Local Privacy Officer Italy

Job Title: Local Privacy Officer Italy

Location: Milano, Italy

About the job

As a Local Privacy Officer (LPO), you will be a strategic business partner responsible for protecting data subjects rights and freedoms, enabling data-driven innovation within Sanofi and maximizing business opportunities. You will lead the implementation of the Privacy operating model, balancing robust data protection with business growth opportunities in an increasingly complex privacy landscape. This role requires you to address critical privacy risk areas, implement privacy maturity at all levels of the company, generate trust and transparency while enabling the business to deliver according to its objectives.

Acting as a force of proposal you'll have to proactively contribute to a robust data governance while having a thoughtful risk-based approach. You will manage local privacy initiatives while contributing to global and regional projects, ensuring compliance with evolving privacy regulations and championing privacy-by-design principles in an increasingly AI-driven environment.

Key Accountability

Prevent Privacy Risks

• Develop and maintain a comprehensive local privacy risk assessment framework that addresses business maturity and ownership, and promotes the effective implementation of the privacy operating model among leadership team members and key stakeholders
• Understand, map and become familiar with business strategy and activities to proactively support their deployment while mitigating privacy risks
• Appoint and lead the Local Privacy champions' network to implement in a proactive way privacy strategy and priorities
• Monitor and analyze local privacy regulations, AI regulatory developments, and enforcement trends and document & implement local variations of global procedures when required by local laws
• Contribute to global position papers, develop and maintain external network with public authorities and other privacy networks, represent Sanofi in industry advocacy efforts to enhance transparency and build trust with internal and external stakeholders
• Actively contribute to transformation initiatives impacting both the business the privacy operating model
• Implement privacy-by-design principles in both local and global projects, with a focus on emerging technologies, innovation, data security and data democratization
• In accordance with the Global Privacy maturity framework, provide periodic reports to map existing and emerging privacy risks
• Provide periodic reports to the Italy Leadership Team to map existing and emerging privacy risks, in accordance with the Global Privacy maturity framework
• Adapt global privacy templates and procedures to local requirements while maintaining consistency, including vendor management due diligence, oversight and monitoring
• Monitor and assess data sovereignty regulatory developments across jurisdictions relevant to Italy, including cross-border transfer requirements, and escalate identified risks to the relevant governance bodies
• Implement and promote Data Sovereignty by Design principles in local and regional projects, ensuring that data sovereignty risk screening is integrated into business transition and transformation design processes, in alignment with the Data Compass framework and the data transfer compliance routes
• Monitor and analyze AI regulatory developments, including the EU AI Act, and their intersection with data protection law (GDPR), to proactively identify and mitigate privacy risks arising from AI systems, automated decision-making (ADM), and profiling activities deployed locally or globally impacting data subjects in Italy
• Integrate AI and ADM risk considerations into the local privacy risk assessment framework, ensuring that high-risk AI systems and profiling activities are subject to appropriate Data Protection Impact Assessments (DPIAs) and, where required, prior consultation with the Garante per la protezione dei dati personali

Protect Fundamental Rights and Sanofi's Interests

• Oversee the mapping and maintenance of local personal data processing activities, and ensuring transparency and effectiveness in data handling practices

• Perform, review and validate accuracy of local privacy, assets and vendors assessments to protect individual rights and freedoms and to protect Sanofi's liability, reputation and license to operate

• Manage data subject rights requests and personal data breaches promptly and effectively to maintain trust and prevent business issues and disruptions

• Develop and deliver targeted privacy training and awareness programs to increase business maturity and ownership of relevant stakeholders and staff

• Proactive escalation of privacy risks to the relevant governing bodies to incorporate new developments and expectations in both privacy operating model and business operations

• Serve as the primary liaison with local Data Supervisory Authorities, demonstrating business maturity in privacy compliance

• Coordinate privacy audits and dawn raid responses, ensuring data security measures are properly implemented and documented

• Dedicate significant part of the activities to global and regional projects, working groups, processing activities and privacy assessments to support both the Global privacy operating model and global and regional business

• Ensure that cross-border personal data transfers involving Italy-based operations comply with applicable data sovereignty regulations, including GDPR adequacy and transfer mechanisms (BCRs, IGTA), and that any transfer involving countries of concern under Data Sovereignty Programs is identified, assessed and escalated to the relevant governance body

• Contribute to the Know Your Data initiative by maintaining an accurate mapping of data flows involving Italy-based personal data, including health data, HCP data, and R&D data, and ensuring these flows are covered by appropriate legal bases and transfer mechanisms

• Perform and oversee privacy risk assessments for AI systems, automated decision-making processes, and profiling activities, ensuring compliance with applicable legal and regulatory frameworks, and anticipating emerging risks, and that data subjects' rights are effectively protected

• Ensure that individuals subject to automated decision-making or profiling by Sanofi are provided with meaningful information, and that appropriate human oversight mechanisms are in place, particularly for decisions producing significant effects on data subjects (e.g., in HR, commercial, or clinical contexts)

Enable Trustworthy Innovation

• Proactively partner with Global and Local Process Owners and Digital teams to integrate privacy considerations into new initiatives, especially those involving data democratization, innovation, AI innovation and business transformation

• Privacy to be source of value propositions also through effective privacy-by-design approach, technological innovation with ethics and integrity, thoughtful risk-based & aligned with the decision operating model and the risk continuum framework (i.e. DAI model)

• Ensure the protection of individual risks & freedoms while maximizing business opportunities AI, advanced analytics and while maximizing business opportunities through a Thoughtful Risk-based approach

• Generate trust and transparency while enabling the business to deliver according to its objectives

• Demonstrate agility and develop mature skills to perform privacy roles and responsibilities in an evolutive and uncertain business environment

• Report on privacy program KPIs and demonstrate the business impact of privacy initiatives in supporting innovation and transformation

• Support the deployment of Sanofi's Data Compass framework locally, enabling compliant cross-border data transfer that sustains Sanofi activities and AI development, while minimizing business disruption and regulatory exposure

• Actively contribute to industry advocacy and regulatory monitoring efforts on data sovereignty topics, helping shape rules that support pharmaceutical innovation and protect Sanofi's ability to serve patients globally

• Champion responsible and privacy-preserving AI practices within the Italy affiliate, embedding privacy-by-design and ethics-by-design principles into AI development and deployment pipelines, and ensuring that AI innovation is conducted in full compliance with applicable legal and regulatory frameworks, and Sanofi's internal AI governance framework

• Serve as a trusted advisor to business and digital teams on the privacy implications of AI, machine learning, profiling, and automated decision-making use cases, enabling innovation while safeguarding data subjects' rights and Sanofi's reputation

Key Working Relationships

Internal

• Be part of Italy leadership teams and ensure close partnership with EBI and Legal teams to be voice of Privacy and ensure that the Prevent-Protect-Enable is effectively understood & in place and in use

• Influence senior stakeholders including General Management, Digital, HR, R&D, and Commercial teams to embed privacy considerations in transformation initiatives

• Collaborate with and guide local privacy champions across departments to increase business maturity and ownership of privacy

• Manage and develop a network of external Local Privacy Officers to deliver according to the local legal requirements and business expectations

• Ensure One voice with the LEBI&GS team

• Participate in Global Privacy Committee meetings and working groups focused on data democratization and innovation

• Partner with global teams on cross-functional privacy initiatives to ensure that data security is integrated with privacy controls

External

• Establish and maintain relationships with local Data Protection Authorities to build transparency and trust

• Represent Sanofi in local privacy and trade associations to influence privacy standards that support innovation

• Engage with external partners and vendors on privacy-related matters, implementing robust vendor management practices

• Act as an advocate for privacy rights of external data subjects (candidates, consumers, patients) while enabling data democratization initiatives

About You

Experience

• Prior experience in Healthcare/Life science sector is an advantage

• Experience working in highly regulated environments, preferably in project and/or compliance management

• In-depth knowledge of data privacy and AI regulations

• Experience working in an international environment

Soft Skills

• Multi-stakeholder management based on influence rather than formal relationships

• Excellent communication, negotiation, writing and advisory skills

• Ability to balance legal/company requirements and business enablement

• Willingness to travel

Technical Skills

•       CIPP/E, CIPM, AIGP or similar privacy qualification

Education

•       Master's or bachelor's degree (law or computer sciences is an advantage)

Languages

•       Strong English and Italian skills (verbal and written), ability to exchange fluently in a global environment

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