Privacy notice: student support

This privacy notice tells you what to expect us to do with your personal information when you seek support from our student support teams within Student Services or a need for support is identified elsewhere in the University and referred to Student Services. Personal information (or personal data) is any information which relates to and identifies you. Data protection legislation (the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018) set out how we should handle your personal information. 

The University of Lancashire (formerly the University of Central Lancashire) is the controller for the personal information we process, unless otherwise stated. We are registered with the Information Commissioner’s Office and our registration number is Z5512420.

There are many ways you can contact the University, including by phone, email, social media and post. See our main contact details. 

You can contact Student Support using any of the contact information on our pages on the Student Hub. 

The University's Information Governance Manager and Data Protection Officer can be contacted via email. Further information and contact details can be found on the data protection pages of our website.

Student Services Support Teams will use the personal data you provide to us directly when you approach us for support. This will vary depending on the support you ask us for. It could include your name and contact details; financial information; details of personal and family circumstances; information about your health (including mental health) or that of your family, and any disabilities you tell us about, as well as any other matters for which you seek support. 

We will use information provided to us by other areas of the University in the event that:

• A member of staff has significant concerns for your health, safety or wellbeing and contacts us for advice or to raise a concern which we then act upon to offer support to you; 
• You declare a disability during online enrolment (unless you are solely enrolled at one of our partner institutions);
• You declare a disability or raise a support need during another University process, such as when you apply for mitigating circumstances, have an occupational health assessment, make an academic appeal, or go through the Support to Study or Fitness to Practise procedure;
• You are referred to us for support by a member of your academic course team or School support team;
• You apply for financial support and we need information, such as attendance information, from other areas of the University for the purposes of your application.

If you declare a disability and seek support from us and external support agencies, we will receive information from external parties relating to your disability assessments and support needs, and associated funding.

We will also use information provided by third parties such as the police, local authorities, employers (if you are an apprentice or student on placement) or other support agencies in the event that they raise concerns for your wellbeing and ask the University to contact you to discuss whether or not you need our support.

We will use your personal data for a variety of purposes to provide support to you. The main purposes are set out below:

Administration

We will use your information to set up a record of contact on our secure casework management system so that we can ensure our teams can fully support you and have a history of your contact with us and the support we have provided. This helps staff in our teams provide continuity of support and relevant expertise.

Communicating with you

We will use your information to communicate effectively with you via email, post, telephone, text (SMS), social media or other methods, as appropriate.

We will contact you regarding any actions or support we have agreed to provide you with and follow-up with you about your support needs.

We will also contact you with information about our services or to seek your feedback on the services you have already received from us.

Providing disability support

During your time as a student or apprentice at the University (including while you are on placement), if you tell us about a disability at any point e.g. during enrolment, as part of any University process such as mitigating circumstances, application for financial support, academic appeal or Fitness to Practise, or by telling a member of staff directly, unless you are solely enrolled at one of our partner institutions, this information will be shared with the Inclusive Support Team. The Inclusive Support Team will receive that information and will contact you to discuss your support needs and any reasonable adjustments which may need to be put in place. The team will discuss with you how we might need to share your information with other relevant colleagues (or external parties such as placement providers) involved in the delivery of your support and implementation of reasonable adjustments. At this stage, you will be given the option to say that you want information about your disability to remain confidential within Student Services. This may mean that support for your disability-related needs may not be available or could be limited.

Providing wellbeing and mental health support

If we are supporting you in relation to a wellbeing issue, such as domestic abuse, sexual misconduct, bullying or harassment, or mental health issues, we may need to share information with academic school staff, other professional services such as the Academic Registry which manages mitigating circumstances and other University processes, placement teams, your employer (if you are an apprentice) or anyone else you might suggest we contact to help provide the support you need. For example, we might help you talk to your Course Leader about how you can catch up on your studies or get an extension on an assessment. We will usually ask for your consent to share information in these cases as it will be beneficial but not essential for us to work with colleagues in these other areas of the University, and external parties such as your employer (if you are an apprentice); however in some rare cases we may need to share information without your consent to ensure your safety and wellbeing.

Responding to a referral from your academic course team

If you have been referred for support by a member of your academic course team, including your Student Coach or Personal Tutor, we will discuss with you what, if any, information you would like us to provide to them regarding your engagement with the support we can offer. This can help your course team to provide you with additional support with your studies and reassure them that you are seeking support.

Assessing and providing financial support

If you apply for financial support such as a hardship loan or grant, we will use the information you provide on your application form to assess your eligibility for financial support and determine the amount of any support we are able to provide. The financial support we can offer is there to support students while studying, so we will check that your attendance levels meet the levels expected as set out in our Student Engagement and Attendance Policy as part of your application process. We will also refer to any previous applications for financial support you have made.

If you do not provide all the information we request on the application form, we cannot determine your eligibility for support. Where we request information about any disabilities you or your children may have for the purposes of your application, it is your choice whether or not to provide this information; however we cannot fully assess your eligibility for support if you do not tell us about all expenditure you incur. This means that your application may not be successful if you choose not to tell us this type of information. If your application is successful, we will use your information to administer the support you have applied for.

The University keeps records about all applications (whether they are successful or not) to enable us to handle any appeals, to comply with the University’s Financial Regulations to show how much financial support we have provided and to whom, and to investigate allegations of fraud. We retain information on all applications for audit purposes so that we can comply with our legal obligations to demonstrate that we are administering public funds appropriately.

Contacting your emergency contact

During the University enrolment process and also when you receive support from Student Services, you will be asked for details of a person we can contact in the event that we have significant concerns about your safety or wellbeing.

If an emergency arises and we have serious concerns for your wellbeing and/or safety and you are unable to provide consent, we will act in your best interests to contact this person without asking you first, to ensure your continued wellbeing and safety. We will only do this in exceptional circumstances, when the law allows it, so this should not inhibit you from being open and honest about seeking support.

Student Services will follow the decision-making process for sharing information when considering contacting your emergency contact without your consent.

Supporting fitness to practise, support to study and regulatory requirements

In some cases, if you are on a professionally-regulated course such as Social Work or Nursing, we may need to share some of your information with your course team so that it can be considered in relation to the regulatory requirements of your course (please refer to your course handbook or ask your course team for details of these requirements). We will do this if we have concerns for your safety or wellbeing, or the safety and wellbeing of others. We will usually discuss such concerns with you first and support you with informing your course team yourself; however we will discuss concerns with your course team directly if necessary so that they can take any steps necessary to ensure that the regulatory requirements relating to your course are being met, and the safety and wellbeing of you and/or others is ensured.

Research, reporting and statistics

We will use and analyse your information to compile statistics and to undertake surveys to help with corporate planning, reporting and University administration, to improve our services and to benefit current and future students.

Your information will also be used for research purposes, including research by University staff for planning and development purposes, and University researchers for the purposes of academic research. Your information will only be used in this way where the law allows us to and we consider it appropriate under the circumstances. Your information will be treated sensitively and we will remove as much identifying information as we can before it is used in any research. 

Any reports, statistics or research papers we produce will not contain any information which will identify you.

Monitoring and compliance

We will use your information to ensure and monitor our compliance with legislation including laws relating to equality, health and safety and immigration. We will also use your information to monitor our compliance with regulatory requirements set by external agencies.

The University can only process personal data about you if there is a lawful basis from the UK GDPR which allows us to do so.

When you or another person contacts Student Services to ask us to provide support to you, we will create a record for you on our secure case management system to show that we have been contacted and to show the interactions we have had with you regarding the provision of support. We process some information, such as the fact we have been contacted and high-level details of the support we have offered and/or provided to you, to demonstrate that we have received and acted on the request for support and supported you to the best of our abilities. The lawful bases on which we rely for processing this type of information are as follows:

Article 6(1)(c), which allows us to process personal data when it is necessary to comply with a legal obligation. We are legally required to provide some reports and statistics to external agencies, as well as keeping records and monitoring compliance with laws relating to equality, charities and the administration of public funds, and the requirement to comply with the registration conditions imposed on us by the Office for Students under the Higher Education and Research Act 2017, among other things.

Article 6(1)(e), which allows us to process personal data where it is necessary to perform a task in the public interest. The provision of student support, as well as internal and external reporting and monitoring, teaching and research, and auditing, is carried out as part of our public tasks (or in some cases, the public tasks of another organisation). The majority of the processing of personal data we undertake to provide student support is carried out in reliance on Article 6(1)(e) UK GDPR.

We also process some information only if you provide your consent. In this case, Article 6(1)(a) applies, and Article 9(2)(a) also applies where the information is special category data (special category data is information about your race, ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data used for ID purposes, health, sex life or sexual orientation).

We only rely on your consent to process some of the personal information you provide to us when accessing our services, such as when we ask if you want us to share information with your course team in relation to any support you require e.g. disability support. It will be clear where we are relying on your consent to process your information because consent will be requested directly from you. When you are asked for consent, we will explain why we are asking and what we will do with your information if you provide consent. Consent can be withdrawn at any time.

If you wish to withdraw your consent at any time, or no longer wish to engage with support, you can email wellbeing@uclan.ac.uk.

If you withdraw your consent for a specific activity, such as sharing your information for a certain purpose, we will stop using your information in that way unless exceptional overriding circumstances apply, such as significant concerns for your safety or wellbeing. If you withdraw your consent, we will still retain all the information we have used to provide support to you up to the point you withdraw it.

We don’t ask for your consent for most of the processing of personal data we undertake to provide support to you or to keep associated records of our interactions and the support we have offered and provided to you, because we need the information to carry out our public tasks i.e. providing student support, and to comply with legal obligations relating to equality and the administration of charities (see above). We only ask for your consent to do something when you have a choice about saying yes or no. Where use of your information is necessary for a particular purpose, meaning we cannot offer you a choice, we rely on one of the other lawful bases explained above and below.

When we process special category data and data about criminal convictions for the purposes set out in this notice, we need an additional lawful basis for the processing as well as one of the lawful bases set out above. To use special category data, we rely on the following additional lawful bases from the UK GDPR and DPA:

Article 9(2)(g) UK GDPR, which allows us to process special category data if the processing is necessary in the substantial public interest and there is a basis to do so in law. The law which allows us to rely on Article 9(2)(g) is section 10 DPA by virtue of Schedule 1 DPA, which also provides the lawful basis for processing data about criminal convictions. The specific conditions from Schedule 1 DPA on which we rely for this type of processing are as follows:

• Schedule 1(6), which allows us to process special category data and/or data about criminal convictions to comply with a statutory or legal function. Such functions include the duties set out in the Equality Act 2010 and the requirement to comply with the registration conditions imposed on us by the Office for Students under the Higher Education and Research Act 2017.
• Schedule 1(8), which allows us to process special category data to monitor equality of opportunity or treatment.
• Schedule 1(10), which allows us to process special category data and/or data about criminal convictions to prevent or detect unlawful acts.
• Schedule 1(11), which allows us to process special category data and/or data about criminal convictions to protect the public against dishonesty, unfitness, etc.
• Schedule 1(17), which allows us to process special category data and/or data about criminal convictions to provide confidential counselling or similar services.
• Schedule 1(18), which allows us to process special category data and/or data about criminal convictions to safeguard individuals at risk and children.

When processing special category data or data about criminal convictions in reliance on the above conditions from Schedule 1 DPA the University must have an appropriate policy document. Read data protection: processing special category data and criminal convictions data.

Article 9(2)(j) UK GDPR, which allows us to process special category data for archiving, scientific or historical research purposes or statistical purposes, where there is a basis to do so in law. The law which allows us to rely on this basis is section 10 DPA by virtue of Schedule 1(4) DPA. We may also rely on Schedule 1(4) DPA if we process personal data relating to criminal convictions for archiving, research or statistical purposes.

We will share your information within the University in the ways described in the ‘Why do we use your personal data?’ section of this privacy notice. We will usually ask for your consent to share your information but in some cases, we will share information without asking you first. Please see below for further details about this.

We only share your personal data with those outside the University where the law allows us to and we consider it to be appropriate under the circumstances. In most circumstances, the information held by the University for the purposes of providing support to you remains confidential and is not shared with any other parties outside the University without your consent.

In rare circumstances, we will share your information with external organisations without your consent. We will also share your information with other areas of the University in some cases. These circumstances will include, but are not limited to, the following:

• We believe that you may be at risk of causing serious harm to yourself or someone else.
• We believe that an adult at risk or a child is at risk of harm based on information you have given to us. That adult at risk or child might be you or someone else.
• We are required to do so by law (e.g. in cases of money laundering, fraud or acts of terrorism).
• You are studying on a regulated course, and based on information you have given to us, we have concerns that you may no longer be able to meet the regulatory requirements of your course.
• To ensure informed and supported decision-making when action is being taken under our Support to Study Policy and Procedure.

In such cases, we will share information with:

• The emergency services
• A local or central government authority
• Health bodies such as the NHS
• The regulatory body responsible for your course or intended profession.
• Any other external party that has a legitimate need to know the information in any of the circumstances set out above.
• Your course team or another area of the University that has a legitimate need to know.
• Internal or external auditors and our fraud response group.

We may also disclose your information to other organisations so that they can provide services on our behalf e.g. hosted IT services and systems. These organisations are called processors. We use processors who are third parties who provide elements of services for us. We have contracts in place with our processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will hold it securely and retain it for the period we instruct.    

Occasionally we may need to send your personal information outside the EEA e.g. to obtain a service from a processor. We only transfer personal data outside the EEA if there is a lawful basis to do so and appropriate safeguards are put in place to protect your information and ensure it remains secure.

The University will keep information about the support we have offered and provided to you for six years after you withdraw from your studies or graduate.

After any meeting/support session with student support teams within Student Services, any paper records relating to your case will be confidentially destroyed once notes have been added to our case management system. Any paper items you give us will be returned to you after being electronically scanned and uploaded onto the case management system.   

Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information. Further information about each of these rights can be found on the Information Commissioner’s Office website. To make a request to exercise any of these rights, please email the Information Governance Manager & Data Protection Officer.

Your right of access

You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. For further information or to make a request, please see the data protection pages of our website.

Your right to rectification

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.

Your right to erasure

You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing

You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing

You have the right to object to any processing we carry out, if we carry it out on the basis that it forms part of our public task or is in our legitimate interests. You also have the right to object to your personal information being used for direct marketing purposes.

Your right to data portability

This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information because we have your consent or because it is necessary for your student contract, and the processing is automated.

We work to high standards when it comes to processing your personal information. If you have queries or concerns, please contact us in Student Services and we will respond. Alternatively, you can contact the Information Governance Manager & Data Protection Officer.

If you remain dissatisfied, you can make a complaint about the way we process your personal information to the Information Commissioner’s Office, which is the UK supervisory authority for data protection. Further information can be found on the data protection pages of our website.