Sooji Seo took over 3M’s privacy duties last month after serving as vice president of ethics and compliance, and privacy chief, for Dell.
“I look forward to extending and expanding my expertise as 3M writes its next chapter on data privacy, security, and digital transformation,” Seo wrote on her LinkedIn profile.
Her move comes after the Maplewood, Minnesota-based company joined toll operators in agreeing to a $215 million settlement in February. The agreement ended six years of class action litigation related to the collection of personal identification data on drivers using two Southern California toll roads.
3M will pay nearly $12 million in cash to roughly two million class members as part of the settlement, as well as $3 million to class counsel and $3,000 to each class representative. Faegre Drinker Biddle & Reath, a large law firm with longstanding ties to 3M, represented the company on the deal.
Seo and 3M didn’t respond to a request for comment.
Frances Phillips Taft, a lawyer hired by 3M in mid-2020 to be its privacy chief, left the company in December, according to her LinkedIn profile.
Taft, a former Faegre lawyer who also held the title of assistant general counsel at 3M, led the company’s strategy for privacy governance and information security. She didn’t respond to a request for comment.
Seo was with Dell since 2007 save for a year-long stint as acting ethics and compliance chief for cybersecurity company Secureworks Inc.
Dell promoted vice president of legal Sommer Coutu to succeed Seo as its privacy chief on May 19, said Meghan Leikin, a spokeswoman for the computer products company. Coutu has spent almost a decade in-house at Dell.
Legal Challenges
3M is grappling with an estimated $33 billion in legal liabilities stemming from two waves of litigation related to allegedly defective combat earplugs and per- and polyfluoroalkyl substances, so-called forever chemicals known as PFAS, Bloomberg News reported in February.
The multidistrict litigation for 3M’s earplug issues is now the largest in US history.
Amid that backdrop, 3M has made changes in its law department.
Kevin Rhodes, a former Kirkland & Ellis partner in Chicago who joined 3M in 2001, took over in February as the company’s new chief legal affairs officer.
Rhodes succeeded 3M’s former chief legal and policy officer Ivan Fong, who left that month to become general counsel for medical device maker Medtronic PLC. 3M hired Fong as its general counsel in 2012.
The company brought on former Kirkland litigation partner Kate Warner in September as a director and assistant general counsel for litigation.
Matar Diouf, a former corporate partner at Womble Bond Dickinson, also joined 3M last year as senior counsel for mergers, acquisitions, integration, and divestitures.
In April, 3M recruited Steven Reich, a former Americas general counsel and head of strategy and governance initiatives at Deutsche Bank AG, to be its chief counsel for enterprise risk management.
Reich joined Deutsche Bank in 2015 and subsequently helped the German financial services company navigate a series of legal and regulatory challenges. He faces a similar task at 3M.
Legal Shuffling
At least three executives with legal backgrounds have recently left 3M.
AmerisourceBergen Corp., a drug company with a new legal chief, hired Ann Anaya in January to be its head of diversity, equity, and inclusion.
Anaya, a former federal prosecutor who once was senior counsel for litigation and preventative law at 3M, spent almost the past five years as the company’s chief diversity officer and vice president of global inclusion.
Marina Pariseau joined 3M in mid-February to replace Anaya.
Kristen Ludgate, a former labor and employment lawyer who worked at 3M for more than a dozen years, stepped down a year ago this month from her role as the company’s chief human resources officer. She was succeeded by Zoe Dickson.
Ludgate, who was tapped in 2018 to replace retired 3M lawyer Marlene McGrath as the company’s top human resources executive, is now chief people officer at HP Inc.
Also exiting 3M was Omar Vargas, a former Justice Department lawyer who for more than four years was the company’s global head of government affairs.
General Motors Co. hired Vargas last year to be head of global public policy. In April, 3M elevated attorney Karen Sisson to be its environmental resource manager and head of strategic advocacy and global government affairs.
Vargas, Ludgate, and Anaya didn’t respond to requests for comment.
Seo, 3M’s new privacy chief, took to LinkedIn this month to advertise a job opening within the company’s legal affairs team for an information technology sourcing and data protection contracts counsel.
An online jobs page at 3M shows its looking to hire a half-dozen lawyers, including a health, safety, and general environmental counsel, a senior trademark counsel, and a senior counsel for enterprise risk management and regulatory compliance.
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