Sr. Counsel – Cybersecurity & Data Privacy

Job Description:

Building trusted markets — powered by our people.

At Cboe Global Markets, we inspire our people to solve complex challenges together because what we do matters. We provide the financial infrastructure that powers the global economy. As a leading provider of market infrastructure and tradable products, Cboe delivers cutting-edge trading, clearing and investment solutions to market participants around the world.

We’re building inclusive ways to support professional and personal development while strengthening the trust we’ve earned as a global market leader. Our teams are empowered to share ideas, actively pursue them and bring on a challenge. As champions of internal mobility and access to opportunity, we encourage our people to “go for it” and equip our managers with the training to coach their teams to the next level. We strive to provide employees a safe space to network, share ideas and create opportunities.

Cboe is seeking a Senior Counsel to provide legal support to all levels of the organization on legal, regulatory, and reputational aspects of cybersecurity, data protection and privacy, artificial intelligence, and intellectual property, including current and emerging legal and regulatory requirements and trends, compliance initiatives, and cyber and data-related investigations.  As an operator of exchanges and other trading venues, Cboe operates in a highly regulated environment and compliance by Cboe with its legal and regulatory obligations is paramount in the conduct of its business.  This position will also support Cboe’s Compliance group on oversight of other emerging compliance risks, such as sanctions and trade controls, AML and FCPA compliance, as well as other regulatory frameworks applicable to global exchange operators. In fulfilling these duties, this position will also collaborate with and manage outside counsel and other experts as necessary.  Further, depending on the division’s needs and the individual’s interests, the position may also provide the opportunity to gain experience in other legal areas relating to Cboe’s diverse businesses. This position is in Chicago, Illinois.

Duties and Responsibilities:

Perform a combination of the following functions.  Particular day-to-day functions may vary among certain of the following functions depending upon priorities at that time.

• Work collaboratively across the organization to provide legal support for the cybersecurity, data protection, and artificial intelligence programs (including legal support for regulatory and audit functions, as needed), and establish appropriate relationships with responsible members of relevant departments, such as Risk, Information Security, Marketing and Communications (MarComms) and Compliance, to ensure coordinated and appropriate responses to incidents, issues, and opportunities related to cybersecurity, data protection, and artificial intelligence.
• Consult with senior leadership and Cboe’s Boards of Directors and responsible Committees regarding cybersecurity preparedness and strategy.
• Lead or support legal involvement in incident response for a broad range of circumstances including fraud, insider risk, data breach, availability attacks and other computer security events, etc.  Align and manage processes to preserve privilege.
• Assist with management of outside counsel and other relevant professionals and collaborate with them and Cboe management and associates regarding various cyber and data protection efforts, including compliance with current and emerging legal and regulatory requirements and best practices; risk assessment and management; conducting tabletop exercises with management, Boards and Committees, and other internal departments; preparation for and management of incident response; and compliance with regulatory reporting requirements.
• Collaborate with Cboe’s Risk group, including Cboe’s Chief Information Security Officer, on threat investigations and programs, including participation in Cboe’s enterprise risk management program and insider threat group.
• Maintain fluency with domestic and international cybersecurity, privacy and data protection laws and regulations impacting Cboe as a financial institution. As needed, provide business and risk partners strategic legal counsel that not only meets current requirements, but anticipates changes (to law and/or technology) to better maintain business flexibility and efficiency.
• Provide legal support to Cboe’s incident response program, including with respect to investigating potential incidents, identifying applicable legal obligations, and managing the company’s notification of and response communications to confirmed data security incidents working in collaboration with Cboe’s Risk, Information Security and MarComms departments.
• Provide counsel on co