Oversight of Data Protection/Privacy Risk

• Providing Risk Advisory and business engagement to ensure Absa and its subsidiaries are in full compliance to the Data Protection Act.
• Be the de-facto Data Privacy Officer (DPO) and spear head Data Privacy from a second line perspective.
• Performing market intelligence to determine proactively any areas of potential exposure to Absa with respect to Data Protection.
• Streamlining any identified business processes to DPA requirements and best practice.
• Communicating in a proactive manner to the businesses to ensure products, services and channels both existing and new are reflective of DPA requirements.
• Represent Absa Bank and its subsidiaries in industry initiatives such as KBA.
• Develop and map out a proactive robust training program for the Bank and its subsidiaries.
• Demonstrating thought leadership by presenting alternative recommendations to existing approaches.
• Be the main point of contact/ liaison between the Bank and the Office of the Data Protection Controller (ODPC).
• Ensure that all data privacy regulatory requirements/incidents are logged and tracked to conclusion.
• To provide country support and coordination with data privacy/protection policies and standards.
• Prepare data privacy reports and provide representation to the various governance forums within the bank.
• In line with the approved Data Privacy Target Operating model, provide oversight on Privacy initiatives.
• Ensure timely submission of licensing/registration requirements as a data processor and controller.
• Ensure Data Subject Requests are processed and responded to timeously.
• Ensure Cloud governance process is adhered to by the business.
• Ensure Privacy Impact Assessments are adequately documented, supported and reviewed.
• Identification of emerging privacy risks and escalation to senior management.
• Ensure oversight and alignment to policy requirements for Data Touch Points updating, Business List of Records, third party management.
• Work closely with Data Governance teams to ensure data quality, completeness and accuracy.
• End to end responsibility for Reputation/Ethics Risk oversight for ABK and its subsidiaries.
• Ensure Reputation Risk Framework, Policy formulation, localization and sensitization across the Bank and various subsidiaries.
• Ensure training of staff on Reputation Risk Management.
• Prepare management and Board decks on reputation risk profile of the bank and subsidiaries.
• Conduct assessments of the Reputation Risk profile of the Bank and its subsidiaries on a monthly/quarterly basis.
• Provide oversight of first line reputation risk initiatives; and
• Partner with business to ensure reputation risk is mitigated for new and existing initiatives.
• Provide oversight and draw insights from adverse media screening initiatives within the FLOD Operations team.
• Communicating in a proactive manner to the businesses on potential Reputation Risk exposure initiatives/points
• Work with in-country MCR team to ensure that advertising and other content is in line with Absa values.
• Provide oversight for business (RBB, CIB and Subsidiary) messaging other external content to ensure Reputation Risk concerns are addressed.
• Provide steer on Reputation Risk escalations and ensure remediation of any related risk exposures.
• Providing input to the Reputational Risk Committee
• Reviewing packs that business teams wish to submit and ensuring that requisite issues have been considered and incorporated into papers before they are tabled.
• Reviewing feedback from the Reputation Committee and identifying any actions that require his/her input.

Key accountabilities/Deliverables/Outcomes

SME Support & Guidance – 75%

• Establish close working relationships with Business compliance to ensure support for Reputation and data privacy policies and framework.
• Act as a role model and drive proactive application of Absa Values throughout the team including establishment of common goals and objectives.
• Support the business leaders to deliver a high-performance culture.
• Support the embedment and roll out of Data Privacy & Reputation Risk policy and review of reports.

Oversight and Regulatory initiatives – 25%                                   

• Keep local compliance stakeholders updated on data protection initiatives, and the impact to their business.
• Embed appropriate policy and procedure review mechanism to assess reputational risk before it is assumed.
• Keep the Country Head of Compliance and other Management and Executives informed on Reputation and data privacy matters (regulations and policy) which may pose financial or reputational risks.

Role/person specification

Qualification

• Bachelor of Law Degree
• Professional Qualification(s) on Conduct (– sub-risks) and Data Protection Capability
• Analytical Skills/ Qualifications/ Experience
• Excellent command of Laws, Regulations touching on Data Privacy/ Banking/Financial Services/ Investment Services etc

Experience

• 8-10 years’ experience in Banking/Financial services in a fast-paced environment
• Stakeholder management skills/ negotiation skills
• Extensive relationships with key Regulatory contacts
• Wide Ranging compliance/ risk mitigation experience in financial services
• Tact and sensitivity as well as strength and authority are important.
• Ability to use initiative and work with minimum supervision but ensuring, at the same time, that the line reports are kept fully informed at all times.
• Ability to consider issues from a range of angles and propose creative solutions that assist the business in achieving its goals in a safe, compliant and controlled manner.
• Ability to make a real contribution in a rapidly changing environment and thrive on change and the need to learn rapidly.