DIRECTOR or SENIOR DIRECTOR OF COMPLIANCE

Position Summary

This position may have director level oversight for the design, implementation and management of Seminole’s NERC Regulatory compliance, information governance, ethics, corporate health and safety, corporate training and related programs. Includes responsibility for programs to monitor, implement, and achieve compliance with federal and regional electric system reliability standards, including Federal Energy Regulatory Commission (FERC), North American Electric Reliability Council (NERC), and Florida Reliability Coordinating Council (FRCC). This position will report to the Executive VP Chief Legal Officer and Chief Compliance Officer.

Essential Functions

• Coordinates daily activities related to information governance, corporate training and reliability standards compliance, including supervision of information governance and compliance teams.
• Provides a safe and productive work environment for team members congruent with Seminole’s desired culture and in full support of Seminole’s purpose, core values, core competencies and organizational goals.
• Maintains knowledge of current and future regulatory requirements and assesses their impact on Seminole.
• Interprets new and existing regulations in consultation with legal and other subject matter experts to determine applicability.
• Led a centralized Reliability Standards Compliance monitoring and reporting program to assure Seminole's auditable compliance with FERC, NERC & FRCC standards as well as FERC Standards of Conduct.
• Manages complex compliance assessments, documents compliance status, and makes recommendations on corrective action required to achieve compliance with NERC Reliability Standards.
• Manages corporate activities during all NERC reliability standards compliance monitoring functions including on-site audits, spot checks, and self-certifications.
• Participates in industry forums and committees to improve overall compliance with NERC and FERC requirements.
• Ensures Seminole is complying with all compliance guidelines and regulations set forth by regulatory agencies.

Regulatory Compliance

• Communicates with the NERC Compliance internal team, subject matter experts and outside consultants regarding NERC Reliability Standards.
• Carefully coordinates and submits mandatory filings for federal, state, and local regulatory agencies.
• Carefully coordinates established balloting process for new and revised NERC Reliability Standards.
• Carefully coordinates regulatory audit preparation activities to include preparation, critique, and validation of relevant reliability standard audit worksheets (RSAW's) and periodic updates.
• Carefully coordinates the storage of required NERC compliance documentation and evidence to ensure the material is available and follows BES Cyber System Information requirements.
• Develops and maintains Seminole’s Vulnerability Risk Assessments (VRA) and Emergency Recovery Plan (ERP) as required by the Rural Utilities Service (RUS).
• Develops effective action plans and coordinates multiple activities in a timely and efficient manner.
• Develops internal processes and controls to achieve and sustain compliance with applicable NERC Reliability Standards (CIP-004 and CIP-011).
• Maintains knowledge of current and future regulatory requirements and assesses their impact on Seminole.
• Leads a centralized Reliability Standards Compliance monitoring and reporting program to assure Seminole's auditable compliance with FERC, NERC & FRCC standards as well as FERC Standards of Conduct.
• Manages complex compliance assessments, documents compliance status, and makes recommendations on corrective action required to achieve compliance with NERC Reliability Standards.
• Manages corporate activities during all NERC reliability standards compliance monitoring functions including on-site audits, spot checks, and self-certifications.
• Participates in industry forums and committees to improve overall compliance with NERC and FERC requirements.
• Ensures Seminole is complying with all compliance guidelines and regulations set forth by regulatory agencies.

Information Governance and Corporate Training

• Advise various departments on records retention issues related to federal, state, and local laws and regulations.
• Archives historical data/records or ensures their destruction, as necessary.
• Aids in the development and maintenance of relevant training materials for the Internal Compliance Program.
• Aids in the evaluation & preparation of procedural documentation, ongoing monitoring, testing, and remediation.
• Coordinates with management to address potential areas of non-compliance and anticipate future compliance requirements.
• Develops, enhances, and operationalizes enterprise-level privacy policies, processes and controls to mitigate risk and comply with applicable laws and regulations.
• Drafts information governance and compliance related plans, procedures, policies, and practices.
• Ensures compliance with financial, legal or administrative requirements and regulations.
• Ensures data integrity by performing data analysis and identification of anomalies.
• Ensures the regulatory training of all employees and contractors (including HIPAA training).
• Establishes and maintains effective relationships with local industry, regional entities, and internal stakeholders to allow for effective achievement of business goals and compliance with program requirements.
• Evaluates & prepares procedural documentation, ongoing monitoring, testing, and remediation related to compliance.
• Implements and monitors access controls, security controls for records management, and ensures data controls for confidential or protected information (including information protected by CAs/NDAs).
• Implements systematic continuous improvements of compliance policies, procedures, training materials, and asset lists.
• Led the design, development, implementation, and maintenance of the information governance program.
• Led the development and ongoing management of privacy programs across the company to ensure compliance with data privacy requirements.
• Organizes, classifies and indexes records so that records are easily accessible when needed.
• Oversees migration and onboarding of paper to electronic record-keeping.
• Oversees the review, update, and approval of corporate procedures.
• Participates in addressing requests with regional regulatory agencies and internal departments to ensure that compliance issues are addressed in a timely manner.
• Participates in compliance monitoring activities such as audits, surveillances, and assessments.
• Represents organization at external meetings at the regional and federal level.
• Upgrades and implements new methods, procedures, and equipment to assure maximum user satisfaction for records management.

Qualifications and Education Requirements

• Bachelor’s degree in accounting, business, engineering, management or related field required.
• MBA, law, or advanced degree desired and a minimum of ten (10) years progressively responsible experience in records and data governance/management, risk management, compliance, accounting, or finance with at least five (5) years in regulatory compliance, specific subject matter experience required.
• Supervisory experience is required.
• Electric utility experience is desirable.
• Knowledge of regulatory framework governing records and data governance.
• Knowledge of records management workflow and content management.
• Knowledge of data privacy regulations (e.g., HIPAA).
• Must have knowledge of NERC Reliability Standards and be familiar with the NERC Rules of Procedure associated with Reliability Standards development, compliance, and enforcement.
• Must remain current with all NERC, FERC, and FRCC compliance requirements.
• Must acquire and maintain knowledge with the technical terminology used in reliability standards.
• Knowledge of Governance, Risk, and Compliance (GRC) solutions and common control frameworks for data regulations.
• Technical knowledge is required (but not developer level skills).