Senior Legal Counsel – Director, Privacy, Digital Products & AI Governance

This is a fully remote position, open to applicants in United States.

📋 Description

• Act as the primary legal advisor for privacy and consumer information issues throughout the digital consumer experience, from prequalification to contract initiation.

• Provide counsel on the acquisition, utilization, and distribution of consumer information, covering FCRA permissible purposes, authorizations, fraud prevention, notifications, and consents.

• Assess and select vendor products and data solutions that incorporate consumer-report or other FCRA-governed information.

• Offer legal insights on consumer-facing digital communications, credit marketing, TILA and Regulation Z obligations, digital disclosures, and adverse action notifications.

• Collaborate with Product, Engineering, Marketing, Compliance, and origination legal teams on marketplace capabilities.

• Function as the main privacy and information security legal advisor for Marketing, Engineering, and business teams from product conception to launch.

• Analyze federal and state privacy regulations, including GLBA and FCRA, and provide practical, risk-based advice.

• Assist in privacy operations, encompassing risk and impact analyses, privacy rights requests, data retention, and data minimization.

• Draft and negotiate data protection agreements, data usage restrictions, audit rights, and security provisions.

• Lead the legal strategy for data breaches and cybersecurity incidents, addressing privilege, notification, and regulatory engagement.

• Keep legal and business leadership updated on privacy, security, and emerging risks.

• Support the enterprise AI governance framework, including policies, standards, risk classifications, and the AI inventory.

• Design and oversee processes for reviewing and approving AI tools and systems.

• Draft and negotiate privacy and acceptable AI usage terms in dealer, technology, and vendor agreements.

• Counsel on dealer and consumer disclosures when AI tools influence shopper experiences or dealer interactions.

• Manage the legal framework for AI training data, model documentation, and data retention according to the NIST AI Risk Management Framework.

• Monitor AI regulations and agency guidance in collaboration with Government Relations.

• Advise on AI's impact on credit, fraud, or funding decisions, including ECOA/Regulation B, fair lending, model governance, explainability, and adverse action considerations.

• Ensure compliance with company policies, procedures, and legal standards.

• Execute other assigned responsibilities.

⛳️ Requirements

• J.D. and active membership in good standing in at least one U.S. state bar, with the capability to register as in-house counsel where necessary.

• Over 8 years of legal practice in the U.S.

• Experience serving as product counsel for a consumer-facing digital platform or marketplace, including the launch of new products, categories, or marketplaces.

• Extensive knowledge of U.S. federal and state privacy and data protection laws.

• Significant experience in operating and/or establishing a privacy program.

• Strong understanding of the NIST AI Risk Management Framework and emerging U.S. federal and state AI legislation.

• Practical experience in advising on AI products and developing AI governance, including AI risk assessments, inventories, policies, or impact analyses.

• Proficiency in drafting consumer notices, consents, and terms of use, as well as negotiating data protection agreements.

• Capability to utilize AI-enabled legal tools responsibly and effectively.

• Knowledge of operational privacy and data governance programs, including risk and impact assessments, privacy rights requests, data retention, data minimization, and incident response.

• Expertise in drafting and negotiating data protection agreements, privacy exhibits, data-use limitations, audit rights, security provisions, and technology agreements.

• Ability to structure and advise on marketplace legal frameworks, including consumer terms of use, shopper accounts, dealer participation terms, lead-sharing and data-sharing agreements, and technology, licensing, and partnership agreements.

• Strong product counseling capabilities.

• Expertise in artificial intelligence products, responsible data usage, AI governance, risk assessments, inventories, policies, and impact analyses.

• Exceptional skills in issue identification, legal judgment, problem-solving, negotiation, and decision-making.

• Ability to lead cross-functional initiatives, influence stakeholders, manage competing priorities, and collaborate with both internal and external legal and technical experts.

• Preferred: experience in online automotive retail, an automotive marketplace, or auto financing.

• Preferred: knowledge of ECOA/Regulation B, TCPA, UDAAP, TILA/Regulation Z, and FCRA.

• Preferred: technical proficiency in software development, data architecture, cybersecurity, or machine learning systems.

• Preferred: considerable in-house experience at a technology, marketplace, e-commerce, or consumer financial services company.

• Preferred: ISO/IEC 42001 training.

• Preferred: experience engaging with regulators, industry groups, or standards organizations.

• Preferred: CIPP/US, CIPM, or AIGP certification.

• Must be legally authorized to work for Credit Acceptance without current or future sponsorship.

🏝️ Benefits

• Annual bonus plan.

• 401(K) match.

• Adoption assistance.

• Parental leave.

• Tuition reimbursement.

• Comprehensive medical, dental, and vision coverage.

• Nonstandard benefits.

• Commitment to an inclusive workplace and being an Equal Opportunity Employer.