Privacy Notice and Authorization for Ariel Employees, Applicants, and Contractors February 2022
This Privacy Notification (“Notification”) explains how Ariel Investments, LLC and its affiliates (collectively “Ariel”) collects, uses, and shares (collectively “process”) personal information that we obtain about current and former employees, applicants, officers, part-time workers, interns, and independent contractors (“Employees”).
Types of Personal Data We Process
Ariel collects personal information (“Personal Information”) about Employees (which may also include your dependents, family members, partners, etc.) through the following avenues: directly from you, from third parties, service providers, contractors, or public sources. We and our authorized service providers, contractors, and third parties process information about you and, depending on the jurisdiction in which you reside, the information we collect may constitute personal data under applicable data protection and privacy laws. The categories of Personal Information we collect are as follows:
- Identifiers, such as name, postal address, email address, social security number, driver’s license number or similar identifier, account name, unique personal identifier, etc.
- Associated identifiers, such as telephone numbers, signature, bank account number or other financial information, medical information or health insurance information, credit history, including bankruptcies, criminal background, etc. (e.g., see CA Civ. Code §1798.81.5).
- Protected classifications of data, such as race, sex/gender, marital status, national origin, age, disability, marital status, veteran status, etc.
- Commercial information, including your bank account, brokerage and investment account details, records associated with personal property, or other purchasing or consuming histories or tendencies, including credit history and bankruptcies.
- Biometric information, including fingerprints.
- Digital identifiers, such as Internet or other electronic network activity information, such as cookies when you access our website, computer use, browsing history, search history, etc.
- Geolocation data, such as data acquired from your computer or mobile device to identify your physical location.
- Sensory information such as audio, electronic, visual, or similar information.
- Professional or employment-related information, including your role/position/title and area of responsibility, information collected about you and your beneficiaries for the provision of benefits, and information about salary and payroll;
- Education information, such as licenses, and accreditation information, including Personal Information which is not publicly available.
- Sensitive Personal Information, such as social security number, driver’s license number, passport number, race or ethnic origin, biometric information, etc.
How We Collect Your Personal Data
We and/or our authorized service providers and third parties collect Employee Personal Information directly from you or as a result of our employment relationship with you.
We will also obtain Employee Personal Information from authorized third parties acting to provide us with information, such as third parties conducting pre-employment checks, third parties processing references on our behalf, health service providers, pension and benefit administrators, learning and development organizations, data analysis and survey companies, payroll processing companies, and any other services related to our human resources efforts.
The Employee Personal Information we obtain through these sources may include your personal details, contact details, identification documents, personal identifiers, and financial account information. Some of this information will be publicly accessible and some will be gained from reliable and independent databases we access through authorized third parties.
While we make every effort to ensure that all Employee Personal Information is accurate, complete, and up to date, you should regularly update and/or correct your personal data by contacting Human Resources. We are not responsible for the accuracy of any Employee Personal Information or any losses resulting from any inaccurate or deficient data that you supply to us.
If you refuse any of our collection requests, we may not be able to process your personal data for certain purposes. This may affect your ability to receive certain benefits.
Business Purposes for Processing Employee PERSONAL INFORMATION
Employee Personal Information may be processed by us, our affiliates, service providers, contractors, and authorized third parties for the business purpose of maintaining operations and performing services on behalf of the business, which may include:
- Managing the recruitment of Employees.
- Administering human resource functions, including performance reviews and appraisals, sickness leave, training, internal directories and organizational charts, internal communications, and dealing with disciplinary actions, termination, and retirement of Employees.
- Administering payroll, the payment of expenses, remuneration and other benefits of Employees, such as bonuses, equity ownership, loans, pensions, health insurance, life insurance, travel insurance, death, or disability benefits.
- Managing Employee communications, including authorizing, granting, and administering access to or use of our systems, facilities, devices and records, including management of email accounts.
- Carrying out audits and investigating or resolving complaints, grievances, or misconduct.
- Preparing for, complying with and/or responding to inquiries, investigations, or proceedings by governmental, administrative, judicial, or regulatory authorities, including civil litigation.
- Responding to due diligence requests from our existing clients or requests for information/ requests for proposals from prospective clients.
- Monitoring Employees in accordance with our policies and procedures and applicable laws, including to establish certain facts, to verify that the business is complying with regulatory or self-regulatory procedures, to investigate and detect unauthorized use of the system, and to prevent or detect crime.
- In connection with a potential asset or stock acquisition, or the outsourcing or insourcing of services provided by Employees, providing reasonable diligence material to a third party or meeting any disclosure obligations as required by law.
- Debugging to identify and repair errors that impair existing intended functionality.
- Performing services on behalf of the business, including maintaining and servicing accounts, providing investor service, processing or fulfilling orders or transactions, verifying investor information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.
- Providing advertising and marketing services.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of a service that is controlled by the business, and to improve, upgrade, or enhance the service.
Disclosure of Employee Personal Information and Recipients
Employee Personal Information may be disclosed to the extent necessary for the above purposes to the following recipients:
- Affiliates or Ariel Investments and related parties, such as Ariel Investments Trust.
- Service providers, contractors, and third parties authorized by Ariel or you to support its human resources functions, benefits administration, or business operations.
- Fraud prevention agencies and law enforcement agencies;
- Courts, governmental and non-governmental regulators, tax authorities, and ombudsmen;
- Legal representatives of the Company, such as our counsels, accountants, and auditors.
- Prospective or existing clients and their representatives, consultants, and other agents.
- Any third party that acquires, or is interested in acquiring, all or a substantial part of our assets or equity ownership, or that succeeds us in carrying on all or part of Ariel’s business, whether by merger, acquisition, reorganization, or otherwise; or
- As required or permitted by law, including to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or we have a legitimate interest in making such disclosure, such as where necessary to protect our rights and property.
California Privacy Rights
Ariel complies with the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”) (“CCPA/CPRA”). If you are a California resident, you can make certain requests regarding your Personal Information. We respond to these requests as required by California law.
Rights Under California Law
You have the right to notice and disclosure at or before the point of collection of (a) the categories of Personal Information and sensitive personal information (“Sensitive Personal Information”) collected, (b) the purposes for the collection, (c) whether the Personal Information/Sensitive Personal Information is sold or shared, and (d) the length of time it will be retained, or the criteria used to determine the retention period, but Ariel will not retain Personal Information or Sensitive Personal Information longer than reasonably necessary for the disclosed purpose. Ariel will not collect additional categories of Personal Information/Sensitive Personal Information or use the collected Personal Information/Sensitive Personal Information for any purpose incompatible with the purpose for which it was collected, without providing you notice.
You have the right to request that Ariel delete any Personal Information/Sensitive Personal Information about you which has been collected from you.
You have the right to request that Ariel correct any inaccurate Personal Information/Sensitive Personal Information it has about you.
You have the right to request that Ariel disclose to you:
- The categories of Personal Information/Sensitive Personal Information it has collected about you
- The categories of sources from which the Personal Information/Sensitive Personal Information was collected
- The business purpose for collecting, selling, or sharing your Personal Information/Sensitive Personal Information
- The categories of third parties to whom Ariel disclose your Personal Information/Sensitive Personal Information
- The specific Personal Information/Sensitive Personal Information that Ariel has collected about you.
You have the right to know what Personal Information/Sensitive Personal Information is sold or shared and to whom. You have the right to request that Ariel disclose to you:
- The categories of Personal Information/Sensitive Personal Information that Ariel has collected about you
- The categories of Personal Information/Sensitive Personal Information that Ariel has sold or shared about you and the categories of third parties to whom the Personal Information/Sensitive Personal Information was sold or shared, by category of Personal Information/Sensitive Personal Information for each category of third party
- The categories of your Personal Information/Sensitive Personal Information that Ariel disclosed for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
You have the right to opt out of the sale or sharing of your Personal Information/Sensitive Personal Information to third parties by directing Ariel not to sell or share your Personal Information/Sensitive Personal Information.
You have the right to direct Ariel to limit the use of your Sensitive Personal Information to (a) that which is necessary to perform the services you requested, (b) that which is necessary to perform an allowed business purpose, or (c) as authorized by regulations. If Ariel uses or discloses your Sensitive Personal Information for purposes other than these, we will provide you notice that your Sensitive Personal Information may be used or disclosed to a service provider or contractor for additional purposes and you have the right to direct us to limit such use or disclosure of your Sensitive Personal Information.
You have the right to exercise these rights without any retaliation or discrimination, such as denying you services, charging you different rates for services, providing a different level of service, or suggesting you will receive a different price or rate for services or different quality of service.
You can make requests pursuant to these rights by calling the following toll-free number: +1-800-725-0140 or by sending a written request to Chief Privacy Officer, Ariel Investments LLC, 200 East Randolph Street Suite 2900. Chicago, IL 60601. California residents may also designate an authorized agent to make a request for access on their behalf by emailing Legal&Compliance@arielinvestments.com.
When California residents exercise these rights and submit a request, Ariel will verify their identity against information we have about you. We may also ask you for certain information (such as name, address, telephone, or email) or to confirm certain information we have about you, such as your social security number. Ariel will endeavor to honor individual requests within thirty (30) days, but will notify you if more time is needed. Please note that some requests may conflict with certain lawful exemptions under the CPRA, in which case you will be notified of such conflict. Ariel and is only required to honor such requests twice in a twelve (12) month period.
Exercise of these rights will have no adverse effect on your employment.
Ariel does not share any Personal Information for cross-context behavioral advertising.
Inquiries, Requests, or Concerns
All inquiries, requests, or concerns regarding this Privacy Notification or relating to the processing of Employee Personal Information should be sent to Human Resources at HR@arielinvestments.com.