Policy and Guidelines

Find out what you need to know about confidentiality, data protection and records.


The Counselling Service has a strict code of confidentiality and will not pass on any information regarding your counselling unless in exceptional circumstances. Counsellors have a duty of care towards students and work to the Ethical Framework for Good Practice of the British Association for Counselling and Psychotherapy.

View the BACP ethical framework

You can also download a PDF version of our Counselling & Mental Wellbeing contract (53 kB). This also outlines how we deal with cancelations and non-attendance.

Data protection policy

The Counselling and Mental Wellbeing team keep a record of all students’ notes in accordance with British Association of Counselling and Psychotherapy Guidance, and GDPR legislation.

This will be used:

  • To ensure safe and ethical practice
  • For statistical purposes
  • To track students' journeys through the service

When we might break confidentiality

While we are a confidential service, there are circumstances in which we may break confidentiality, although this is unusual. Examples of this include:

  • When you provide express permission
  • If a court orders a student’s notes to be made available for a criminal investigation/court case
  • Where the counsellor believes that you are at risk of serious harm to yourself or others

This is including but not limited to:

  • Immediate and advanced suicide plans
  • Child protection (see below) 
  • Nursing & Fitness to Practise (see below)

Your counsellor will discuss any concerns with you prior to passing on information to a third party. However, there are exceptions as stated above, and if the situation is critical, we may have to pass on the information directly.

Recording of Concern & Risk

If a counsellor is concerned by issues raised by you related to risk to self or others, they will bring this to the attention of the Head of Student Counselling and Mental Wellbeing to ensure safe practice. This is also recorded confidentially in your file.

If you have any questions or concerns regarding this, please speak to your counsellor or contact counselling@napier.ac.uk

Nursing & fitness to practice

If you are a nursing student we recognise that you are a practising professional as well as a student, and could have a greater opportunity during professional training to do harm to others. If a Counsellor has concerns about your 'fitness to practise', in most cases we will raise this with you. To ensure safe counselling practice, we may bring any concerns to the Head of Student Counselling and Mental Wellbeing.

 If concerns are serious then the matter will be dealt with under the University’s 'Student Disciplinary and Fitness to Practice' regulations, which can be found on the Regulations page.

Record keeping and data protection

Counsellors keep secure records of sessions. These are stored electronically on a secure database and kept in accordance with BACP guidelines.

Students rights are protected under the General Data Protection Regulation (EU) 2016/679. For more information, please review sections 7 and 8 of the Data Protection Code of Practice.

You will be asked to fill in an anonymous evaluation form at the end of your counselling which is used to improve the service. All content in this evaluation is strictly confidential and anonymised.

Child Protection & Serious Risk

If there is a child protection issue or a serious risk to your wellbeing, advice will be sought by the Counsellor from the Head of Student Counselling and Mental Wellbeing who will make a decision if there is a need to contact social services following City of Edinburgh Council’s GIRFEC (Getting it Right for Every Child) guidelines or Adult Protection guidelines. 

Information on GIRFIC can be found here.

Click here for Adult Protection guidelines.

Registration with a local GP (Doctor)

In accordance with university regulations (see below) please ensure you are registered with a GP (Doctor) when applying for counselling. This is to protect both you and the Counsellor should you become mentally unwell. We will not contact your GP with details of your counselling unless in exceptional circumstances (please see Confidentiality section). Your GP must be local to your place of residence while studying at the university. 

International students: Please note that insurance schemes such as CISI do not count as being registered with a GP. 

Package of Care: Please contact us if you have any concerns regarding registering with a GP and any impact on your package of care, such as NHS Continuing Health Care. If you are in the process of registering with a GP, you can attend an assessment appointment but any further counselling will only take place once you have confirmed your registration with a GP. 

If you don’t wish to register with a GP or share your GP details with us, you can be referred to the Edinburgh Napier Students' Association for support.