The Chief Privacy Officer (CPO) will collaborate with legal, compliance, IT, procurement, the Provostâ™s office including both research compliance and faculty research, and other University functions to develop, implement and administer a comprehensive privacy and data governance program at the University in compliance with all applicable laws including, without limitation, HIPAA, FERPA, GDPR and state privacy laws.
The CPO is the Universityâ™s first privacy officer and will be the senior privacy resource for the University. This person will work with University leadership to identify and address emerging data privacy issues and questions. This individual will collaborate with other University stakeholders to build a data governance program, develop sound privacy policies, procedures and practices that anticipate future innovation in both University administration and emerging areas of research, including bioinformatics and data science. This individual will maintain the Universityâ™s privacy policies and procedures, facilitate data governance activities, and partner with University leadership to ensure that the Universityâ™s program adopts a risk-based analysis consistent with the Universityâ™s mission and values.
This individual must be comfortable working with a wide range of constituents and dealing with broad scope of issues involving both faculty research and data sets as well as administrative data (student records, employee records, financial data, legal data, etc.). The CPO will collaborate with University stakeholders to consider the ethical, legal, regulatory, technological and other implications of these issues and their impact on a wide range of stakeholders as well as the institution. In this capacity, the CPO must be a solution oriented person capable of seeing multiple perspectives who will apply regulatory requirements to ensure the appropriateness of use, protection and confidentiality of data and other information assets across the organization.
The CPO will report to the Vice President and General Counsel and, recognizing the institution-wide nature of the responsibility, will work closely with the Provostâ™s Office, University faculty members, and other members of University leadership. This position will require a high level of knowledge of HIPAA privacy obligations, particularly in the context of research. This position will not be responsible for the University of Chicago Medicineâ™s (âœUCMâ) HIPAA Privacy Program but will be expected to coordinate closely with UCMâ™s Chief Privacy Officer and UCMâ™s HIPAA Privacy Program (e.g., when developing a response to privacy and security incidents that involve data from both the University and UCM). This position requires an individual capable of enhancing the overall awareness and culture of privacy and data governance at the University through training and education.
Build, implement, coordinate, and manage a comprehensive privacy and data governance/privacy program to meet federal, state, and international laws, regulations, and rules regarding privacy
Develop and maintain privacy policies, procedures and practices for research and administrative data, respectively
Draft, review, and maintain privacy policies for the Universityâ™s various websites and online services
Facilitate University-wide data governance program and related meetings, programs, and working groups
Serve as senior privacy resource for the University and work with University leadership to identify and address emerging data privacy issues and questions consistent with the Universityâ™s values, mission and legal requirements
Collaborate with faculty, information technology and security, the privacy team at the Medical Center, legal counsel, University research administration, the Provostâ™s office, procurement, compliance and internal audit
Collaborate with the information security officer to ensure alignment between security and privacy compliance programs including policies, practices, investigations, and acts as a liaison to the information systems department.
Establish with the information security officer(s), an ongoing process to track, investigate and report inappropriate access and disclosure of protected health information. Monitor patterns of inappropriate access and/or disclosure of protected health information.
Advise University research administration in negotiating data sharing contracts for research
Guide procurement in negotiating IT vendor, cloud storage, and consulting and services agreements that involve personally identifiable information
Maintain current knowledge of applicable federal, state, and international privacy laws as well as developments and high-profile incidents at similar institutionsÂ Â
Inform relevant unit leaders and their teams of industry trends and updates on data privacy issues and topics
Provide business units with appropriate tools and methodologies to ensure ongoing compliance
Develop and manage privacy training materials and conduct ongoing privacy training and awareness activities for researchers and administrative units
Collaborate with the Universityâ™s Chief information Security Officer to update and maintain the Universityâ™s incident response plan
Conduct periodic assessment of operations for privacy compliance; assist with investigations when appropriate
Develop and manage procedures for vetting and auditing vendors for compliance with privacy and data security policies and legal requirements
Lead, manage, and contribute to other projects and initiatives as assigned
Expert on privacy matters related to large complex, customer oriented, research-intensive organizations entrusted with large volumes of sensitive, confidential data of a critical nature to the enterprise and its constituents ideal.Â An understanding of HIPAA, FERPA, GDPR and other privacy laws and regulations in higher education and healthcare is critical
Success operationalizing a privacy and data governance program is ideal
Outstanding communication and presentation skills; demonstrated ability to build successful relationships with a wide range of persons across multiple constituencies
Experience with academic research working with an academic medical center preferred.
Ability to define and implement a multi-year strategic program and a corresponding set of strategic goals
Excellent issue-spotting, analytical and problem solving skills
Ability to understand, research, analyze, interpret and apply complex federal, state and international privacy laws, rules and regulations and the constantly evolving risk profiles
Digital and technical proficiency
Ability to facilitate debate, consensus and decision-making and manage governance activities
Excellent judgment in a high-pressure environment; comfortable identifying institutional level decisions or questions of first impression that require input from senior leadership
Dedication to treating internal and external constituents as clients, maintaining a customer service approach
Experience working with HIPAA, FERPA, GDPR, state privacy laws, and ideally experience with their application in both research and administrative contexts
Demonstrated success in training and educating a range of stakeholders on a comprehensive privacy or related plan
Demonstrated ability to manage appropriate responses to different incidents and investigations preferred
Excellent project management skills; demonstrated ability to prioritize work and meet deadlines in a fast-paced environment
Experience working with metrics and success implementing evidence-based changes preferred
Education, Experience or Certifications:
Bachelor's degree required
JD or master's degree in business or related field preferred
Tenor more years of progressively responsible experience in privacy, compliance or related areas in a large research university, academic medical center, or other relevant complex organization required
Certified Information Privacy Professional qualification a plus
Professional References Contact Information
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