Student Support and and Wellbeing Privacy Notice

You may contact the University of Chichester Data Protection Officer by email: DPOfficer@chi.ac.uk

The University’s Privacy Standard, Privacy Notices and related policies can be found on the University’s Data Protection web pages.

If Student Support and Wellbeing services are supporting you they will maintain a record of your personal data which may include the following information:

• Details about you which have been drawn from the main University database.  These include your name, student number, University and home addresses and contact details, and your registered next of kin.  This information is processed in accordance with the University’s Privacy Standard and Privacy Notices which can be accessed via the link above.
• Any contact the service has had with you such as appointments, drop-ins, emails, telephone calls, texts, etc.
• Notes and reports about your concerns - this may also include special category data, such as information about your health
• Details about the information, advice and support offered
• Any documents related to your concerns which you have provided - these may also include special category data about you
• We may also hold information from external agencies such as your GP surgery or NHS services - this may also include special category data
• Relevant information from other University services who have a duty of care towards you, this may also include special category data.  These services include:
  • Student Support and Wellbeing services
  • Accommodation and Estates services
  • Other University professional services such as Health and Safety
  • Your Academic Department
  • Other Academic Departments
  • The Students’ Union

The records may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure.

The main purpose of the records is to help to provide you with the best possible support whilst you are studying at the University.  In addition, where there is a perceived serious risk of harm to yourself or another person the information may be used to advise the decisions that must be made in order to keep you and others safe.

The records may also be used as evidence of the support and advice offered when an official complaint about the service provided is received by the University.

We are sometimes legally required to provide information to outside agencies, for example if a court subpoenas records required in court or under the Counter-Terrorism and Security Act 2015 or where the University needs to act in our capacity as a UK Visas & Immigration student sponsor.

The records are also used to provide completely anonymized statistical information to help us to monitor the effectiveness of our services and to identify where our services need to be improved.  This anonymized statistical information may also be used to meet any relevant requests we receive under the Freedom of Information Act 2000.

The main legal basis we rely on for processing your personal data is contractual.  The University has a duty of care to deliver its educational and pastoral services competently and, in carrying out its services and functions, to act reasonably to protect the health, safety and welfare of its students. The University also has a duty under the Health and Safety at Work Act 1974 to do everything reasonably practicable to ensure the health and safety of their students.

In addition, the nature of our services means it is sometimes necessary for us to process special category data about you such as health or mental health issues. Special category data may be processed either to enable the provision of necessary health and social care, to protect your vital interests and/or, with your explicit consent, to support you in other ways.

In some cases, the Student Support and Wellbeing services have a legal obligation to maintain records about you.  These include:

• Case notes maintained by our advisers as a requirement of their professional registration, such as our Nurse Health Advisers, Wellbeing Mental Health Advisers and Wellbeing Counsellors
• To ensure you will not be discriminated against during the application process and during your studies here, where you have declared a disability.  We also have a duty to make ‘reasonable adjustments’* to facilitate your studies
• Our obligation to have emergency evacuation plans for students requiring additional assistance (eg when the fire alarm sounds)
• If you attend an overseas student outing, we need to keep a risk register to ensure the safety of all the students and staff on the trip
• If you are on an international student visa, the Office of the Immigration Services Commissioner (OISC) requires us to keep certain information about you

In very exceptional circumstances, where a high risk of serious harm has been identified, we may process your information to protect the vital interests of yourself or others. This will only occur if you are unable to give consent.

* ‘Reasonable adjustments’ are what the Equality Act 2010 calls any special facilities, assistive technology or support services which enable you to make the most of your studies.

Student Support and Wellbeing services take the security of your personal data very seriously indeed.  It is recognised that some of the information held is of a very sensitive nature which could cause distress should there be a security breach.

Personal data is held in electronic systems stored in accordance with the University’s Electronic Information Security Policy. All your personal data is held on secure servers within the United Kingdom protected by information security systems. All Student Support and Wellbeing electronic folders and student case records have strict password access controls; only specific authorised members of staff are granted access to these folders and case records, and only to those files and records which are appropriate and relevant to their role.

Occasionally paper files are processed (for example where evidence of a condition is received in the form of a letter); these are always scanned and filed into our secure electronic storage at the earliest opportunity and the paper files are securely shredded.

All members of staff undertake regular training on how to keep your information safe.

Every member of the Student Support and Wellbeing services is committed to maintaining the confidentiality of your personal data, and this is also a condition of their contract of employment with the University.

In addition, the Wellbeing Counselling Service, the Student Health Advice Service, the Wellbeing Mental Health Advice Service, and staff in the Wellbeing Student Advice Team work to recognised standards of confidentiality from professional bodies including the BACP, HPC and NMC, see below:

• British Association for Counselling and Psychotherapy
• Health and Care Professions Council
• Nursing and Midwifery Council

Advisers in our services are also members of university student services organisations and adhere to their codes of practice.  These include:

• Association of Managers of Student Services in Higher Education - AMOSSHE
• The National Association of Disability Practitioners - NADP
• The National Association of Student Money Advisers - NASMA
• University Mental Health Advisor Network - UMHAN
• The OISC (Office of the Immigration Services Commissioner) Regulation of Immigration Advice and Services
• Association for International Student Advisers/UK Council for International Student Affairs – UKCISA

When you contact any of the Student Support and Wellbeing services - whether by email, phone, text, or face-to-face at a drop-in or appointment - only information that is relevant to your concern and to the advice and support relating to it will be recorded (electronically or on paper).  These records will be accessible to advisers in the same service, but they will only access these records if they need to.  For example, if you see one of the nurses about a twisted ankle and then drop in again on a later day, the other nurse will be able to see the notes and treatment offered.

Your personal data may be shared with other services within Student Support and Wellbeing if an adviser believes another service needs to know about your concerns and/or the support and advice offered in order to provide you with the support you need.  If this support relates to other than health or social care, the adviser will talk to you about sharing your information with another service, and will ask for your explicit consent to do this.  Only if the circumstances are exceptional, where the adviser believes you or another person(s) to be at risk of harm, will the adviser share the information without your consent.

Sometimes it may be necessary to work with staff in other departments to better support you.  In these situations, we would ask your permission to share relevant information with them to enable us to provide you with the most appropriate support.  We will explain our reasons to you and advise you about whom we feel needs to have information about you. We will then ask for your consent to share this information. If we do have your permission to share information then we will only share the information needed to ensure that appropriate support is in place.  In exceptional circumstances, where the adviser believes another department needs to know information about you because of risk of harm to yourself or another person, it may be necessary to share the information without your consent.

In some situations, you may wish to restrict the type of information we share, however, if you do wish to restrict the sharing of your information this may limit the support and effectiveness of help that we can offer you.

In some instances, staff may need to share appropriate information from your personal data with organisations outside the University to ensure support is in place for you. This could include services - such as your GP or other NHS services, Social Services or Local Authorities - and work placements where reasonable adjustments need to be made to accommodate any additional support requirements you may have. We will explain our reasons to you and advise you about whom we feel needs to have information about you. We will then ask for your explicit consent to do this.

If we have serious concerns about your safety or the safety of others we may have to share appropriate information with organisations and services from outside the University, or your next of kin. Wherever possible we would discuss this with you first and obtain your consent. However, this may not always be possible; such circumstances would arise only:

• Where there is risk of harm to yourself or others, including safeguarding issues e.g. child protection
• Where disclosure is required by law e.g. a court subpoenas records required in court or under prevention of terrorism legislation
• If we are legally obliged to provide information to UK Visas and Immigration (UKVI) as a UKVI Student Route sponsor

If we are legally obliged to provide information to outside agencies we will do this in line with UK data protection legislation.

We would discuss our reasons for sharing this information with you, as appropriate, as soon as reasonably possible.

Most of the data held by Student Support and Wellbeing services will be held for the duration of your studies at the University and then for a further 3 years from your last day with us.

The exceptions to this rule occur where we are required to keep the information for longer than this for legal or contractual reasons.  For example, the requirement to keep records of advice given by our International Student Advisers to international students and applicants for 6 years.

Each year all the records are checked to identify those which have reached the end of their retention period.  Electronic records are then either deleted completely or have all personally identifiable information irreversibly removed from them (this enables the University to keep accurate year-on-year records which can be analysed to monitor the effectiveness of the support offered).

You have a right to request the personal data we hold about you.  If you'd like a copy of the information you are entitled to, please write to or email the University’s Data Protection Officer (DPOfficer@chi.ac.uk).

Guidelines on how to make a request for your data can also be found on the University’s Data Protection web pages

If you wish to exercise any of the following rights regarding information held about you by Student Support and Wellbeing services, please contact Student Support and Wellbeing services on StuSupport@chi.ac.uk.

Right to rectification

If you think any of the information we hold about you is inaccurate you can ask us to correct it or remove it.

Right to erasure

If you think the information we hold on you is not relevant to your support, or if you think the data is being held longer than necessary, you may request that it be deleted.  We will discuss your request with you and, where possible, we will comply with your request.

Right to restrict processing

If you have asked us to correct your data you may also ask us to restrict our use of it whilst we are verifying its accuracy.  You may also ask us to restrict our use of your data if you disagree with the way we are using it or whilst we are investigating the issue you have raised.

If you wish to complain about any aspect of our information rights practice you may do so by contacting the Information Commissioner’s Office.