Meet Bhakti: master problem solver, unapologetically detail oriented, our favorite lawyer.
What is your role at JUST?
I established the General Counsel role at JUST. I am a trusted advisor to the C-Suite and Board executives. I’m also responsible for global privacy compliance and strategy, risk management and risk mitigation, contract negotiations and development of policies and processes.
Is there a typical workday for you?
There is no typical day. My day is driven by business priorities and execution of JUST’s strategic initiatives. Throughout the day almost everything I do affects JUST’s overall business.
I respond to requests from various stakeholders for contracts, contract renewals, SOWs, change orders and contract amendments, new client MSA’s and Data Processing Agreements, CCPA Addenda, revisions to our insertion orders from various media vendors, responding to privacy and security questionnaires, collaborating with the HR team for drafting various policies and creating and updating training materials for company-wide GDPR trainings.
I spend a fair amount of time conducting research and analysis into new laws and regulations that could affect JUST’s overall business.
How are you spending your quarantine time?
I walk 5 miles a day and bike with my kids. I really enjoy gardening and this year we are growing some new plants like tomatoes, cantaloupe, watermelon, peach, and grapes.
What do you enjoy the most about working in the legal side of marketing?
The best part I have enjoyed so far is the new and exciting platforms each team at JUST uses. Every new platform agreement is an exceptional learning experience for me. These agreements present new contractual challenges along with certain GDPR/CCPA compliance issues which are unique to the platform and technology we use. I also enjoy working with the AdTech ecosystem which offers complex privacy issues.
You’ve built a successful legal career providing counsel for up-and-coming startups and multinational, Fortune 500 enterprise companies alike. How is working at JUST different than your past experiences?
JUST has a very fast-paced work environment where priorities are constantly evolving. This is the first time I am working at an advertising agency. I am the first ever General Counsel at JUST and a single person department which makes it bit challenging to introduce new processes while improving current ones. In my previous roles, I have never been the only one on my team. When I joined JUST, one of my top priorities was to meet the key stakeholders, understand their team’s charter and ask them about their expectations from me which helped me streamline my engagement with them. Learning the advertising agency lingo was bit challenging, but fun!
What’s your favorite lawyer joke?
What are the latest trends or innovations happening in your field?
Privacy law is a rapidly changing field as it needs to keep pace with the ever-changing technologies and platforms. But we can broadly classify the recent innovations based on their regional effectiveness.
First is the domestic privacy laws. CCPA is enforceable effective July 1, 2020 and that has changed the privacy landscape in CA. It is a landmark law that secures a broad range of privacy rights for California consumers and imposes compliance obligations on California businesses. The California Privacy Rights Act (CPRA) referred to by many as CCPA 2.0 made the November 2020 ballot. If passed, it would be effective January 1, 2023 and it would have far-reaching national and international impact well beyond CA based businesses. Various states have introduced data privacy laws as well.
Secondly, on the international front, the latest trend is the landmark judgment issued by the Court of Justice for the European Union (CJEU) in Schrems II case on July 16, 2020. The CJEU invalidates the EU-US Privacy Shield Framework but Standard Contractual Clauses remain valid. Another evolving topic is the ePrivacy Regulation. It is currently a proposal for the regulation of various privacy related topics in relation to electronic communications within the European Union. The scope of the ePrivacy Regulation is still under discussion and cookies and AdTech are the key impact areas.
Why should brand marketers look for agency partners which are well-versed in data protection and privacy?
Brand marketers should look for an agency that believes in protecting client data privacy and shares client data in a responsible manner. They should consider the agency’s data protection practices and policies when electing to work with them.
You also provide pro-bono legal advice to local small businesses within your community. Why is that important to you?
Providing pro-bono advice is my way of giving back to the community. It gives a sense of fulfillment and also presents me with an opportunity to learn about other areas of law.
How do you stay up to date with the latest news in your field? Any favorite publications/blogs you follow?
JUST is an IAPP (International Association of Privacy Professional) member. I like to follow them on their website and LinkedIn. IAPP is one of my go-to websites and I really enjoy watching their LinkedIn Live sessions which are very insightful. I also like attending webinars conducted by well-known law firms that bring me up to speed on the various new developments.
You speak five languages (impressive!). Do you have any favorite expressions from other languages that don’t exist in English?
My favorite expression is a german saying ‘Jetzt mal Butter bei die Fische geben’ which literally translates to “give butter with the fish”, it actually means come to the point. I like it because I say it a lot.
What does it take to be successful at JUST?
Working at JUST gives me a chance to work with variety of people from different countries and backgrounds. I think it is very important to have a collaborative mindset. Being flexible really helps. I think it is important to ask questions. Having good communications skills is very important. If you cannot communicate your ideas and rationale behind your thoughts, then it is very difficult to be successful in your role and develop lasting relationships with your colleagues.
Is there a project or accomplishment you’ve reached while working at JUST that you’re particularly proud of?
The creative team at JUST and OFX were planning a photoshoot for their “OFXpert” campaign for a long time, but were blocked since March due to the shelter in place order from San Francisco Department of Public Health. The order was updated in June allowing for certain activities, given certain social distancing protocols were followed. I kept the JUST senior management and OFX teams updated with latest order details. The intention was to protect everyone from the risks of violation of the order as well as avoid any health issues. I spent time analyzing the guidance issued in the “Industry-wide Labor-Management Safety Committee Task Force – Proposed Health and Safety Guidelines for Motion Picture, Television, and Streaming Productions During the Covid-19 pandemic” publication and shared my findings with the teams involved. This helped us get quick approvals from OFX legal team for the event. Our CFO Joe Parente, Head of Human Resources Emily Brinkert and I decided how to move forward on this, but it was a great team effort overall. We had to navigate a lot of complexities to pull this off securely and safely.
What has been the most valuable career advice anyone has given you?
The managing partner at a law firm I worked with previously always encouraged me to have a solution-oriented approach. It really helped me see problems as challenges that I could overcome. I still remember his exact words “Don’t come to me with a problem, come to me with a solution to your problem”.