Data Protection Officer

About the Team

The Security Team at TUMO safeguards the organization's digital environment and the personal data of students and staff across its global network, promoting secure-by-design and privacy-by-design principles across its systems and operations.

About the Role

The Data Protection Officer (DPO) provides independent oversight of privacy compliance across TUMO's global network, ensuring consistent data protection standards and verifying that privacy requirements are effectively implemented in the organization's products, systems, and operations. Success in this role requires a strong understanding of the technical controls that support privacy compliance, as well as the ability to collaborate effectively with regulatory authorities, local data protection representatives, and TUMO's Engineering and IT teams.

Reporting and independence

• Reports to the Chief Information Security Officer

• Independence is established by charter: direct and unobstructed access to the CEO and Executive on any data protection matter; no instruction as to the outcome of any assessment, opinion or finding; no penalty or dismissal for performing the tasks of the role; no duty that would determine the purposes or means of processing; an annual report to the Executive in the holder's own name

About you

• Organized, flexible, and able to manage changing priorities.

• Able to defend your position with data protection authorities while being open to changing it when justified

• Able to write clearly so that legal partners can act without further clarification

• Able to explain to engineers what needs to change, why, and how

• Comfortable saying no and explaining your reasoning

• Make evidence-based decisions, challenge assumptions, and remain open to continuous improvement

• Comfortable asking for help when needed

Ideal Experience

• Extensive working knowledge of the EU GDPR and of national divergence in at least two member states

• Previous experience as a Data Protection Officer or working closely with one

• Experience with Data Processing Agreements (DPAs), Joint Controller Agreements, Standard Contractual Clauses (SCCs), and Transfer Impact Assessments, including international transfers to countries without adequacy decisions

• Experience conducting Data Protection Impact Assessments (DPIAs) and other privacy risk assessments

• Experience handling data subject access and erasure requests from start to finish

• Familiarity with at least one non-EU privacy regime (DPDP, APPI, nFADP or comparable)

• Understanding of technical privacy controls, including identity and access management, data residency, logging, data retention and deletion, analytics, tracking technologies, and consent management

• Awareness of the EU AI Act and ISO/IEC 42001 as context

• Experience processing children's data

• Strong written and verbal English. Armenian, French or German is an advantage

Key responsibilities

1. Regulatory scope

Multi-jurisdiction privacy

• Maintain the GDPR baseline across all centers and identify where national law requires more

• Track divergence within the EU, including Germany's TDDDG §25 and the EDPB Guidelines 2/2023 reading of Article 5(3) ePrivacy, and France's Article 82 LIL and CNIL positions on session replay

• Track non-EU regimes where TUMO operates or is preparing to operate: India (DPDP), Japan (APPI), Kazakhstan (data residency), Switzerland (nFADP), Albania, Argentina, the United States, and Armenian data protection law

• Brief the Executive on material legal change and what it costs TUMO

• Apply parental consent thresholds ranging from 13 to 18 by jurisdiction, and anticipate the higher regulatory bar applied to children's data

2. Stakeholders and the network

External data protection counterparts

• Act as point of contact for centre-side DPOs, external data protection coordinators, municipal data protection offices and supervisory authorities

• Support TUMO International's franchise account managers with assessments, privacy policies and partner-facing responses, on timescales that do not hold up contracts

Partner agreements and legal support

• Draft, or contribute to the drafting of, the data protection provisions of franchise and partner agreements alongside TUMO International

• Revise agreements where a centre's own counsel, data protection coordinator or supervisory authority has required changes, and propose the position TUMO should take

• Work with the Head of Legal, who provides legal opinion, participates in negotiation where needed, confirms the legal correctness of privacy policies and website and cookie documentation before issue, and reviews data subject requests from a legal standpoint

• Follow agreed changes through to signature

Franchise

• Advise the franchise network; the role holds no line authority over franchise entities

• Escalate through a defined path to the CISO and Executive where advice is not acted on and residual risk is material

3. Implementation and assurance

Product and platform change

Please note that this role sits in none of the implementation teams and holds no delivery capacity.

• Specify what must change, why, and under which legal provision

• Table it with the owning team - Product Engineering & AI for T360, registration and the AI systems; Data Analytics for learner-data reporting; Communications for franchise and centre websites - with stated urgency and the consequence of not acting

• Agree route and owner in that forum; delivery sequencing rests with respective teams

• Verify independently that each change was made and behaves as specified

• Escalate to the CISO, and to the Executive where the risk warrants it, or when an agreed item implementation does not conform to stated requirements

• Work with Communications on the privacy content of franchise and centre websites, including cookie notices and consent mechanics, before they go live

• Review with Data Analytics what learner data is extracted, aggregated and reported: which fields, at what level, who receives it, and whether any individual-level reporting is justified

Contracts and transfer mechanisms

• Own the data protection substance and negotiating position on Data Processing Agreements, Joint Controller Agreements and Standard Contractual Clauses

• Apply the Article 44-49 transfer chain, including transfers to countries holding no adequacy decision, and conduct Transfer Impact Assessments

Rights, breach and records

• Handle access, erasure and objection requests across centers, including in Armenian, English, French and German

• Own breach assessment and the 72-hour notification decision across more than one supervisory authority

• Maintain the Record of Processing Activities, conduct Data Protection Impact Assessments, and contribute the data protection view to AI Impact Assessments

Training and awareness

• Deliver data protection training and induction, and contribute to the wider awareness program.

Benefits

• Health Insurance and discount on travelers insurance

• Assistance with work permit and opening a bank account if needed

• Extra New Year paid holidays: 3rd, 4th and 5th of January

• 5 days of Personal Leave

• Birthday Leave