Data protection for organisations

This page answers the questions an HR or procurement team usually asks before deploying Aperio. It summarises how the platform handles personal data. Our Privacy Policy is the full and authoritative document, and the terms every organisation accepts are in our Data Protection and Data Sharing Agreement. We are happy to complete your own data protection questionnaire.

Who is responsible for the data

Aperio Profiles is a trading name of Liberation Academy Ltd, registered in England and Wales (company number 16087057), registered office 20 Wenlock Road, London N1 7GU. We are registered with the Information Commissioner's Office (registration reference ZB819301). For the part of a profile that is shared with an employer, the employer and Aperio act as joint controllers: Aperio decides what is collected and how it is secured, and the employer decides how it uses the shared profile within its organisation. Aperio is your single point of contact for any data protection query, at enquiries@liberationacademy.co.uk.

What an employer can and cannot see

This is the most important point, and it is enforced in the platform rather than promised in a policy. Once someone completes a Workplace Profile, an employer's dashboard receives only their workplace personality profile (the Big Five, scored for work) and their stated working arrangement, plus any specific adjustments the individual actively chooses to share.

Executive-function scores, any neurodivergence or pattern screening results, the sex the person was assigned at birth, any diagnoses they disclose, and their raw answers are never sent to an employer. When a person shares an adjustment, they can also choose to tell their employer which area it relates to (ADHD, autism, dyslexia, dyspraxia or other). That is their own separate, explicit choice, no score or result is attached to it, and they can withdraw it at any time. Standalone screener results (ADHD, autism, bias) are never shown to an employer for a named individual at all; an employer sees only anonymous, organisation-wide figures (how many people completed a screener and how many scored in the high range), subject to the minimum group size below. A person whose workplace profile suggests possible ADHD or autistic traits is offered a screener funded from the employer's code pool. That request is anonymous too: the employer approves it before a code is spent, and is told only that a screener of that kind was requested, never who asked. The employer never sees the result.

Where data is hosted, and who processes it for us

Data is stored with Supabase in the UK region (AWS London), with row-level security restricting access to server-side calls. Payments are processed by Stripe; we never see or store card details. Transactional email is sent via Resend. The site runs on Vercel. In the bias screener only, short written answers are scored by OpenAI in the United States; OpenAI does not use them to train its models and may keep them for up to 30 days before deleting them. Analytics (Google Analytics and Vercel Analytics) and the Meta Pixel load only for visitors who opt in through the cookie banner; they are described in our cookie policy. Each provider operates under a data processing agreement. Where a provider processes data outside the UK (Stripe and Resend in the US; Vercel edge functions may execute outside the UK), the transfer is safeguarded by the UK Addendum to the EU Standard Contractual Clauses or the UK International Data Transfer Agreement. UK storage by a UK controller is not a restricted transfer.

Lawful basis

Our lawful basis for generating and delivering a profile is the contract with the individual (UK GDPR Article 6(1)(b)). For the health-related elements, executive-function scores, any screening results, and any diagnosis disclosed, the basis is the individual's explicit consent (Article 9(2)(a)), which is requested on a dedicated consent screen before the assessment begins and recorded with the exact wording shown. Because consent given in an employment relationship is not a completely free choice, employers agree, as a condition of using Aperio, that anyone who declines to take part will not be penalised or treated less favourably for it.

How long data is kept

Each type of data is kept only as long as it is needed. Raw assessment answers are deleted or anonymised about 90 days after a report is produced. Results are kept while the individual's Aperio account is active. Where someone has no Aperio account, their results are deleted 24 months after their last activity. Access codes and session tokens are kept for up to 12 months, and audit and access logs for up to 18 months. Records we are required to keep for legal reasons, consent history, any workplace adjustment shared with an employer (as Equality Act evidence), and payment records (for HMRC), are retained for up to 6 years. Short-lived deletions, including raw answers, run automatically every day and are logged.

What happens when someone leaves the organisation

When an employer marks a person as a leaver, that person's profile data is withdrawn from every employer-facing view: their results and any shared adjustments stop appearing in the dashboard. The individual's own account and their own copy of their report are unaffected. Because nothing is destroyed by marking a leaver, reinstating a person restores the previous visibility if it was done in error.

How an individual can access or delete their data

Individuals can exercise most of their rights themselves from their Aperio account: view the data held about them, download a copy, manage or withdraw anything shared with an employer, and request erasure. Erasure requests are actioned within one calendar month. Where the law requires us to retain something, for example evidence of a workplace adjustment under the Equality Act 2010, we tell the person what is retained and why. Individuals also have the right to complain to the ICO at ico.org.uk.

Minimum group size for aggregate analytics

Any organisation-wide figure is protected so that no individual can be identified from it. Aggregate screener figures, both completion counts and high-range counts, are suppressed unless at least five people fall inside the group and at least five fall outside it, so neither a count nor its opposite can single anyone out. Where an organisation-wide breakdown of sex distribution is offered, it is shown only once more than 50 people have completed an assessment, and it is suppressed automatically whenever a group is small enough that an individual could be recognised.

What Aperio is not

Aperio is a self-report profiling tool. It is not a clinical or diagnostic assessment and it is not a substitute for an occupational health assessment or an Access to Work assessment where one is needed. Its output supports human judgement about working conditions and adjustments; employers agree, as a condition of use, not to use any individual's profile to make a recruitment, promotion, disciplinary, redundancy or other employment decision about them, and not to use Aperio to assess job candidates.

Contact

Data protection contact: Liberation Academy Ltd, trading as Aperio Profiles, 20 Wenlock Road, London N1 7GU. Email enquiries@liberationacademy.co.uk. General enquiries: hello@aperioprofiles.co.uk. For the full detail, see our Privacy Policy.