Assistant General Counsel, EU Data Privacy

Key Responsibilities 

EU Data Privacy Regulation 

Responsibilities:  

Legal Counsel 

• Provides legal advice to Honeywell SBG and Functional Leadership concerning data privacy and data export/localization laws and regulations that impact Honeywell primarily in the EU including the GDPR, but also encompassing other regional, national and local laws regulating Honeywell’s operations and activities in the areas of cross-border data sharing, new system implementations, new service and product offerings, including cloud-based SaaS, XAAS and PAAS offerings, and the use of emerging technologies like Generative AI and ML 

Privacy Program Development, Implementation and Administration 

• Works as part of a Corporate COE cross-SBG and Functionally to develop, implement, and administer a robust global and sustainable data privacy program to minimize data privacy risk and support Honeywell’s organic growth through product and service offerings that are privacy compliant and build trust in the Company’s brand.  

• Works with the Government Relations team to influence and formulate data privacy, localization, and related laws consistent with Honeywell’s business objectives. 

• Develops and maintains mechanisms to facilitate intragroup and external cross-border data transfers. 

• Develops Honeywell-wide and Function-specific data privacy training programs, including Accelerator modules. 

• Reviews privacy impact assessments and conducts DPIAs for assigned SBGs and Functions. 

• Promotes a culture of high data privacy ethical standards and accountability. 

Human Resources 

• Provides EU data privacy legal support to Human Resources on employee, candidate, contingent worker, and workplace data processing activities, including recruiting, onboarding, performance management, benefits administration, workforce analytics, investigations, employee monitoring, and HR technology implementations. 

• Advises Human Resources on GDPR transparency, lawful basis, retention, access, transfer, and data subject rights requirements for employee personal data, including special category data. 

• Reviews and supports DPIAs, legitimate interest assessments, notices, policies, and procedures for HR processing activities involving sensitive data, monitoring technologies, or new HR systems. 

• Partners with Human Resources, IT, and Compliance teams to manage privacy risks in HR vendor engagements, cross-border HR data transfers, employee investigations, works council consultations, and responses to employee privacy complaints or requests. 

Marketing 

• Along with other COE team members, provides data privacy strategy and leadership for Honeywell’s Marketing and Sales teams, identifying and developing innovative initiatives to improve communication and execution of Honeywell’s Digital Marketing Policy and processes while identifying opportunities to maximize data use. 

• Provides thought leadership for data privacy developments in the Sales and Marketing space including the impact of EU rulings. 

• May conduct PIAs and/or DPIAs on marketing processing activities that involve tracking technologies or new and complex innovative technologies. 

M&A 

• Supports M & A team and SBG GCs on data privacy aspects of mergers, acquisitions, and divestitures from the due diligence phase until successful integration. 

• Continuously improves the COE’s M & A toolkit and integrates lessons learned from transactions. 

Transactional Work and Third-Party Privacy Compliance  

• Supports SBGs on particularly complex or high priority commercial transactions involving data privacy, including participating as needed in difficult negotiations with vendors, customers, channel partners, or other entities regarding data privacy compliance and contract provisions. 

• Drafts and reviews privacy-related template provisions and agreements for global cross-SBG use with goal of standardization, simplification, and integration of best practices, including data processing agreements, privacy statements and notices, and other standard privacy documents. 

• Reviews third party privacy policies, terms of use and other third-party materials for compliance with applicable data privacy laws, regulations, and Honeywell policies/best practices. 

• Conducts and/or reviews data privacy impact assessments or similar analyses of third-party practices. 

Data Subject Requests, Regulator Inquiries, Litigation External Data Requests and Complaints 

• Addresses privacy-related complaints received from third parties. 

• Provides legal support for external and internal investigations into alleged privacy violations. 

• Advises on Data Subject Requests and third-party requests to ensure compliance with applicable privacy laws. 

• Partners with the SBGs as a subject matter expert in privacy-related litigation.  

Digital Regulation and Governance 

• Advise IT and product teams on data governance, including data classification, retention, access controls, and data quality standards across Honeywell's automation products and internal systems. 

• Serve as the lead legal advisor on data rights and obligations under the EU Data Act, including user access rights to co-generated data, data sharing obligations, and restrictions on unfair contractual terms related to data access. 

• Counsel product and commercial teams on data localization and residency requirements across jurisdictions, including emerging requirements in the EU, China, India, and other key markets, and advise on compliant architecture and contractual solutions. 

Critical Skills 

• Established expertise in data privacy law, data governance, and technology regulatory risk, with demonstrated ability to influence senior leadership. 

• Deep working knowledge of GDPR and the EU Data Act. 

• Strong contracting capability for data privacy and data governance terms, including data access and data rights provisions, security addenda, audit rights, and flowdown clauses. 

• Incident response and regulatory engagement experience, including breach notifications, investigations, and interactions with regulators in the EU. 

Qualifications You Must Have 

• J.D. (or equivalent) and admitted to practice law in a jurisdiction in the EU. 

• 10+ years of relevant legal experience, including significant experience advising on data privacy, data governance, and technology matters. 

• Demonstrated ability to synthesize complex issues quickly and communicate clearly to technical and non-technical audiences. 

• Proven subject matter expertise in data privacy law, data governance, and regulatory risk management. 

We Value 

• Prior in-house legal experience in regulated or industrial sectors. 

• Experience with global data privacy and data governance regulatory regimes, including the EU Data Act and GDPR. 

• Investigation, litigation, or regulatory compliance experience in data privacy and digital regulation. 

• Strong, independent leadership and the ability to set strategic direction and execute in a matrixed organization. 

ABOUT HONEYWELL 

Honeywell International Inc. (Nasdaq: HON) invents and commercializes technologies that address some of the world's most critical challenges around energy, safety, security, air travel, productivity, and global urbanization. We are a leading software-industrial company committed to introducing state of the art technology solutions to improve efficiency, productivity, sustainability, and safety in high growth businesses in broad-based, attractive industrial end markets. Our products and solutions enable a safer, more comfortable, and more productive world, enhancing the quality of life of people around the globe. Learn more about Honeywell: click here. 

THE BUSINESS UNIT 

The Corporate Strategic Business Group (CORP SBG) at Honeywell is a division focused on corporate-level functions and initiatives that support the overall operations and strategy of the company. It is responsible for overseeing areas such as finance, legal, human resources, communications, and corporate governance, working closely with other business units and SBGs to ensure alignment and coordination across the organization. The CORP SBG plays a crucial role in the overall strategic direction and management of Honeywell's corporate functions and operations, supporting the company's business objectives. 

Honeywell is an equal opportunity employer. Qualified applicants will be considered without regard to age, race, creed, color, national origin, ancestry, marital status, affectional or sexual orientation, gender identity or expression, disability, nationality, sex, religion, or veteran status. Learn more about inclusion and diversity: click here