Confidentiality
The University of Westminster takes its data protection obligations very seriously. All University staff receive compulsory data protection training.
Access to any personal information you give us when participating in any of our counselling and mental health advice services is subject to a staff code of practice and confidentiality agreement. Access to your personal information is limited by permissions to only those staff who need access to deliver our services to you. See 'Use of personal data' below for more details.
Your personal data
Participation in our confidential individual counselling/mental health advice will require registration with the service, where your personal details will be required, and for further communications and appointments and the recording of subsequent personal information and notes related to any counselling sessions.
If you are a student with the University of Westminster, some information when you register will be available from our Student Records System. Otherwise, our records will only comprise of the information you provide to us. Students and staff from participating organisations will be asked to provide information as part of the registration process.
In your use of our services, you may give us personal information that is sensitive (also known as ‘special category personal data’). We will only use and share any sensitive data you give us with your consent or where otherwise allowed by law. Please see the information below.
Use of personal data and legal basis of processing
The personal information you give the University as a participant in our counselling and mental health advice services will be only usually used to manage and deliver the service to you.
The legal basis for this processing will be your consent.
We work closely with other University support services such as Disability, Accommodation and Advisers and use a co-ordinated approach to provide the best service to students. Where necessary, practitioners within the service may need to liaise with colleagues to discuss the best possible support. These discussions are specific, limited and with your consent. Where a student’s welfare or vulnerability is a cause for concern, their needs may be raised with the Head of Student Support and Residential Life, at the University’s Co-ordinated Casework meetings or with key staff. Any information shared by the Counselling and Mental Health Advice service will be limited and with the student’s welfare in mind and to ensure that students are supported in an integrated and holistic way.
For student clients of participating institutions, as part of our duty of care responsibilities, we will contact the link person of the relevant institution if we have cause for concern for a student’s welfare.
With your express permission, it may be appropriate for the counsellor/mental health adviser to liaise with, or write to, a third party, for example a general practitioner (GP), counsellor/psychotherapist, with a view to making a referral. In the case of telephone calls, the purpose of the call will be discussed with you beforehand.
Additionally, in an emergency where you or a third party may be thought to be in danger of harm or where a member of staff would be liable to civil or criminal court proceedings, information about you may be shared outside the service.
If circumstances allow, the counsellor/mental health adviser will normally encourage you to pass on information to the relevant person/agency yourself. If there is no indication that this has happened, and if the crisis or danger is sufficiently acute, the counsellor/mental health adviser may pass on the information directly.
However, wherever possible, consent to disclose information will be sought.
In line with their professional requirements, counsellors may discuss their work with a supervisor external to the service. The supervisor is bound by service confidentiality processes. The purpose of this supervision is to help the counsellor/mental health adviser reflect on their work.
Additionally, the service will create aggregated and anonymous reports for describing, measuring, auditing and improving the service. This information is likely to be shared with internal colleagues and with external partners for only these purposes, where no individual will be recognisable.
Data retention
Your personal data given to the University will be held by us for six years from the end of your contact with the service. After that date, your personal information will be securely deleted from all systems and storage.
Aggregate and anonymised reports may be kept for longer until they are no longer required by the University.
Special category data
If at any time you would like to withdraw consent for the University to hold and process your sensitive personal data relating to the Counselling and Mental Health Advice Service, please contact the Counselling Service Manager at [email protected].
Data transfers and sharing
None of your personal information is shared by the University with any other third party organisation, other than where this has been consented to by you or in the circumstances mentioned above or where otherwise allowed by UK law.
Where services involve a third party processing your information, such services will be covered by a contract, and details of the services and the legal mechanism for any data transfers outside the EU and EEA can be initially requested from:
For the Privacy Policy relating to our Counselling Service Platform please contact Counselling Service Manager at [email protected].
Your rights
If you have any questions relating to the use of your personal information in the University Counselling Service, please contact Counselling Service Manager.
You have a right of access to the notes held in your record and to request that your records are amended or destroyed. If those notes contain references to other individuals, these may not be available to you as protection is also granted to third parties. If you wish to see your notes, you should email the Counselling Service Manager, giving two weeks’ notice.
If you have any questions or concerns about your personal information and your information rights, please see the University’s data protection web pages or contact the Information Compliance Team at [email protected].
You can also contact the Information Commissioner’s Office with any concerns or complaints you may have with the processing of your personal data.
This statement was last reviewed and updated in October 2021