Assistant General Counsel, EU Data Privacy

Job Overview We are seeking an experienced attorney to be a member of our data privacy and digital regulatory legal practice focused on the EU region but with responsibilities outside the region as well providing strategic counsel across business segments and corporate functions. The position carries both strategic and operational weight: shaping enterprise policy while managing day‑to‑day legal risk where compliance failures can trigger regulatory enforcement, loss of customer trust, or disruption to business operations. The role partners closely with functional and business teams to embed legal and compliance considerations into internal systems, product development, incident response, and business operations. This position has no direct reports but operates at an executive level in the Law Department with significant influence on legal and business strategy. You will report directly to our VP & GC Data Privacy, and you’ll work out of our Bracknell UK location on a hybrid work schedule. 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 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. Benefits of Working For Honeywell In addition to a competitive salary, leading‑edge work, and developing solutions side‑by‑side with dedicated experts in their fields, Honeywell employees are eligible for a comprehensive benefits package. This package includes employer subsidized Medical, Dental, Vision, and Life Insurance; Short‑Term and Long‑Term Disability; 401(k) match, Flexible Spending Accounts, Health Savings Accounts, EAP, and Educational Assistance; Parental Leave; Paid Time Off (for vacation, personal business, sick time, and parental leave), and 12 Paid Holidays. Pay Equity The annual base salary range for this position is $242,000 – $302,000. Honeywell considers various factors when extending an offer, including but not limited to the scope and responsibilities of the position, the candidate’s work experience, education and training, key skills, as well as market and business considerations. 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. #J-18808-Ljbffr