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.
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