Associate General Counsel, Privacy and Data Security, Gap Inc.

Doris and Don Fisher opened the first Gap store nearly 50 years ago in San Francisco. The reason was simple: Don couldn't find a pair of jeans that fit. They never expected to transform retail, but they did. While our past is full of iconic moments, our future is going to spark many more. We're looking for the people who will help make our next decade just as revolutionary as our first five.

Today, Gap Inc. is a global retail portfolio with $15.5 billion in net sales (during fiscal year 2016). Our six brands reach customers in more than 90 countries worldwide through about 3,200 company-operated stores, about 450 franchise stores, and e-commerce sites.

The position plays a critical role in the enablement of the changing face of retail. This position is responsible for the overall leadership and legal strategy of key enterprise programs focused on privacy, data security and information management in collaboration with our global legal teams. This includes providing strategic counsel on customer and employee data practices and policies, vendor and technology agreements and the company's e-commerce, mobile and omni-channel strategies, as well as serving as a key leader in GDPR compliance and incident responses.

The role will work closely with the information security, internal audit, and corporate security teams and requires expertise in both privacy law and compliance in order to handle complex issues in a variety of contexts. This position will lead a team focused on privacy, data security and information management related projects in the legal and compliance space and be expected to interact with and influence senior level business partners, including c-suite leaders and the CISO.

COMPETENCIES

  • Strategic Orientation
  • Drives Results
  • Customer Impact
  • Change Leadership

ORGANIZATIONAL LEADERSHIP

  • Responsible for evolving privacy strategy and developing Gap Inc.'s next stage privacy program and compliance framework, develop and communicate policies and practices, perform risk assessments, monitor ongoing compliance in coordination with other compliance and operational assessment functions, and oversee the intersection of privacy and data security in collaboration with the information security team.
  • Counsel marketing and innovation teams on privacy implications for new products and features, including in the areas of online advertising, mobile, social, and communications.
  • Advise on privacy issues related to mobile applications, behavioral advertising, social networking and marketing, email, SMS/text, and telephone marketing, spyware, adware, affiliate marketing, location-based services, tracking technologies, etc.
  • Participate as leader in the Global Legal Department sharing best practices, knowledge and resources across the internal community.

KEY RESPONSIBILITIES

  • Provide proactive strategic leadership and guidance on privacy and data security issues across global legal and compliance teams to drive partnership, knowledge-sharing and efficiency.
  • Advise on compliance and best practices across all aspects of global privacy and data protection law and regulation, including consumer data use and sharing, behavioral advertising and analytics, data retention, data security and data breaches.
  • Support company engagement with government, industry, and consumer groups on privacy issues.
  • Advise on potential business impact of proposed changes to U.S. and international privacy and data security laws and regulations. Review collection, use and transfers of user data and draft privacy policies and disclosures.
  • Provide strategic expertise and partnership to Gap Inc.'s commercial, advertising and employment legal teams on a wide range of data protection and other global privacy matters.
  • Provide strategic expertise and partnership to Gap Inc.'s commercial, advertising and employment legal teams on a wide range of data protection and other global privacy matters.
  • Creatively build upon and drive awareness around privacy and data security issues, including developing and delivering training.
  • Lead data incident response preparedness, including evolving and practicing the Company's data incident response plan.
  • Oversee Information and Records management including alignment with privacy and security policies.
  • Provide strategic direction and leadership to team and build strong talent and capability aligned to achieve strategic objectives.
  • Ensure teams follow established strategies and deliver on goals and objectives.

TWO FOLSOM

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KEY EXPERIENCES

  • Juris Doctor or LLM from an accredited law school
  • Licensed to practice law in the U.S.
  • Minimum 12+ years' experience, preferably in a corporate legal department, with substantial focus on consumer and employee privacy and data security legal and compliance issues.
  • Experience building and/or leading corporate privacy and data security program.
  • Demonstrated collaboration skills including building strong business partnerships along with achieving results.
  • Experience with online, mobile, social networking and digital technology issues.
  • CIPP strongly preferred.
  • Technical/systems background a plus.
  • Experience effectively leading, managing and developing team.
  • Demonstrated collaboration skills including building strong business partnerships along with achieving results.
  • Strong interpersonal and team-building skills
  • Ability to work independently and cross-functionally
  • Strong organizational skills and ability to prioritize and to juggle multiple tasks
  • Ability to influence beyond authority in a complex and matrixed organization
  • Desire and ability to work in a fast-paced and challenging environment
  • Flexibility and a positive attitude
  • Strong speaking, writing and negotiating skills
  • Support an inclusive work environment

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