Version 1.0
Effective date: 28 September 2026
Last reviewed: 28 September 2026<\/p>\n\n\n\n
AccessWays respects students\u2019 privacy and treats information obtained through Non-Medical Help (NMH) support confidentially.<\/p>\n\n\n\n
This policy explains how confidential information may be used or shared in connection with AccessWays services and the circumstances in which confidentiality may be limited.<\/p>\n\n\n\n
It should be read alongside the AccessWays Privacy Notice, Terms of Support and Safeguarding and Student Welfare Policy.<\/p>\n\n\n\n
Translations are provided for convenience only. If there is any inconsistency or difference in meaning, the English version shall prevail.<\/p>\n\n\n\n
Information that a student shares during support will normally be treated as confidential and will not be disclosed unnecessarily.<\/p>\n\n\n\n
This may include information about:<\/p>\n\n\n\n
AccessWays will seek to collect, use and retain only information reasonably necessary for providing and administering its services and meeting applicable legal, professional and DSA requirements.<\/p>\n\n\n\n
Confidentiality does not mean that everything discussed during support must remain secret in all circumstances.<\/p>\n\n\n\n
AccessWays may need to use or share limited information as part of providing and administering NMH support.<\/p>\n\n\n\n
Depending on the circumstances, this may involve Student Finance England (SFE), the Student Loans Company (SLC), the Department for Education (DfE), the student’s higher education provider, Needs Assessment Centre, relevant professional or regulatory bodies, or service providers acting on behalf of AccessWays.<\/p>\n\n\n\n
Information shared may include information reasonably necessary to:<\/p>\n\n\n\n
AccessWays will not routinely provide another organisation with unrestricted information about what a student discusses during an NMH session merely because that organisation is involved in the student’s education or DSA support.<\/p>\n\n\n\n
AccessWays may maintain appropriate records about support provided, including dates, times, attendance, agreed support activities, relevant Work or Learning Plan information and sufficient information about the support undertaken.<\/p>\n\n\n\n
Records should contain only sufficient relevant information for legitimate service, DSA, professional, audit or legal purposes.<\/p>\n\n\n\n
AccessWays will avoid unnecessarily detailed records of personal disclosures where those details are not relevant to the purpose of the record.<\/p>\n\n\n\n
SFE currently requires providers to retain clear evidence of work undertaken and, where applicable, Work or Learning Plans containing relevant session information.<\/p>\n\n\n\n
Where appropriate, AccessWays may ask a student for consent before sharing information with another person or organisation.<\/p>\n\n\n\n
Where consent is relied upon, AccessWays will seek to make clear what information is proposed to be shared, with whom and for what purpose.<\/p>\n\n\n\n
A student may normally decline or withdraw consent where consent is the basis being relied upon.<\/p>\n\n\n\n
However, consent is not the only possible basis for information sharing<\/strong>. Withdrawal or refusal of consent does not prevent AccessWays from using or sharing information where another lawful basis applies or where disclosure is otherwise required or permitted by law.<\/p>\n\n\n\n AccessWays may use or disclose relevant information without the student’s consent where there is an appropriate lawful basis and doing so is necessary and proportionate.<\/p>\n\n\n\n Depending on the circumstances, this may include situations involving:<\/p>\n\n\n\n AccessWays will consider the circumstances rather than treating the existence of a concern or allegation as automatically justifying unrestricted disclosure.<\/p>\n\n\n\n Where information is shared, AccessWays will seek to disclose only information reasonably necessary for the relevant purpose.<\/p>\n\n\n\n A disclosure of disability, neurodivergence, distress or a mental-health difficulty does not by itself<\/strong> mean that confidentiality will be broken.<\/p>\n\n\n\n Where AccessWays reasonably considers that information needs to be shared because of a serious safeguarding or safety concern, it will act in accordance with the AccessWays Safeguarding and Student Welfare Policy.<\/p>\n\n\n\n Where appropriate and safe to do so, AccessWays will normally tell the student about a proposed disclosure.<\/p>\n\n\n\n There may be circumstances where prior notification is inappropriate, impracticable or could materially increase risk, prejudice an appropriate investigation or undermine the purpose of the disclosure.<\/p>\n\n\n\n This reflects the safeguarding approach already adopted by AccessWays. Pasted text<\/p>\n\n\n\n AccessWays will not normally disclose confidential information to a student’s parent, family member, friend, partner or other third party merely because that person requests it.<\/p>\n\n\n\n Where appropriate, AccessWays may ask the student for permission before discussing their support with another person.<\/p>\n\n\n\n AccessWays may verify the identity or authority of a person requesting information before making a disclosure.<\/p>\n\n\n\n Information may nevertheless be shared without the student’s permission where there is another appropriate lawful basis or legal requirement to do so.<\/p>\n\n\n\n Where a complaint, safeguarding allegation, audit or investigation concerns AccessWays, AccessWays may retain, review and use relevant records and correspondence in order to understand and respond to the matter.<\/p>\n\n\n\n Relevant information may be disclosed where reasonably necessary to an appropriate authority, DfE, SLC, insurer, professional body, legal or professional adviser, or another person or organisation with a legitimate role in the matter.<\/p>\n\n\n\n An allegation will not automatically be treated as established fact merely because it has been made.<\/p>\n\n\n\n AccessWays will seek to distinguish between factual information, information reported by another person and professional judgement when recording or communicating relevant concerns.<\/p>\n\n\n\n DfE’s NMH investigation process expressly provides for evidence gathering that may include correspondence, telephone recordings, invoicing information and other information held by SLC, and providers may be asked to provide information during an investigation.<\/p>\n\n\n\n A request that something be kept \u201coff the record\u201d does not necessarily prevent AccessWays from making an appropriate record where this is reasonably necessary for safeguarding, DSA administration, professional accountability, complaints, legal compliance or another legitimate purpose.<\/p>\n\n\n\n Where appropriate, AccessWays will explain this to the student.<\/p>\n\n\n\n Records will be factual, proportionate and limited to information reasonably relevant to their purpose.<\/p>\n\n\n\n AccessWays will not knowingly alter, conceal or destroy relevant records in order to avoid legitimate audit, investigation, complaint or legal processes.<\/p>\n\n\n\n Confidential information will be handled and stored with appropriate security measures.<\/p>\n\n\n\n Access to information will be limited appropriately, and external service providers handling personal information on behalf of AccessWays will be subject to appropriate data-protection arrangements where required.<\/p>\n\n\n\n Personal information will be processed in accordance with the AccessWays Privacy Notice and applicable data protection law.<\/p>\n\n\n\n This policy explains AccessWays’ approach to confidentiality and information sharing. The Privacy Notice provides further information about the purposes and lawful bases for processing personal data, retention, individual rights and how to raise a data-protection concern.<\/p>\n\n\n\n AccessWays may update this policy where reasonably necessary because of changes to law, DSA requirements, professional standards or the operation of its services.<\/p>\n\n\n\n The current version and effective date will be made available to students.<\/p>\n\n\n\n <\/p>","protected":false},"excerpt":{"rendered":" Version 1.0Effective date: 28 September 2026Last reviewed: 28 September 2026 AccessWays respects students\u2019 privacy and treats information obtained through Non-Medical Help (NMH) support confidentially. This policy explains how confidential information may be used or shared in connection with AccessWays services and the circumstances in which confidentiality may be limited. It should be read alongside the […]<\/p>\n","protected":false},"author":1,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"footnotes":""},"class_list":["post-34","page","type-page","status-publish","hentry"],"yoast_head":"\n5. Sharing information without consent<\/h3>\n\n\n\n
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6. Safeguarding and welfare<\/h3>\n\n\n\n
7. Requests from family members and other third parties<\/h3>\n\n\n\n
8. Complaints, allegations and investigations<\/h3>\n\n\n\n
9. Confidentiality does not prevent appropriate record-keeping<\/h3>\n\n\n\n
10. Security and data protection<\/h3>\n\n\n\n
11. Changes to this policy<\/h3>\n\n\n\n