Saul Muscat – GDPR Officer

“After teaching abroad for a number of years, I joined the B2W Group in Feb 2017 as an Enrolment Officer and have since worked in a few various roles within the company. When asked if I would like the opportunity to be trained as a Data Protection Officer, I jumped at the chance as I have always been fascinated by technology and digital security.”

[email protected]

Download our Privacy Policy here: Privacy Policy 2023

Download our Supply Chain Subcontractor Policy here: Supply Chain Subcontractor Policy 2022


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 you.

– 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 yourself.

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;
– other companies within the B2W Group in order to provide the most appropriate learning to meet your needs.
– 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
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 with companies outside of the B2W Group. 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 distress. 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.

– 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: [email protected]


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,

Telephone: 0303 123 1113


You can also report at concern here –

Back2Work Complete Training provide Pre-Employment Training throughout the UK.

Pre-Employment Training works great as both a recruitment service for employers and an employment service for those who are unemployed.

Registered office in England and Wales, No:07559200
© 2019, Back2Work Complete Training, All Rights Reserved.


0161 474 7603
[email protected]

Floor 2, Building 4,
Universal Square,
Devonshire Street,
M12 6JH