Counselling, Mental Health and Wellbeing Service privacy notice

This privacy notice explains:

• who we are
• how and why we collect and use personal information about you
• what personal data is collected and held about you in the Counselling, Mental Health and Wellbeing Service’s database
• our purposes and lawful bases for processing
• who we share your personal data with
• relevant retention periods
• how you can exercise your privacy rights

This notice provides information in addition to the University’s Student Privacy Notice. Please read it and if you have any questions contact us using the details provided.

Who we are

Throughout this notice, “University”, “we”, “our” and “us” refer to the Manchester Metropolitan University, an exempt charity under Schedule 2 to the Charities Act 1993 (amended by the Charities Act 2011). The University is the Data Controller in respect of the personal data you provide as part of using our Disability Service.

The University is registered as a data controller with the Information Commissioner’s Office (ICO). We manage personal data in accordance with the General Data Protection Regulation (GDPR) and the University’s Data Protection Policy.

The personal data we process

We collect and process certain data about you, including information of a sensitive nature. This includes:

• the information you provided when you made first contact with us (whether in person, by telephone, email or any other form of communication).
• the information you provided when you completed the service registration form (including your name, date of birth, address, phone number, your GP and whether you have a disability).
• the information you provided when you completed the Counselling, Mental Health and Wellbeing Service consent form.
• a record of each contact we have had with you (whether in person or otherwise, scheduled appointment, drop-in or other), including short notes about each contact.
• to ensure that our service is accessible to all of our student population, our service registration form also gives you the option to provide information to support equality and diversity monitoring (such as your age, ethnicity, gender identity, religion, sex, sexual orientation and whether you have a disability).

What is the purpose and lawful basis of the processing?

Collecting and processing information from you in order to effectively deliver support 

• Confirming that you are a student.
• Registering you as a client of the Counselling, Mental Health and Wellbeing Service.
• Carrying out a drop-in, initial assessment or other scheduled appointment with you by any of the Counselling, Mental Health and Wellbeing team.
• To provide you with our counselling, mental health and wellbeing services.
• To make disclosures to other university services and academic departments,
• Making a record of each contact we have with you (whether in person, telephone, email or other means).
• Carrying out any administration relating to your contact with the Counselling, Mental Health and Wellbeing Service.
• Dealing with your enquiries and to make contact with you when you request an appointment or other service with the Counselling, Mental Health and Wellbeing Service.

Lawful basis: Performance of a contract

We need to collect and process certain information from you in order to effectively deliver our counselling and wellbeing services to you in accordance with the Student contract.

Lawful basis: Public task

In order to a perform our counselling and wellbeing services, as a public authority acting in the public interest. This is to protect you, to enable us to deliver an efficient service, and to comply with the British Association for Counselling and Psychotherapy Ethical Framework for the Counselling Professions. 

Data Protection Act 2018 Schedule 1, Part 2 – s17 – necessary for the provision of a confidential counselling service.

Sharing information with external parties where it is necessary in relation to your counselling, mental health and wellbeing support 

• To make disclosures to your GP, your psychologist, your psychiatrist, your emergency / trusted contact and others as directed by you as per your instructions within your Counselling, Mental Health and Wellbeing Service Consent Form.
• Writing any letters or emails to third parties on your behalf and with your prior agreement.
• Making any telephone calls to third parties on your behalf and with your prior agreement.

Lawful basis: Consent

We make these disclosures as per your consent and instructions.

Handling complaints and obtaining feedback on the service you have received

• Handling any complaints you may have so that we can improve our business.
• Invite you to provide feedback on our service and participate in surveys.

Lawful basis: Legitimate interests

 We process personal data for these purposes in ways which you would reasonably expect and which we believe have minimal privacy impact.

Referrals to our Disability Service

• To make disclosures to our internal Disability Service so they may determine whether any adjustments need to be made for you if you have declared a disability.
• Taking account of, and provide additional support for, any disabilities, health issues or conditions.

Lawful basis: Legal obligation

Under the Equality Act 2010 we are obliged to consider reasonable adjustments and offer support on the grounds on health and disability.

In the event of significant concerns for your immediate safety or wellbeing 

• Protecting your vital interests, or those of another party, in exceptional circumstances and emergencies.
• Making disclosures to third parties, who we believe may be able to assist, in exceptional circumstances, such as significant concern for immediate safety or welfare.

Lawful basis: Vital interests

In the event of significant concerns for your immediate safety or wellbeing we may contact others who may be in a position to support you, typically your GP, and your emergency or trusted contact. We would always seek to discuss this course of action with you but if our concerns are for your immediate safety or wellbeing, we may do so without your consent.

Undertaking equality and diversity monitoring

• Undertake equality and diversity monitoring of users of our services to seek to ensure they are accessible to all our student population.

Lawful basis: Data Protection Act 2018 Schedule 1, Part 2 – s8

Necessary for the purposes of identifying or keeping under review the existence or absence of equality of opportunity or treatment.

The right to withdraw consent

Where  we have collected and processed your personal information with your consent, (as outlined above) then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. You can withdraw your consent by writing to counselling@mmu.ac.uk stating your Name, your student ID number and in the e-mail subject state: Withdrawal of Consent.

Data retention

Your personal data will only be retained for as long as it is necessary in accordance with the University’s Retention and Disposal Schedule. Specifically, we will retain your Counselling, Mental Health and Wellbeing Service personal data for a period of 6 years after our last contact with you, after which it will be deleted unless we are required to continue to retain this information due to ongoing legal proceedings.

Your rights in respect of the processing

The GDPR provides data subjects with the following data subject rights:

• The right to be informed – this privacy notice assists with fulfilling these obligations.
• The right of access.
• The right to rectification.
• The right to erasure.
• The right to restrict processing.
• The right to data portability.
• The right to object.

Please note, that these rights apply in certain circumstances, for example according to the lawful basis utilised by the University. The right of access to personal information held about you exists in order to be aware of, and verify, the lawfulness of the processing. To exercise these rights please write to: dataprotection@mmu.ac.uk.

How to contact us

For questions or concerns about this Privacy Notice or how we store and use your personal information, please contact counselling@mmu.ac.uk in the first instance.

Our Data Protection Officer can also be contacted by email at dataprotection@mmu.ac.uk, by calling 0161 247 3331 or in writing to: Data Protection Officer, Legal Services, All Saints Building, Manchester Metropolitan University, Manchester, M15 6BH.

Right to lodge a complaint with the supervisory authority

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) as the supervisory authority in respect of the processing of your personal data. We would encourage you to use our internal complaints procedure through our initial contact and the University Data Protection Officer, prior to contacting the ICO. If you wish to contact the ICO, the following contact information can be used: casework@ico.org.uk or telephone: 0303 123 1113. For any further contact information please see: https://ico.org.uk/global/contact- us/.

Updates to this privacy notice

We may update this privacy notice from time to time in response to changing legal, technical or business developments. When we update our privacy notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material privacy notice changes if and where this is required by applicable data protection laws.

This privacy notice was last updated on: 20 October 2023