Associate General Counsel - Privacy Officer

7 days left

Minneapolis, Minnesota
May 10, 2022
Jun 03, 2022
Employment Status
Full Time
Health Care that Starts with You!

Join a truly mission-driven organization! Independent, nonprofit UCare is recognized as one of the Minnesota's leading health plans. We provide more than 600,000 members across Minnesota and western Wisconsin with the health coverage plans and services they need to maintain and improve their health. The innovative coverage we create makes a difference for Medicare-eligible individuals, individuals and families enrolled in Minnesota Health Care Programs, such as MinnesotaCare and Medical Assistance, and disabled adults with special health care needs.

UCare is growing in size, membership, products, geographic coverage, and employees. We're an organization that's going places. Be part of a team that cares about you, be part of UCare.


Enter a highly collaborative environment where people are truly engaged, and feedback is valued. You'll enjoy a competitive salary and benefits, as well as a host of other perks, including a nationally recognized wellness program, and a bright, open, award-winning office space in Northeast Minneapolis just minutes from major freeways and retail centers.

At UCare, we welcome and employ a diverse employee group committed to meeting the needs of UCare, our members, and the communities we serve.




UCare offers Medicare, Medicaid, Individual and Family health plans - powered by the hardest working people in the industry. Our people powered teams de-complicate, advocate and always go the extra mile to help our members. We serve with integrity, compassion and commitment to do right by members, providers and government partners. Above all, we come to work excited to provide members a path for the best health of their lives.


Working at UCare is more than a career; it's a mission. A mission that defines us as professionals, unites us as an organization and shapes how we interact with our members and each other. Employees join UCare and stay because of the opportunity to have a purpose-driven job.

Our strong culture has established UCare as a Star Tribune Top 150 Workplace for 12 consecutive years since the awards program began. It's a culture that embraces innovative ideas, strategic partnerships, and exemplary customer and provider experiences. Working at UCare is being a part of a people powered team dedicated to making a real difference in the lives of our members and communities.


Work Location: Hybrid or Standard

The health and safety of our employees, members, providers, and our community is our highest priority. Therefore, all new employees are expected to be fully vaccinated against COVID-19 prior to starting at UCare, subject to limited exceptions such as for a sincerely held religious belief or for medical reasons.

Position Description

As the Associate General Counsel - Privacy Officer, this position is responsible for providing sound and critical legal advice to internal stakeholders regarding matters related to information privacy and security and civil rights to ensure compliance with applicable laws, regulations, and policies. You will also collaborate with business stakeholders to assess and reduce legal risks from potential procedural or technology changes that affect privacy. You will conduct privacy risk assessments focused on specific business processes or applications to identify and suggest prioritization of privacy risk treatment for the organization and determine how to maintain and improve adherence to regulatory requirements and corporate policies. You will lead and manage breach responses on behalf of UCare and serve as the main point of contact with outside counsel. You will also manage, and serve as the organization's subject matter expert, regarding practices and issues related to record retention, litigation holds, discovery, data requests, and Business Associate relationships. In this role, you will assist with drafting and negotiating contractual terms or agreements related to data sharing and information privacy. This role also serves as the organization's Civil Rights Coordinator and co-chair of the Privacy and Data Security Committee in partnership with the Information Security Officer.

• Understand state and federal regulations and contractual requirements related to UCare's business from an information privacy and security and civil rights framework.

• Maintain, develop and implement UCare's Privacy Program and the resulting privacy policies, procedures and documentation for the processing and handling of personal data (with a focus on Protected Health Information) in coordination with appropriate members of the organization.

• Provide legal advice on data privacy and security laws and regulations with emphasis on the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the Health Information Technology for Economic and Clinical Health Act (HITECH), state privacy laws including, but not limited to, Minnesota Health Records Act and Minnesota Government Data Practices Act, and all other related rules and regulations.

• Provide legal advice and support to internal stakeholders regarding matters related to civil rights and non-discrimination in health care under Section 1557 of Affordable Act and other applicable civil rights laws including evaluating risks associated with various business strategies and initiatives.

• Monitor continuous adherence to the Privacy Program's requirements and lead appropriate corrective action to address privacy issues as necessary. Ensure that business units, technology teams and third parties (service providers) follow UCare's Privacy Program, implement monitoring to verify the extent to which these stakeholders meet privacy policy requirements and address privacy concerns.

• Provide statutory/regulatory interpretation of privacy and security laws, as well as civil rights laws and review proposed legislation affecting UCare's operations to identify implementation challenges and assist the implementation team with interpretation of final bill/regulation language.

• Conduct legal research, draft legal memoranda and other legal correspondence, as needed.

• Develop and manage litigation hold procedures, and review, respond to, and oversee discovery requests, subpoenas, and other external requests for confidential information.

• Provide legal support to Procurement, Vendor Management, and the Information Security team to ensure that third-party suppliers' contracts and operating-level agreements meet privacy requirements including assisting with negotiations of data privacy and security provisions in internal and 3rd party contracts/agreements.

• Manage and oversee UCare's compliance with legal requirements related to Business Associates including maintaining and updating UCare's Business Associate Agreement template, ensuring the appropriate mechanisms are in place for identifying Business Associates and reviewing and advising on proposed modifications to Business Associate Agreements that may arise during contract negotiations.

• Lead the organization's response to privacy-related incidents, emergencies and other issues or events including the engagement and management of outside counsel.

• Develop, improve, implement, and manage the privacy impact assessment process, and conduct risk assessments to determine the organization's specific privacy-related legal requirements and potential vulnerabilities.

• Report privacy matters and metrics in a transparent and business-relevant manner to the Deputy General Counsel, Chief Compliance & Ethics Officer and members of the Compliance Oversight Committee and Privacy & Data Security Sub-Committee, allowing the business to make informed decisions on adequate and appropriate mitigating measures.

• Manage the organization's record retention program to facilitate deletion or anonymization of personal data that is no longer needed for identified purpose(s), and in accordance with applicable requirements.

• Collaborate with the Information Security Officer to establish effective information privacy and security processes, review potential privacy and security issues associated with new technology, and address data incidents and breaches, including prevention, impact mitigation and management of breaches.

• Oversee the annual privacy awareness campaigns and trainings for all employees, such as New Employee Privacy Training, and specialized training (e.g., Social Media, Marketing).

• Serve as the organization's liaison with key regulators (e.g., OCR, DHS) on all privacy matters.

• Serve as UCare's Civil Rights Coordinator, coordinating efforts to comply with and implement UCare's responsibilities under Section 1557 of the Affordable Care Act (ACA), including ensuring that UCare appropriately investigates and handles grievances in accordance with Section 1557.

• Direct and supervise Privacy staff in managing workload, assigning tasks, development and oversight of staffing training, development plans, monitoring performance and coaching employee(s).

• Other projects and duties as assigned.


Juris Doctorate (J.D.) from an accredited law school. Licensed in good standing to practice law in the State of Minnesota or be eligible for membership in the Minnesota Bar.

One or more of the following certifications/designations is preferred: Certified in Healthcare Privacy Compliance (CHPC), Certified in Healthcare Compliance (CHC), Certified Information Privacy Professional (CIPP), Certified Information Privacy Management (CIPM), or Certified Information Privacy Technologist (CIPT).

Required Experience

At least five years of progressively more responsible experience in health care compliance or law or related activities; state or federal regulatory or managed care compliance or law, information privacy laws and practices and internal controls auditing and monitoring. Demonstrated ability to work effective across departments or divisions within an organization. Experience supervising staff.

Preferred Experience

Experience with Medicare and Medicaid managed care programs. Experience working with delegated entities.


The UCare difference is our people power - employees actively working on the behalf of our members to get them access to the health care they need. We value and respect each individual's ideas and contributions, and provide the freedom to grow both personally and professionally. We are centrally located, and offer onsite education, equipment and wellness resources, and a myriad of volunteer activities. If you're looking for an inclusive environment that celebrates your people power, helps you build on your strengths and gives you the opportunity to truly make a difference, we invite you to apply.

As an Equal Opportunity/Affirmative Action Employer, we welcome and employ a diverse employee group committed to meeting the needs of UCare, our members, and the communities we serve.

JOB POST DATE: 05/09/2022

Similar jobs

More searches like this

Similar jobs