Howden UK Broking Head of Data Protection

Who are we?

Howden is a global insurance group with employee ownership at its heart. Together, we have pushed the boundaries of insurance. We are united by a shared passion and no-limits mindset, and our strength lies in our ability to collaborate as a powerful international team comprised of 24,000 employees spanning over 56 countries.

People join Howden for many different reasons, but they stay for the same one: our culture. It’s what sets us apart, and the reason our employees have been turning down headhunters for years. Whatever your priorities – work / life balance, career progression, sustainability, volunteering – you’ll find like-minded people driving change at Howden.

Role – Head of Data Protection

Who are we?

Howden is a collective – a group of talented and passionate people all around the world. Together, we have pushed the boundaries of insurance. We are united by a shared passion and no-limits mind-set, and our strength lies in our ability to collaborate as a powerful international team comprised of 24,000 employees spanning over 100 countries.

Our people are our biggest asset as well as our largest shareholder group and are everything that makes us unique; our inclusive culture, the quality service we offer our clients, and our continued growth, all come from our people-first approach. There’s no such thing as individual success. We all need to play our part, contributing our skills and experience to make a true difference. That’s Howden.

Why work at Howden?

We have always been employee-owned and driven by entrepreneurial spirit. Right from the beginning, we've focused on employing talented individuals and empowering them to make a real difference to the company, whilst building successful and fulfilling careers at the same time. Simply put, we hire talented specialists and give them what they need to make a difference for clients. Always have, always will.

People join Howden for many different reasons, but they stay for the same one: our culture. It’s what sets us apart, and the reason our employees have been turning down disappointed head-hunters for years. Whatever your priorities – work/life balance, career progression, sustainability, volunteering – you’ll find like-minded people driving change at Howden.

What is the role?

Head of Data Protection Howden UK Broking and UK Reinsurance shall lead the Data Protection Function that is responsible for developing, implementing, embedding and maintaining a data protection control and oversight framework for Howden’s UK Broking (including its Specialty and Retail Pillars) and UK Reinsurance Divisions. The framework must be pragmatic, risk based and suitably robust to support Howden’s UK Broking and UK Reinsurance entities to meet applicable data protection legislation, including the UK Data Protection Act, but also any other applicable legislation in territories where those entities operate. The framework must also align to and complement Howden Group’s overarching Data Protection framework, governance and policy.

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What will you be doing?

Oversight & Change

- Work closely with Howden UK Broking and UK Reinsurance senior leadership to develop and drive a data protection strategy that is aligned to the operating model and strategies of those businesses, promoting and supporting consistency of approach and application as much as practically possible.
- Develop and maintain an annual Data Protection Plan setting out the resources needed to deliver the projects and activities to be undertaken by the function, which shall be aligned to and support the regulatory expectations and objectives of the Howden UK Broking and UK Reinsurance businesses (which may include their overseas operations).
- Support in developing and maintaining a data protection risk and control framework, including data protection policy, processes, procedures, controls and monitoring.
- Implementing a data protection horizon scanning process, ensuring any new or changing legislation is identified and implemented by expected timeframes.
- Produce reports and escalate data protection updates, risks, issues and compliance performance to the relevant Howden UK Broking and UK Reinsurance governance committees.
- Establish and maintain an effective data protection risk identification and escalation process across all Howden UK Broking and UK Reinsurance businesses, ensuring swift and timely mitigation or management of risks and breaches.
- Develop, maintain and promote the consistent use of data protection tooling.
- Continually raise awareness of data protection and ensure adequate programme of data protection related training to employees.
- Oversee and manage any reporting to and interaction with data protection supervisory authorities, including the Information Commissioner’s Office.
- Ensure that all Howden UK Broking and UK Reinsurance businesses have the correct data protection registrations and licences.
- Support in embedding a data protection by design approach within Howden UK Broking and UK Reinsurance businesses.

Stakeholders

Develop and maintain appropriate working relationships with the following to ensure that data protection issues are identified and proactive provision of appropriate solutions:

- Key senior leadership across the Howden UK Broking and UK Reinsurance businesses to ensure a strong understanding of their current and future strategies, business models and objectives, to proactively pre-empt and recognise the data protection support they will require.
- Key operational and functional heads that are responsible for the development and delivery of operational processes and systems to embed a data protection by design approach and to support swift escalation of risks and concerns.
- Key information security leadership and functions, to ensure a clear understanding of information security processes and controls, and how these dovetail and work alongside data protection controls and risk mitigants.
- Internal Control Function Heads across the first, second and third line of defence, to develop an aligned and complementary risk, control and assurance framework, and to support addressing remedial actions.
- Group Head of Data Protection and wider group data protection functions to support an alignment of approach, ensure consistent upward escalation and reporting and to share best practice and common risks and issues.

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Function responsibilities

To develop, support and maintain a data protection function that is able to achieve the following for Howden’s UK Broking and UK Reinsurance businesses.

- Providing timely and considered advice and guidance on a range of data protection matters relating to Howden’s UK Broking and UK Reinsurance businesses, this will include, but will not be limited to – Marketing, DPIA’s, Subject Rights, Privacy Notices, Data Security.
- Supporting compliance with the UK Data Protection Act, the EU General Data Protection Regulation (GDPR), other Data Protection Laws and the Privacy and Electronic Communications Regulations (PECR).
- Establish processes to monitoring compliance with the EU GDPR and other data protection laws, such as the UK Data Protection Act 2018, our data protection policies, including internal data protection activities, raising awareness of data protection issues, training staff;
- Providing advice on the conduct of and supervising data protection impact assessments (DPIAs);
- Completing a Record of Processing Activities (ROPA) that cover each of the in scope entities within Howden UK Broking and UK Reinsurance.
- Complete annual Data Protection Risk Assessments for Howden UK Broking and UK Reinsurance, ensuring that these are reported to the relevant governing committees, but that they also support and contribute to wider Howden Group Data Protection Risk Assessments and ERICCA.
- Support in the development and on-going reporting of KRI and KCIs that feed into the Howden UK Broking and UK Reinsurance risk management framework and, where relevant, Howden Group risk management framework and ERICCA.
- Having regard to the risk associated with processing operations and taking account of the nature, scope, context and purposes of processing
- Prioritising focus on the more risky activities, e.g. where special category (sensitive) personal data is processed, or where the potential impact on individuals could be damaging;
- Establishing clear points of contact for all BAU data protection queries from Howden’s UK Broking and UK Reinsurance businesses with regard to potential complaints and breaches, ensuring that data subject rights’ requests accurately handled
- Making available data protection resources, policies, procedures, guidance, training material and points of contact information in a way that is easily accessible.

Team management

- Develop and maintain a function with the appropriate blend of skill, experience and knowledge to deliver the data protection support and oversight required by the Howden UK Broking and UK Reinsurance businesses.
- Implement an approach to employee development which enables employees to enhance their data protection, industry and Howden knowledge, experience and skill set.
- Provides visionary leadership by fostering a culture of employee engagement and role modelling, encouraging and rewarding essential behaviours and maintaining a high level of personal and professional confidence
- Manages (resource, motivate, drive, develop and focus) the team to ensure the required standards of performance are met; and that the professional and personal development of all team members increases their capability and effectiveness
- Promotes individual accountability through an ongoing performance management approach that aligns personal performance goals with the functional and wider business goals
- Ensures there are effective succession plans in place and actively develops team members to provide future successors
- Identifies and hires talent
- Manage (resource, motivate, drive, develop and focus) the UK data Protection Function to ensure the required standards of performance are met; and that the professional and personal development of all team members increases their capability and effectiveness
- Actively undertakes personal development to ensure up to date knowledge and understanding of best practice
- Develop and maintain appropriate working relationships with the following to ensure that data protection issues are identified and proactive provision of appropriate solutions:
- Key senior leadership across the Howden UK Broking and UK Reinsurance businesses to ensure a strong understanding of their current and future strategies, business models and objectives, to proactively pre-empt and recognise the data protection support they will require.
- Key operational and functional heads that are responsible for the development and delivery of operational processes and systems to embed a data protection by design approach and to support swift escalation of risks and concerns.
- Key information security leadership and functions, to ensure a clear understanding of information security processes and controls, and how these dovetail and work alongside data protection controls and risk mitigants.
- Internal Control Function Heads across the first, second and third line of defence, to develop an aligned and complementary risk, control and assurance framework, and to support addressing remedial actions.
- Group Head of Data Protection and wider group data protection functions to support an alignment of approach, ensure consistent upward escalation and reporting and to share best practice and common risks and issues.

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What are we looking for?

- Ability to provide risk-based advice.
- Experience in achieving stated objectives involving a diverse set of business partners and leading multifaceted projects.
- Negotiation skills to work effectively with key internal and external partners.
- Client relationship skills to continuously coordinate with controllers and processors while maintaining independence.
- Interpersonal skills to communicate well with a wide-ranging audience, from the Board of Directors to data subjects, from managers to IT staff and lawyers.
- Self-starter with ability to gain required knowledge in wide-ranging environments.
- Experienced within a Data Protection compliance field, to include building, implementing and managing data protection programmes within a sophisticated and enterprise-wide organisation.
- Experience with supporting marketing initiatives and the PECR regulations.
- Experience in handling data subject rights requests.
- Detailed knowledge of UK and European data protection law, and an in-depth knowledge of the GDPR.
- An understanding of technical and operational measures that should be in place to ensure the security of personal data and familiarity with information technologies and data security.
- Experience in compliance monitoring and risk management.
- Experienced in producing and presenting data protection reports to senior governance committees.
- Experienced in developing and delivering data protection training to employees of all levels.
- Financial Services experience preferred.

Compliance & Regulatory Responsibilities

- Compliance with the EU General Data Protection Regulation (GDPR), UK Data Protection Act 2018, other UK data protection / privacy related legislation (such as the Privacy and Electronic Communications Regulations) and ICO guidance related to the tasks of a DPO.

Professional Qualifications

- CIPP/E or Certified Data Protection Practitioner (PC.dp) preferred but not essential

What do we offer in return?

A career that you define.

Our business succeeds by allowing our people to make a mark in the areas they care about most: personal development, volunteering, and fundraising for charity, or creating new insurance products that address society’s greatest challenges.

And we know that separate home and work lives don't really exist. If you're happy and healthy at home, you're more likely to be happy and fulfilled at work – and vice versa. That's why we do our best to support our people in every aspect of their lives.

Diversity and Inclusion

At Howden we value diversity - there is no one Howden ‘personality type’. Instead, we’re looking for individuals who share the same values as us:

- Our successes have all come from someone brave enough to try something new
- We support each other, in the small everyday moments and the bigger challenges
- We are determined to make a positive difference, at work and beyond

We consider our people our chief competitive advantage and as such we treat colleagues, candidates, clients, and business partners with equality, fairness, and respect – regardless of age, disability, race, religion or belief, gender, sexual orientation, marital status, or family circumstances.

Our sustainability promise

We’re on a life-long journey to become an ever-more sustainable group. It's a commitment to taking care of our people and the world we live in, to doing good business, and to making a positive impact wherever we can. Our governance processes, company policies, and review systems are all geared towards our goal of making a positive impact in the world. You can read more about our sustainability work here .

What do we offer in return?

A career that you define. At Howden, we value diversity – there is no one Howden type. Instead, we’re looking for individuals who share the same values as us:

- Our successes have all come from someone brave enough to try something new
- We support each other in the small everyday moments and the bigger challenges
- We are determined to make a positive difference at work and beyond

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Reasonable adjustments

We're committed to providing reasonable accommodations at Howden to ensure that our positions align well with your needs.  Besides the usual adjustments such as software, IT, and office setups, we can also accommodate other changes such as flexible hours* or hybrid working*.

If you're excited by this role but have some doubts about whether it’s the right fit for you, send us your application – if your profile fits the role’s criteria, we will be in touch to assist in helping to get you set up with any reasonable adjustments you may require.

*Not all positions can accommodate changes to working hours or locations. Reach out to your Recruitment Partner if you want to know more.

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