Back 2 Work Complete Training Limited Privacy Notice for our Customers and Learners

B2W takes the security of your personal data very seriously. This privacy statement sets out why we need your information, what we need and how we will use it.

Why do we need data about you?

B2W need to collect and use information about you (data) to deliver our range of services including employability support and skills training.

B2W works as a data processor for a number of public bodies including the Department for Work and Pensions (DWP), The Education and Skills Funding Agency (ESFA), devolved administrations in Scotland, Wales and Northern Ireland and local authorities. As the “Data Controller” these bodies are able to lawfully process data in line with the following lawful basis and B2W as a “Data Processor” for these bodies are able to lawfully process your data on the same basis under the contracts we have with these bodies.

Lawful Basis for Processing

We are able to gather, use and share (process) your data as a “public task in the public interest” under relevant laws, including the General Data Protection Regulation (article 6(1)(e)). We are able to process your sensitive personal (special category) data by ensuring that this processing is proportionate, and is necessary for statistical research purposes under the General Data Protection Regulation (article 9 Sections (2)(g) and (j)).

For the purposes of the General Data Protection Regulation, the various supply chain partners that B2W use to support delivery of the contracts we have with the various “Data Controllers” are also able to process this information in line with the contractual requirements we have with them.

How will your data be used?

B2W will use your data to:

• Help us agree with you the appropriate type of service we can provide to support you in your training or support you into employment and independent living or other service we provide to
• Monitor and report on our performance in supporting you, including producing statistics and equalities monitoring reports.
• Better understand how our services work, what difference they make to the people involved and how to improve future services for people like

Privacy Notice for our Customers and Learners

What information about you is needed?

To deliver, monitor and evaluate our services, we will ask you for:

• Your contact details;
• other personal data (for example, your age, gender, National Insurance Number), and;
• sensitive / personal data (for example, about your health, religion, ethnicity).

We will also ask you about your relevant background / historical information that supports the service we offer to you and will hold information on the support you receive as a participant in the programmes we offer through these public bodies.

How will we store your data?

Your data will not be transferred to, stored at, or processed in a destination outside the European Economic Area (EEA). We will store your information on databases held in locations that have been tested for electronic and physical security and access will be permitted only to those with a need to know. We will not store your personal information for longer than is necessary to deliver and evaluate the services we offer.

Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

Sharing your Data

To deliver our services, B2W may need to share the minimum necessary of your personal and sensitive details with:

• potential employers;
• specialist training and other organisations necessary for your full participation in the service we offer, where these organisations are covered by a contract held with B2W and therefore incorporated into our contract(s) held with the data controller;
• third party contractors acting on behalf of B2W to provide support services necessary for the delivery of our service to you; and

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• other parties, as is necessary for the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings).

To evaluate our services, we may also contact you to invite you to take part in the evaluation of our services. The feedback you give will help shape future employability and other services we offer. The information collected will be used for research, evaluation and statistical purposes only. You do not have to take part in evaluation activities if you do not want to.

We will not share your contact information for any marketing purposes. We will also not use your image for marketing purposes without your prior consent.

Your Responsibilities

You are reminded that it is your responsibility to ensure the security of your own data (including printed material such as CVs) at all times, including when on B2W premises.

B2W cannot accept responsibility for the loss or theft of your personal data if caused by your own negligence.

Your Rights

• You have the right to access the personal data we process about you. To access the personal data we processes about you, submit a request in writing (by post or email) to the B2W Data Protection Officer (address below). B2W will treat this as a Subject Access Request and will respond within one month of receipt of the request.

B2W as the “Data Processor” will need to contact the relevant public body to obtain their authority as “Data Controller” to release your data but we will provide the “Data Controller” with all the assistance they require to meet your demands for access to your personal data on a timely basis.

• You have the right to object to processing that is or is likely to cause substantial damage or distress to you or another. To exercise this right, please write stating what processing you object to and why it is causing, or is likely to cause you damage or B2W will consider the request and respond within 21 days to confirm whether the objection is accepted. B2W as the “Data Processor” will need to contact the relevant public body to obtain their authority as “Data Controller” to respond to your request but we will provide them with all the assistance they require to respond to your request on a timely basis.
• We seek to ensure that personal data processed is accurate and up to date. You have the right to request to rectify, block, erase or destroy inaccurate information. To exercise this right you can write to B2W setting out the information and the reasons you wish it to be changed etc. We will consider the request and respond within 21 days to confirm whether the request is accepted. In cases where the inaccurate data is the result of processing by B2W we will respond to you directly without reference to the public bodies who are our “Data Controllers”. However in some cases the inaccurate data may relate to information we have received about you from the various public bodies we process data for. In these cases we will need to confirm details with the public body but we will work with them to provide you with an appropriate resolution on a timely basis.

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• You have the right to be confident that we will handle your personal information responsibly and in line with good practice. If you have a concern about the way we are handling your information you can write using the details below.

Processing as Data Controller

The vast majority of the data processing carried out by B2W is under contracts with public bodies

and we process your data as a “Data Processor” in line with the lawful basis outlined above.

In a minority of cases the lawful basis of processing may be contractual or by consent or by another lawful basis. In these circumstances we will confirm the specific legal basis to you via additional documentation. Where B2W requests additional personal data from you above and beyond the data required to act as a Data Processor or in circumstances where B2W are the Data Controller we will also specifically ask for your consent to process your data. In any circumstances where the lawful basis of processing is your consent you will be able to withdraw your consent at any time.

To exercise these rights, you can write to the B2W, Data Protection Officer:

Postal Address: Data Protection Officer, Back 2 Work, Floor 4, Building 4, Universal Square, Devonshire Street North, Manchester, M12 6JH

Email: dpo@b2wgroup.com

Visitors to our Website

When someone visits our website, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns.

We collect information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type, referral source, length of visit, entry and exit points and the number of page views).

We do this to find out things such as the number of visitors to the various parts of the site.

This information is only processed in a way which does not identify anyone.

We do not make and do not allow Google to make, any attempt to find out the identities of those visiting our website.

You can find more information on how cookies are used on this website in the Cookies Policy.

If we do want to collect personally identifiable information through our website, we will be upfront about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

When You Contact Us Via Our Contact Forms

When you use our contact form, the information submitted is emailed to us so that we can correspond with you. Your personal data will be stored in the website’s database.

We store your data on our website database so that if an email doesn’t get through we can check the website and access the request to ensure we don’t miss any enquiries or leads.

Security

Our website has HTTPS encryption via an SSL certificate to ensure any data passed between your browser and the web server (where this website is hosted) is encrypted.

Change of Ownership

Information about users and visitors, including personal data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the User or visitor data commits to a privacy notice that has terms substantially consistent with this privacy notice.

Client data may be physically or electronically transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing the operation of the Service, and only if the recipient of the client data commits to a privacy notice that has terms substantially consistent with this privacy notice.

Links to Other Web Sites

This privacy notice does not cover any links within this site linking to other websites. Those sites are not governed by this privacy notice, and if you have questions about how a site uses your information, you’ll need to check that site’s privacy statement.

Cookies

Cookies are small text files that store information on your hard drive or browser which means that we can recognise that you have visited our website.

They make it easier for you to maintain your preferences on our website.

A cookie often includes a randomly generated number which is stored on your device. Many cookies are automatically deleted after you finish using the website.

Use of Cookies

This website does not store any information that would, on its own, allow us to identify individual users of this service without their permission.

Any cookies that may be used on this website are used either solely on a per session basis or to maintain user preferences. Cookies are not shared with any third parties.

Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third-party cookies. For example, in Internet Explorer, you can refuse all cookies by clicking Tools ⇒ Internet Options⇒ Privacy ⇒ Block all cookies, then use the sliding selector.

Blocking all cookies will, however, have a negative impact upon the usability of many websites, including this one.

Complaints

Please note that B2W have a Complaints procedure and if you need to complain about the way any request you have made in relation to your personal data has not been handled appropriately you can use our Complaints procedure to help resolve this issue. Please ask for a copy of our complaints procedure.

If you feel we have been unable, or unwilling, to resolve your information rights concern, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). The ICO are the supervisory authority responsible for data protection in the UK.

For further information, including independent data protection advice and information in relation to your rights, you can contact the Information Commissioner at:

Postal Address: The Information Commissioner, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113

Website: www.ico.org.uk

You can also report at concern here – https://ico.org.uk/concerns/handling/