On May 25th 2018, the new EU General Data Protection Regulation (GDPR) became effective. The regulation intends to strengthen and standardise data protection for everyone in the European Union (EU). Among other things, this means that you as a user has a right to know how and why we use the information collected on you, as well as your rights to these data.
When you seek help at Student Counselling Service, you therefore accept that we process your personal data with reference to the data policy indicated below.
Which data do we collect about you?
When seeking help at Student Counselling Service, you will figure in our recording system with the following information:
- Civil registration number
- Phone number
- Place of study
- Reason for enquiry
You will be registered by your civil registration number to ensure that we are able to identify you in our recording system. Additionally, we keep a record of your course of treatment to grant you the best service possible.
What is our legal basis?
Our legal bases for processing your personal data is consent and legitimate interest.
Hence, when seeking help at Student Counselling Service and thus accepting that we process your data, this is considered an implicit consent.
Legitimate interest means that we, in the treatment we give you, use those methods that will ensure the most effective treatment. As such, you receive the best help possible and we have the opportunity to improve within our chosen methods. You can always withdraw your consent. You do so by discontinuing your treatment.
Which treatment methods do we use?
At Student Counselling Service, we use the method Feedback Informed Treatment (FIT), which is an evidence-based tool for dialogue and evaluation, developed by professional practitioners to use in the course of treatment.
The method consists of two simple forms that focus on effect and cooperation. Whenever you show up for an appointment at Student Counselling Service, both you and your counsellor will fill out the forms. The purpose is for the counsellor to be able to develop his/her practice and adjust the treatment to your needs from time to time. This ensures that you get the best help possible.
When we use FIT as method, we register the following information about you:
- First name
- File number
- Information about your wellbeing
As part of the counselling, the counsellor might ask you at some point in your treatment if it would be okay for him/her to record one of your appointments on video. This is done as part of the method called deliberate practice.
We use the method at Student Counselling Service to develop the counselling practice. Whether you agree or decline is completely up to you. If agreeing, your counsellor will subsequently use it for feedback and sparring from the rest of the counsellors at Student Counselling Service and possible from an external supervisor. Both are subject to confidentiality. Your counsellor deletes the recording as soon as having received feedback, yet no later than one month after recording it. The recording will thence not figure anywhere.
For how long do we keep your data?
When concluding your course at Student Counselling Service, your data will be deleted according to the rules on storing of records, as stated in the Act on Medical Record-Keeping §15. This means that we are obligated to keep your record for five years if you have had sessions with a psychologists, and 10 years if you have seen one of our psychiatrists for a consultation. If you have had sessions with one of our social workers, you can choose to have your data anonymised immediately after concluding your sessions.
If you do not make use of this, we keep your data for five years, after which they will be deleted. Regardless, after your course of treatment, your FIT-data will be pseudonymised and only used as follow-up data for research and as documentation on the effect of FIT as method.
If you have received SPS-counselling (special pedagogical support), we are obligated to keep your data for the remainder of the contract, due to contractual commitments to the National Agency for Education and Quality.
Disclosure of information?
We are not going to share your information with anyone, except if you have given us your written consent. For instance, this could mean a consent that allows your parents, siblings, partner or any other contact person to call and receive information about your course of treatment, or in case your record should be forwarded to your doctor.
As data subject, you have a number of rights that we can help you with. Your rights include the following:
You have the right to gain insights into which personal information about you that we process, with what purposes we process the information, and whether we disclose personal information to others.
You have the right to rectify incorrect personal information about you.
In some cases, you have the right to have certain personal information about you erased.
In some cases, you have the right to limited processing of your personal information, meaning that we only keep your data in a given period.
You have the right to so-called data portability of your personal information, insofar as it concerns the personal data we have collected based on your consent.
In some cases, you have the right to take exception to our processing of your personal information based on reasons and circumstances related to your specific situation. Insofar as we have obtained your consent to partly process your data, you have the right to revoke your consent at any time, after which the personal data (which have been obtained based on your consent) will be deleted.
If you wish to make use of the rights as described above, you must address firstname.lastname@example.org.
We commit ourselves to doing everything in our power to meet your requests regarding our processing of your personal information. However, depending on the case’s complexity, some processing time is to be expected. Our goal is to start processing and handling incoming requests/cases within two months of receiving the written request.
If you find our answer to be unsatisfactory after having processed your case, you can address our Data Protection Officer DPO team ApS.
Their phone number is 71 74 90 20 (Monday to Friday from 8am-5pm) and e-mail address email@example.com.
If you wish to complain, this can be done by contacting The Danish Data Protection Agency.