least annual) revisions and due diligence processes including Policy Notices and cover letters.
* Perform due diligence site and process reviews for initial and annual privacy notice projects.
* Regarding Secure Destruction Services, the CPO will set policy, conduct due diligence reviews, maintain secure destruction certifications and coordinate destruction services with Senior Enterprise Compliance Manager.
Additional Responsibilities
* Engage through partnership with Legal in lobbying efforts to facilitate favorable compromises in legislation verbiage to benefit TFS and its customers.
* Liaise with Legal, Internal Audit, Enterprise Compliance, Information Security and Senior Management to maximize awareness of pending legislation that could impact TFS or customers
* Establish objectives, development plans and ensure performance goals are met by Privacy Team members
* Manage Privacy Department budget, conduct forecasting, perform expense reconciliation and seek out opportunities to reduce costs.
* Participate in and/or lead cross-functional Compliance Working Group meetings.
* Participate in IT Data Governance committees.

TFS is looking for individuals with strong business sense and practical expertise. Successful candidates should have:

TECHNICAL REQUIREMENTS
* Strong command of Microsoft Office applications (Word, Excel, PowerPoint, MS Projects, Access, Visio, etc.)
* Proficiency with Brio/Hyperion reporting, Teamsite, Siebel and mainframe applications, Lotus Notes or comparable software and systems
* Solid working knowledge of financial institutions lines of business (i.e. Finance, Sales, Operations, Marketing, Product, etc.)
* Basic knowledge of compliance, privacy, data protection, encryption and data loss prevention technology
EXPERIENCE / EDUCATIONAL REQUIREMENTS / LICENSES OR CERTIFICATIONS
* The ideal person for this role should have extensive management experience in Information Privacy and Data Security
* An education including a B.A. or B.S. degree in finance, accounting, business administration, economics, or related fields of study is strongly preferred.
* Masters or other advanced degree a plus
* 10-15 years financial services industry experience
* 5-10 years of managing and developing staff
* Experience with Privacy strategy and framework development including policies, procedures, standard documentation and publication required
* Relevant technical certifications as Certified Information Privacy Professional or other industry certifications a plus
* Working knowledge of building and maintaining an Enterprise Privacy/Data Protection Department
* Record of mitigating compliance and reputation risks
SPECIAL SKILLS / KNOWLEDGE
* Experience with legal and regulatory compliance frameworks.
* Strong understanding of U.S. and international Privacy/Data Protection/Information Security laws and impacts on Financial Services Industry preferred.
* Demonstrated and practical research and analytical skills.
* Successful project management skills, ideally across functional areas of business, with a history of successful collaboration with others
SUPERVISION EXERCISED
* Senior. Privacy Team Lead, who will supervise any contingent workers and interns,
* Senior Privacy Administrator
Turn toward great benefits:
* Work/Life benefits (flextime, 9/80 work schedules offered where applicable, tuition reimbursement)
* Vehicle lease and purchase (Associates are eligible date of hire, access to favorable rates and more incentives!)
* Medical, dental and vision insurance (Associates are eligible date of hire & premiums are paid by Toyota)
* Matching 401(k) and fully funded Pension Plan
* Paid time off (vacation, sick, personal, holidays)
About Toyota Financial Services
Headquartered in Torrance, Calif., Toyota Financial Services (TFS) is the finance and insurance brand for Toyota in the United States, offering retail auto financing and leasing through Toyota Motor Credit Corporation (TMCC) and extended service contracts through Toyota Motor Insurance Services (TMIS). Lexus Financial Services is the brand for financial products for Lexus dealers and customers. TFS currently employs over 3,300 associates nationwide, and has managed assets totaling more than $81 billion. It is part of a worldwide network of comprehensive financial services offered by Toyota Financial Services Corporation, a wholly-owned subsidiary of Toyota Motor Corporation.
EOE. M/F/D/V.


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