OCIO-0045 Personal Data Protection Programme Support Service (NS) - FRI 8 Nov

Deadline Date: Friday 8 November 2024

Requirement: Personal Data Protection Programme Support Services to the NATO Office of the CIO

Location: Brussels, BE

Full Time On-Site: Yes

Time On-Site: 100% (Teleworking is possible only in Belgium)

Total Scope of the request (hours): 1824

Required Start Date: 2 January 2025

End Contract Date: 31 December 2025

Required Security Clearance: NATO SECRET

Note: For all Level-of-Effort and Completion-Type requests processed outside of the IWC Value Stream, and for which the contractor will not be reimbursed directly by OCIO for travel expenses, additional travel funding shall be allocated on a Not-to-exceed basis when the yearly Option is exercised.

Annex A – Special Terms and Conditions

The contractor will be responsible for complying with the respective national requirements for working permits, visas, taxes, social security etc. whilst working on site at NATO HQ Brussels, Belgium.

No special status is either conferred or implied by the host organisation, NATO HQ Brussels, Belgium to the contractor whilst working on site.

The contractor will be responsible for complying with all the respective National Health COVID-19 regulations in Belgium before taking up the position.

If the successful Contractor is allowed to work remotely, travel to NATO HQ for meetings will be at the contractors expense. Travel to other locations will be reimbursed as if the travel originated in Brussels. Attendance at these meetings are mandatory.

1. INTRODUCTION

The NATO Office of the CIO (OCIO) is leading the implementation of a NATO-wide personal data protection programme (PDPP), and requires support of a motivated contractor.

NATO is in an interesting position concerning personal data protection. While most of its member states must follow the EU General Data Protection Regulation (GDPR), NATO does not. It therefore has the flexibility of choosing the best elements of GDPR and other personal data protection frameworks while avoiding spending effort on tasks that do not add much data protection value.

The contractor will have a key role in further implementing the PDPP strategy to ensure this, as well as assist with the policy’s implementation at the various NATO Bodies in Europe and North America.

We are looking for a well-rounded professional with excellent project management and communication skills as well as experience in personal data protection/privacy. NATO knowledge would constitute and asset.

2. TASKS

The contractor will effectively and efficiently provide the following services:

2.1 Monitor the implementation of the PDPP Strategy

Measurement: Monitor the implementation of the PDP Strategy. Survey the type of personal data processed by NATO and prioritize in to categories so that NATO Bodies only spend effort on those categories where it adds substantial value.

When: continuously throughout 2025.

2.2 Conduct a comprehensive gap analysis of existing data protection practices across NATO bodies to identify areas of non-compliance and prioritize remediation efforts.

Measurement: Develop a risk-based prioritization framework for PDPP implementation, considering data sensitivity, volume, and potential impact of breaches.

2.3 Maintain and review the PDPP Implementation Supporting Document. The PDPP Policy tells NATO bodies what to do. The Supporting Document tells them how to do it. Create a modular framework for the Supporting Document, allowing for updates and revisions as regulations evolve or new data processing activities emerge. Conduct regular reviews of the Supporting Document to ensure its alignment with the latest legal and regulatory requirements.

Measurement: Supporting document is maintained and revised as appropriate.

When: by the end of 2025.

2.4 Develop PDPP forms and templates that will form Annexes for the PDPP Implementation Supporting Document.

Measurement: PDPP Forms and Templates ready to be used by NATO bodies.

When: by the end of 1st Quarter 2025.

2.5 Develop user-friendly guidance and training materials to accompany the forms and templates, facilitating their adoption and correct usage. Incorporate regular training sessions and awareness campaigns for NATO personnel on data protection principles and best practices.

Measurement: Collect feedback from users on the forms and templates, and develop and implement iterative improvements of the guidance and training materials.

When: Development by the end of 2nd Quarter 2025. Updates and maintenance: continuous.

2.6 Provide Implementation Assistance.

Assist the development of local directives and customized implementation plans for each NATO body across the NATO Enterprise, considering their unique data processing activities and organizational structure.

Measurement: Establish a support mechanism for NATO bodies during the implementation phase, including regular check-ins, training sessions, and troubleshooting assistance.

When: throughout the implementation phase (2025 and potentially beyond).

2.7 Write a lessons’ identified report with analysis and recommendations.

Conduct a post-implementation review to assess the effectiveness of the PDPP implementation and identify areas for continuous improvement.

Develop recommendations for future PDPP enhancements based on lessons learned and emerging trends in data protection.

Measurement: Written report with analysis, conclusions and recommendations.

When: by the end of 4th Quarter 2025.

2.8 Continuously monitoring for both PDPP incidents and new or emerging data protection regulatory changes. Develop and maintain a data breach response plan to ensure a swift and coordinated response in the event of a data breach. Establish a continuous monitoring and auditing program to assess compliance with the PDPP and identify potential risks.

Measurement: Track the frequency and complexity of unforeseen requirements, and adjust resource allocation accordingly.

2.9 Provide support to unforeseen requirements as necessary.

Measurement: Provide OCIO support as necessary.

When: throughout 2025.

3. PROFILE

[See Requirements]

4. LOCATION OF DUTY

4.1 The contractor will be embedded with the OCIO at NATO HQ, Brussels Belgium.

Teleworking is possible (only in Belgium) with the percentage of time as per agreement with management.

5. TIMELINES

5.1 The services of the contractor are required for the period starting 2 January 2025 until 31th December 2025.

5.2 A contract extension is possible for the calendar years 2026 and 2027. These contract extensions are subject to performance of the contractor and related NATO regulations and budget availability.

6. SPECIFIC WORKING CONDITIONS

6.1 Secure environment with standard working hours. Occasional non-standard hours may be required in support of the NATO Chief Information Officer urgent tasks.

7. TRAVEL

7.1 Occasional business travel may be required. Travel expenses to be reimbursed by NATO based on the NATO per diem rate, in addition to the hourly rate.

7.2 Substantial travel would be required in 2025, as the contractor will be travelling to various NATO locations to help NATO Bodies implement the PDPP. The amount of travel will be around 25% most months, though some months may be as high as 50% and other months there will not be any travel.

8. SECURITY AND NON-DISCLOSURE AGREEMENT

8.1 The contractor must be in possession of a security clearance of NATO Secret.

8.2 A signed Non-Disclosure Agreement will be required.

3. PROFILE

• Must have project management experience.
• PM certifications (e.g. PRINCE2, PMP) are desirable.
• Must have a university degree.
• A university degree requiring excellent writing skills (humanities or journalism) is desirable.
• Must have excellent English writing skills and the ability to brief their work in English.
• The ability to write and brief well in French is desirable.
• It is desirable that the contractor has experience in Personal Data protection or privacy.
• A certification in personal data protection management (e.g. CIPP/M) is desirable.
• If a Contractor has experience and certification in GDPR or another privacy law/regulation, it is essential the contractor is able to think outside of that paradigm, as NATO is not implementing GDPR.
• Must have a NATO SECRET security clearance.
• Should have a deep knowledge of the NATO Enterprise and its bodies, along with the relationship between them.

8. SECURITY AND NON-DISCLOSURE AGREEMENT

• The contractor must be in possession of a security clearance of NATO Secret.