Policy
Purpose
The purpose of this policy is to explain the University’s arrangements for collecting, storing and using Emergency and Trusted Contact details, and the circumstances in which the University may contact those individuals. It supports the University’s responsibility to protect student health, safety and wellbeing while ensuring that personal information is handled appropriately and in accordance with data protection legislation.
Scope
This policy applies to all students of City St George’s, University of London. It covers the provision and use of Emergency Contact and Trusted Contact information throughout a student’s period of registration.
Principles
Students must provide an Emergency Contact as part of registration and are strongly encouraged to provide a Trusted Contact on an opt-in basis. Students are responsible for keeping these details up to date.
Students must notify the individual(s) they nominate and obtain their consent before sharing their contact details with the University. The Emergency Contact and/or Trusted Contact Information Sheet in Appendix 1 should be shared with them as appropriate.
Emergency Contact details will usually be used following an adverse situation or emergency where there is serious concern for a student’s health and safety, such as a medical emergency, hospital admission, serious incident, or where the University has been unable to contact the student.
Trusted Contact details may be used proactively where the University has serious concerns that a student’s physical or emotional wellbeing, or that of others, is at significant and imminent risk and the contact could help support the student. Trusted Contacts will not be contacted to discuss academic progress.
The University will make every effort to seek the student’s consent before sharing personal information. However, information may be shared without consent on a case-by-case basis where necessary, including where the University considers this to be in the student’s vital interests or where there may be a risk to life or serious harm.
Emergency and Trusted Contact information will be securely held on the University’s electronic student records system, accessed on a need-to-know basis, and handled in accordance with the Data Protection Act 2018 and UK GDPR. It will not be used or shared for unrelated purposes.
Roles and responsibilities
Students: provide an Emergency Contact; decide whether to opt in to providing a Trusted Contact; obtain the nominated person’s consent; provide all requested contact methods; and keep contact details current, including reviewing them during annual re-registration.
Director of Student Experience (or nominee): authorises contact with an Emergency Contact and/or Trusted Contact.
Senior specialist staff: decisions about contacting an Emergency and/or Trusted Contact, particularly where information may be shared without the student’s consent, are taken by experienced senior staff. Usually at least two of the following will discuss the individual circumstances: Head of Student Health & Wellbeing (or nominated senior member of staff); Head of Student Support and Designated Safeguarding Lead (or nominated senior member of staff in Student Support); Director of Student Experience (or nominated senior member of staff in the Student Experience Directorate); and Academic Registrar (or nominated senior member of staff in Academic Services).
Designated Safeguarding Lead: must be consulted where the student is under 18.
Procedure
Emergency contact
An Emergency Contact will usually only be contacted where an emergency has occurred and there is serious concern for the student’s health and safety. This may include a medical emergency or hospital admission, a serious incident, or where the University has been unable to contact the student.
Trusted Contect
A Trusted Contact may be contacted as a proactive, preventative measure if the University believes the student’s physical or emotional wellbeing, or that of others, is at significant risk. Contact will only normally occur where there are serious concerns of significant, imminent risk and where serious or lasting harm may occur. The University will consider the student’s current level of risk, recent behaviour, previous engagement with support, known medical history, concerns raised by others, capacity to make safe decisions, whether sharing information may increase the risk of harm, and the support needed to keep the student safe.
Authorisation and decision-making
Authorisation to speak with an Emergency Contact and/or Trusted Contact must be approved by the Director of Student Experience and/or their nominee. The University will make every effort to seek the student’s consent in advance, although this may not always be possible. Decisions to share information without consent are made on a case-by-case basis.
Data and record keeping
Contact details are securely held on the electronic student records system. Whenever personal information is shared with an Emergency and/or Trusted Contact, the University records the justification for the decision, the nature of the information shared, with whom it was shared, and the time and date of disclosure. This information is securely held within our case management system and access is restricted to staff with responsibility for student Health and Wellbeing.
The University reserves the right to contact an Emergency and/or Trusted Contact without consent where it considers this to be in the student’s vital interests, including where there may be a risk to life or serious harm.
Advice and guidance
Queries about this policy and advice on its application should be referred to Student Health & Wellbeing. Students can also refer to the Student Privacy Notice and the University’s Data Protection Policy for information about how personal data is collected, used and retained.
Failure to comply
Failure by a student to provide an Emergency Contact means the mandatory registration requirement has not been met. Students are responsible for ensuring that nominated contacts have consented to their details being shared and for keeping those details current. Failure to follow the policy may also result in personal information being unavailable when urgent support is required. University staff must handle and disclose Emergency and Trusted Contact information in accordance with this policy and applicable data protection requirements.
Review
This policy is reviewed annually, with allowance for updates where required. The collection of Trusted Contact data on an opt-in basis will remain under review and may be updated in accordance with sector best-practice guidance. The policy is reviewed by Student Health & Wellbeing/Student Experience and submitted to the appropriate University approving authority. The approving authority for the previous version was the Safeguarding and Prevent Steering Group and SLT; the approving authority for this draft version is to be confirmed.