Counselling & Wellbeing Services

University of Glasgow Counselling and Wellbeing Services: Privacy Notice

Your Personal Data

The University of Glasgow will be what’s known as the ‘Data Controller’ of your personal data processed in relation to the services provided by the Counselling and Wellbeing Services (CWS). It is important that you read this notice prior to providing your information.

How do we collect your personal data?

We will obtain personal data about you from the following sources:

• From information provided when you register with CWS via our online webform
• From third parties who have indicated concern over your welfare
• From referral information passed onto us from another health and wellbeing service, such as the National Health Service (NHS) or Occupational Health (staff)

What types of data do we collect?

We will collect the following types of personal data about you:

•  Your name, date of birth, gender, either your Student ID number or Staff employee number
• Contact details, including your University and personal e-mail addresses and telephone number
• Information about your course of study or employment role
• GP details

And the following types of special category data:

• Information relating to why you require treatment, what you hope to gain from the service and any mental health support or treatment you are currently receiving
• Details on disabilities and any other health or mental health conditions
• Ethnicity (optional)

We will only collect data that we need, in order to provide and oversee our service(s) to you.

Legal basis for processing your data

We must have a legal basis for processing all personal data. In this instance, there are several legal bases under which CWS use your data.

Your personal data is processed under the following legal bases:

1. Contract

• in order for us to provide a service to you for counselling/psychological therapy sessions and/or other treatment you must enter into a contract with our service, known as ‘Contract of Engagement’

2. Legal Obligation

• where we are legally obliged to disclose information shared with us for example under The Terrorism Act (2000), the Drug Trafficking Act (1986), the Road Traffic Act (2000) and where we receive a court order 

3. Vital Interests

• where staff believe that you or a third party is at serious risk. If the risk is believed to be sufficiently serious, the member of staff may share your information directly, irrespective of your consent.

4. Consent

• on specific occasions we will only process certain data if you consent e.g., when you attend an assessment appointment, we ask you to complete a psychometric evaluation form or passing your details onto a third party.

Your special category data is processed under the following legal basis:

5. Provision of health or social care or treatment

• Where there is a contract with a health professional. This covers the provision of the medical treatment you receive from CWS in the form of counselling/psychological therapy and support. It also covers onward referral to third party agencies, such as GP, National Health Service or other healthcare providers.

6. Substantial public interest on the basis of Union or Member State law

• under the Equality Act (2010) we may pass your information on to the Disability Service to ensure reasonable adjustments are made to teaching and assessment processes so that students can participate fully in their studies.

What we do with it and who we share it with?

The personal data you submit is processed by staff at the University of Glasgow in the United Kingdom. The systems used to process your data (MyCampus, Office 365) are part of the University’s corporately supported IT architecture and are protected by the University’s security measures. Minimal data consisting of pertinent information, such as your name, student ID, your identified issue of concern, is shared internally with:

• Disability Service - Where students are being supported by both the Disability and CWS, we may need to share limited information to ensure coordinated support.
• Peer Support – Where students are being supported with general wellbeing concerns
• Student Support Officers - Where students are being supported with predominantly academic concerns
• Safeguarding Team – Where students are being supported with safeguarding and risk concerns
• Academic Staff – Where your mental wellbeing may be impacting on your academic capabilities
• Occupational Health – Where staff are being supported by both Occupational Health and CWS we may need to share limited information to ensure coordinated support

Please note, where a referral has been made by someone else (for example, Glasgow International College or National Health Service) for you to attend our services, we may share minimal personal information with the referrer to ensure we are providing the best co-ordinated care.

In addition:

• Clinical information and other data on you is held on CORE (Clinical Outcomes Routine Evaluation) a third party secure online platform which stores clinical data such as notes from counselling sessions and correspondence with you and your healthcare professionals. All data is held on servers in the UK and Ireland by Corenet IMS and will only be accessed by authorised persons of the University of Glasgow or Corenet IMS.
• We may pass your information on to third party mental health providers, such as Mynurva and other mental health care agencies in order to provide you with the most appropriate clinical care. Your consent will always be sought and confirmed via email in these circumstances.
• We will only discuss the support you receive from CWS with a family member/carer/GP where you have requested that they receive such information or where we have a legal obligation to do so or is in your vital interests

Please note, your data may form part of anonymous data collection and retention for statistical purposes, used to track and report student presentations and service use, to ensure the efficient use of resources, and evaluate the impact and performance of our service provision. Any data included in reports for the Scottish Funding Council, the Scottish Government, Local Authorities or other funders, to help us understand the success and determine the effectiveness of our work, will only be done so anonymously and as part of a total amount, so you will never be identifiable.

How long do we keep it for?

Your data will be retained by CWS for:

6 years after (whichever is sooner):

• Your last contact with the service; or
• Termination of your studies (for example on graduation or withdrawal)

After this time, your data will be securely deleted, and any paper or electronic files will be destroyed.

What are your rights?*

You can request access to the information we process about you at any time. If at any point you believe that the information we process relating to you is incorrect, you can request to see this information and may in some instances request to have it restricted, corrected or, erased. You may also have the right to object to the processing of data and the right to data portability.

If you wish to exercise any of these rights, please submit your request via the webform or contact dp@gla.ac.uk.

*Please note that the ability to exercise these rights will vary and depend on the legal basis on which the processing is being carried out. 

Complaints

If you wish to raise a complaint on how we have handled your personal data, you can contact the University Data Protection Officer who will investigate the matter.

Our Data Protection Officer can be contacted at dataprotectionofficer@glasgow.ac.uk

If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office (ICO) https://ico.org.uk/

Health Assured Support Line 

The Health Assured support line is a separate service offered to students of University of Glasgow. Health Assured provides a confidential service and the information you discuss with their helpline support workers is not routinely provided to the University unless your health, wellbeing or welfare is judged to be at imminent risk. In these circumstances and where the support worker thinks you need additional support they will seek your consent to share your name and information about their concerns with the University Counselling & Wellbeing Service so that they can provide you with further help. In some circumstances where you are not able to provide consent or where you refuse consent, Health Assured may still decide to share relevant information with the University where it is necessary to protect your or another person’s vital interests. This approach is consistent with the University’s Student Privacy Notice which you signed up to at registration, and can be viewed above.

Counselling & Wellbeing Services (CWS)

By agreeing to attend ongoing counselling/psychological therapy sessions, you are required to read and agree to the following:

1. Attendance

We ask that you prioritise your appointments within the week. CWS is under significant demand, and cancellations and appointments not attended without prior notice (DNA’s) increase the length of time the next student on the waiting list will have to wait to be seen. We do appreciate however that sometimes you might need to re-schedule an appointment. We ask that where possible, you provide at least 48 hours’ notice if you are not able to attend your appointment, so we can offer the appointment time to someone else.

• Cancellations. If you cancel your appointment please note that it is your responsibility to reschedule. If we do not hear from you within 4 working days of your cancelled appointment, we will assume you no longer require our services and your file will be closed. Repeat cancellations may result in your file being closed.
• DNA’s. If you Do Not Attend an appointment without prior notice, please note that it is your responsibility to re-schedule. If we do not hear from you within 4 working days of this, we will assume you no longer require our services and your file will be closed.

Please also note that each missed appointment will count towards the number of sessions you are offered. Two consecutive DNA’s will automatically result in your file being closed.

In circumstances where your file has been closed please note that if you wished to resume sessions in future, you are welcome to attend CWS again and would be able to go back on the waiting list.

2. Confidentiality

We ask that you read and understand CWS Privacy Notice, available above. If you have any questions please do not hesitate to ask. We can be reached at: studentcounselling@glasgow.ac.uk.

3. Student and staff conduct

You have have read and understood the UoG policy on expectations of student and staff conduct available at: Senate Office: Code of Practice and Unacceptable Behaviour

4. Complaints

You are aware that there is a formal complaints procedure available should you be unhappy with any aspect of the service you have received from CWS: Complaints: Which Procedure

Complaints relating to services provided will be received according to the University’s complaints procedure and should initially be addressed to the member of staff concerned, or their manager, who will then look at options for resolution and assist with further steps, should they need to be taken; which may include:

• Informal resolution within the service
• Formal complaint via the University Procedure
• Complaint to a professional body
• Complaint to a statutory registration body