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