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

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🇺🇸 United States – Remote

💵 $225.8k - $263.4k / year

⏰ Full Time

🟠 Senior

⚖️ Legal Counsel / General Counsel

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Credit Acceptance

WebsiteLinkedInAll Job Openings

1001 - 5000 employees

Founded 1972

💸 Finance

💳 Fintech

🚘 Automotive

Finance • Fintech • Automotive

Credit Acceptance is a company that specializes in providing auto financing solutions to individuals, including those with bad credit history or no credit history at all. With over 50 years of experience, Credit Acceptance has helped more than 4 million consumers secure financing for vehicle purchases. The company operates a network of over 15,000 dealers and offers customers the ability to pre-qualify for auto financing, which does not impact their credit score. Furthermore, Credit Acceptance provides educational resources and tools, such as payment and auto price calculators, to assist customers in managing their finances and understanding their credit options. The company's mission is to drive possibility by offering financial solutions that give individuals the opportunity to improve their financial situation and secure reliable transportation.

📋 Description

• Serve as lead legal counsel for privacy and consumer-information matters across the digital consumer journey from prequalification through contract origination • Advise on acquisition, use, and sharing of consumer information, including FCRA permissible purpose, authorizations, fraud prevention, notices, and consents • Evaluate and select vendor products and data solutions using consumer-report or other FCRA-governed information • Provide legal guidance on consumer-facing digital communications, credit advertising, TILA and Regulation Z requirements, digital disclosures, and adverse-action communications • Partner with Product, Engineering, Marketing, Compliance, and origination counsel on marketplace capabilities • Serve as primary privacy and information security counsel to Marketing, Engineering, and business teams from product design through launch • Interpret federal and state privacy laws, including GLBA and FCRA, and provide practical risk-based guidance • Support privacy operations, including risk and impact assessments, privacy rights requests, data retention, and data minimization • Draft and negotiate data protection agreements, data-use restrictions, audit rights, and security schedules • Lead legal strategy for data breaches and cyber incidents, including privilege, notification, and regulator engagement • Keep legal and business leadership informed about privacy, security, and emerging risks • Support the enterprise AI governance framework, including policies, standards, risk classification, and the AI inventory • Design and maintain intake and assessment processes for reviewing and approving AI tools and systems • Draft and negotiate privacy and acceptable AI-use terms in dealer, technology, and vendor agreements • Advise on dealer and consumer disclosures when AI tools affect shopper experiences or dealer engagement • Own the legal framework for AI training data, model documentation, and data retention using the NIST AI Risk Management Framework • Track AI regulation and agency guidance with Government Relations • Advise on AI affecting credit, fraud, or funding decisions, including ECOA/Regulation B, fair lending, model governance, explainability, and adverse-action considerations • Remain compliant with company policies, processes, and legal guidelines • Perform other duties as assigned

🎯 Requirements

• J.D. and active membership in good standing in at least one U.S. state bar, with the ability to register as in-house counsel where required • 8+ years of U.S. legal practice • Experience as product counsel for a consumer-facing digital platform or marketplace, including launching new products, categories, or marketplaces • Deep working knowledge of U.S. federal and state privacy and data protection law • Significant experience operating and/or building a privacy program • Strong knowledge of the NIST AI Risk Management Framework and emerging U.S. federal and state AI laws • Hands-on experience advising on AI products and building AI governance, including AI risk assessments, inventories, policies, or impact analyses • Experience drafting consumer notices, consents, and terms of use, and negotiating data protection agreements • Ability to use 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 restrictions, audit rights, security schedules, and technology agreements • Ability to structure and advise on marketplace legal architecture, including consumer terms of use, shopper accounts, dealer participation terms, lead-sharing and data-sharing arrangements, and technology, licensing, and partnership agreements • Strong product-counseling skills • Expertise in artificial intelligence products, responsible data use, AI governance, risk assessments, inventories, policies, and impact analyses • Strong issue-spotting, legal judgment, problem-solving, negotiation, and decision-making skills • Ability to lead cross-functional initiatives, influence stakeholders, manage competing priorities, and collaborate with internal and external legal and technical experts • Preferred: experience in online automotive retail, an automotive marketplace, or auto finance • Preferred: knowledge of ECOA/Regulation B, TCPA, UDAAP, TILA/Regulation Z, and FCRA • Preferred: technical fluency in software development, data architecture, cybersecurity, or machine-learning systems • Preferred: significant 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 bodies • 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 benefits • Nonstandard benefits • Inclusive workplace and Equal Opportunity Employer

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