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The Manager, Corporate Compliance, is responsible for the day-to-day execution of Cisive 's Corporate Compliance Program and serves as the Company's principal subject matter expert on background screening and consumer reporting compliance. Reporting to the General Counsel (GC), the position supports and, where delegated, acts on behalf of the Legal Department in developing, implementing, monitoring, and maintaining the programs, policies, procedures, and training required to keep all business units in compliance with applicable operational, regulatory, and contractual requirements.
The position requires a working knowledge of the federal Fair Credit Reporting Act (the “FCRA”) and analogous state consumer reporting statutes, EEOC guidance, “Ban the Box” and fair chance laws, data privacy regulations, and industry standards, with particular depth in the Healthcare vertical. The Manager serves as a trusted advisor to department leadership — proposing and reviewing policies affected by compliance requirements, resolving or escalating client-escalated compliance matters, and delivering compliance education to internal staff and clients. Continued development of knowledge and skills in these areas is an expectation of the role and is materially supported by Executive Leadership.
Essential Duties and Responsibilities
Compliance Program Administration and Governance
Conduct the implementation, maintenance, monitoring, and periodic revision of the Corporate Compliance Program and Policies.
Coordinate the regular scheduled review of Compliance Program documents, providing direction, coordination, and recommended revisions as necessary.
Author, develop, and maintain Compliance Policies and Procedures, and perform compliance review and approval of Operations policies.
At the direction of the GC and in coordination with Operations, draft, update, and manage Public Record policies and related matching-criteria policies across the enterprise.
Manage and update, no less than annually, the Cisive Common Name policy and related internal control documents.
Maintain records of substantive contact with any government agency relevant to the Compliance Program, and preserve the confidentiality of compliance matters consistent with Cisive policy and applicable law.
Regulatory Monitoring, Research, and Interpretation
Track and research International, federal, state, and local laws, regulations, ordinances, and enforcement developments affecting Cisive 's operations; evaluate and interpret their application to the business.
Ensure that Cisive understands legal and regulatory developments within the consumer reporting and background screening industry, including competitor and industry responses to such developments.
Assist the Legal Department in designing policies and procedures responsive to emerging legal and regulatory requirements and communicate required changes to Operations leadership as appropriate.
Author and distribute Compliance Alerts and Advisories — e.g., Ban the Box / fair chance, credit checks, FCRA amendments, salary history restrictions, and state consumer reporting requirements.
Support the review of contracts, financial arrangements, marketing initiatives, and other transactions that may implicate consumer protection, fraud, or abuse laws and regulations, escalating to the GC and Legal as warranted.
Client-Facing and Operational Compliance Support
Review and approve, or appropriately escalate, client forms relating to FCRA disclosure, authorization/consent, and adverse action; train others to perform the same review.
Respond to or appropriately escalate internal and external inquiries regarding the FCRA, analogous state consumer reporting regulations, required forms and notices, disclosure questions, and Ban the Box legislation and regulations.
Work alongside Implementations to address new and existing client questions regarding compliance and services, and to confirm client readiness from a compliance perspective.
Partner with Operations to investigate, resolve, and document client-escalated compliance matters.
Education, Training, and Communications
In cooperation with Human Resources and Senior Compliance Leadership, develop and deliver programs that educate and train Cisive personnel on the Compliance Program and applicable legal and regulatory requirements.
Design and deliver effective compliance education for internal staff and for clients, including in-person/live via Teams, eLearning, and webinar formats.
Curate and create content for company compliance publications, including the Compliance Quarterly e-newsletter and quarterly compliance advisories.
Develop presentations and training/communication materials appropriate for audiences ranging from front-line staff to client executives.
Monitoring, Issue Identification, and Response
Work with Cisive managers to establish internal compliance review and evaluation procedures for relevant departments, and assist in conducting reviews, monitoring, and audits.
Identify potential areas of compliance risk; develop, implement, and track corrective action plans; and issue general guidance to affected departments.
Work with the Legal Department on newly identified areas of non-compliance and on changes that increase the probability of deficiencies or violations.
Support the prevention, detection, and response to allegations of fraud, abuse, and other improprieties, including assisting with internal investigations at the direction of the GC.
Prepare and contribute to reporting for the GC on levels of compliance and non-compliance identified through monitoring and auditing, the effectiveness of remediation and training efforts, and corrective actions taken.
Cross-Functional, Product, and Third-Party Support
Assist and work with Information Technology on compliance-dependent processes, including adverse action design, implementation, and user acceptance testing.
Participate in Product Development and product review activities, providing compliance input on new and modified products, specifications, and data sources.
Assist and work alongside Marketing, Sales, and Client Success on client questions, compliance consultations, webinars, and publications.
Coordinate with Human Resources to confirm that appropriate internal background checks are performed.
Other assignments as made and communicated by company leadership.
Education and Qualification Requirements
Required
Bachelor's degree required.
Minimum of five (5) years' experience in consumer reporting, compliance, regulatory affairs, or law firm.
Working knowledge of the FCRA and analogous state consumer reporting laws, EEOC guidance, and fair chance/Ban the Box requirements.
Must possess or obtain within three (3) months of start date, the Advanced FCRA Individual Certification offered by the Professional Background Screening Association (PBSA).
Demonstrated technical writing capability — policies, procedures, advisories, and training documentation.
Preferred
Previous employment with a consumer reporting agency (CRA).
Experience designing or delivering compliance training and instructional content.
Strong working knowledge of data privacy frameworks relevant to screening (GDPR, DPPA, GLBA, HIPAA, state privacy statutes).
Professional affiliation with PBSA, SHRM, or an equivalent professional body.
Prior supervisory or team lead experience.
Required Skills and Competencie s
Strong time management skills, with the ability to multi-task and work at a fast pace.
Ability to effectively present information and respond to questions from groups of executives, managers, and clients.
Excellent written and oral communication skills.
Excellent presentation skills, including the ability to set up and conduct webinars.
Excellent computer skills — Microsoft Office and internet-based research tools.
Resourcefulness and strong attention to detail, with the ability to handle multiple projects simultaneously.
Ability to make decisions and solve problems independently, and to recognize when a matter must be escalated.
Professional manner and image suitable for close work with clients.
Ability to effectively handle time-critical issues, remain productive, and meet goals in stressful situations.