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CCPA Employee Privacy Policy

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Effective Date:  February 1, 2021

This CCPA Employee Privacy Policy (“Policy”) sets forth our privacy practices as required by the California Consumer Privacy Act (“CCPA”). This Policy applies only to Aperio employment-related individuals residing in the State of California who are considered “consumers” as defined by the CCPA – namely, job applicants, employees, and contractors of Aperio. Pursuant to the CCPA, Aperio (“we” or “us”) must deliver this Policy at or before the point we collect your personal information, and identify the categories of personal information that we collect and why we collect such information.

As defined in the CCPA, “personal information” is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident.

For Applicants: We only ask and collect personal information that we require to enable us to make a decision about whether or not to offer you employment. If you do not provide particular information to us, then we will have to make a decision on whether or not to offer you a role without that information, which in some cases could result in us deciding not to pursue your recruitment. In addition, some of the personal information you provide to us is required by law, such as documentation we need to check your right to work. If you choose not to provide us with such required personal information, we will be unable to proceed with considering you for employment, and we will inform you of this decision accordingly.

For Employees with an Aperio Account: Please note that the CCPA does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act (“GLBA”). Accordingly, if you are also an Aperio client and we manage an account for you, the CCPA does not apply to information that we collect about you that you provide to obtain our financial products and services. You can learn more about your CCPA rights as an Aperio client by reviewing our CCPA Privacy Policy.

Within the last twelve (12) months, Aperio has collected the following categories of personal information about its job applicants, employees, and contractors (some example elements overlap with multiple categories):




A. Identifiers

A real name, alias, postal address, unique personal identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.


B. Customer Records Information

A name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.


C. Protected Classification Characteristics under California or Federal Law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), and requests for parental, pregnancy, disability or sick leave.


D. Commercial Information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.


E. Biometric Information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.


F. Internet or Other Electronic Activity Information

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.


G. Geolocation Data

Physical location or movements, such as tracking building and office entry.


H. Sensory Data

Audio, electronic, visual, thermal, olfactory, or similar information, such as voicemail greetings and messages.


I. Professional or Employment-Related Information

Job related data, maintained as part of the employment relationship that could be contained in a job application or resume; an employment contract; a contractor agreement; a performance review; a disciplinary record; photos; information from employee expenses; browsing and search history; payroll and benefits related data; internal and external contact information; or information captured from video, audio, systems, or other forms of monitoring or surveillance.


J. Non-public Education Information (Family Educational Rights and Privacy Act (FERPA))

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades or transcripts.


K. Inferences Drawn from Other Personal Information

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.


Aperio obtains the categories of personal information listed above from the following sources:

  • Directly from you, such as forms you complete as an applicant or employee, or services we provide you.
  • Indirectly from you, such as monitoring information that your work computer or mobile device transmits when interacting with our applications.
  • Third parties, including recruiters who submit your information to us for an employment position that may interest you and consumer reporting agencies for employment background checks.

Please note that “personal information” as defined in the CCPA does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Personal information covered by certain sector-specific privacy laws, such as the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA).

Aperio may use or disclose personal information that we collect about you for one or more of the following business purposes:

  • To recruit new employees, and prior to employment, to conduct employment related background screening and checks.
  • To administer benefits, such as medical, dental, optical, commuter, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, and insurance.
  • To pay or reimburse for expenses, including salary administration, payroll management, payment of expenses, to administer other compensation related payments, including assigning amounts of bonus payments to individuals, administration of departmental bonus pools and administration of stock option plans.
  • To conduct performance-related reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions and staff re-structuring.
  • To monitor work-related licenses and credentials, including provisioning software licenses for use in the course of an employee’s work related responsibilities, ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies.
  • To provide human resources management services, including providing employee data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration.
  • To maintain your contact information.
  • To assist you in the case of an emergency, including maintenance of contact details for you, and your dependents or emergency contacts in the case of a personal or business emergency.
  • To monitor eligibility to work in the United States.
  • To foster and improve our culture and working environment, including conducting staff surveys, providing senior management information about other employees, and conducting training.
  • To ensure a safe working environment, which includes information collected relating to disciplinary actions, and code of ethics conduct processes and investigations.
  • To protect health and safety in the workplace, including conducting surveys and health screenings involving collection of personal health and biometric information about you and your household, to permit contact tracing and reduce the risk of spreading viruses or other diseases during a pandemic or public health emergency.
  • To maintain security on Aperio systems and infrastructure, which includes hosting; management of our software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and internet access.
  • To comply with applicable law or regulatory requirements, such as legal (state and federal) and internal company reporting obligations, including headcount, management information, demographic and other required reporting.

When disclosing your personal information to a third party for a business purpose, Aperio enters into a contract with the third party describing the purpose of such disclosure and requiring that such personal information be kept confidential and not used for any purpose except to perform the services under the contract or respond to regulatory or law enforcement requests.

In the preceding twelve (12) months, Aperio has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers

Category B: California Customer Records personal information categories

Category C: Protected classification characteristics under California or federal law

Category E: Biometric Information

Category F: Internet or other similar network activity

Category I: Professional or employment-related information

We disclose your personal information to the following categories of third parties:

  • Our affiliates, including, for purposes of this section, BlackRock Investment Management, LLC and other companies with the BlackRock name.
  • Our vendors and service providers (e.g., website hosting, information technology and security, cloud storage, etc.).
  • Third parties who provide professional services such as attorneys, auditors, etc.
  • Third parties to whom you or your representatives authorize us to disclose personal information in connection with products or services we or they provide to you.
  • Government agencies as required by laws and regulations or otherwise to comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal information necessary for the specific purpose and circumstances.

In the preceding twelve (12) months, Aperio has not sold any personal information, and we have no future intention of selling such information.

We reserve the right to amend this Policy at our discretion and at any time. When we make changes, we will notify employees through an email notice and reflect the date it was updated. 

If you have questions regarding this CCPA Employee Privacy Policy or our data privacy practices, please write us at:

Attn: Data Privacy Officer

Aperio Group, LLC

3 Harbor Drive, Suite 204

Sausalito, CA 94965

Or email us at: