Privacy & Data Protection Policy
Mentorium Minds
Version: 2.0
Effective Date: 7 July 2026
Review Date: 7 July 2027
1. Purpose
Mentorium Minds is committed to protecting the privacy, confidentiality and security of the personal information entrusted to us.
This policy explains how personal information is collected, used, stored, shared and protected in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and other applicable data protection legislation.
2. Scope
This policy applies to all personal information processed by Mentorium Minds in connection with the delivery of its services, including:
Specialist Mentoring funded through Disabled Students' Allowance (DSA)
Workplace coaching and mentoring funded through Access to Work (ATW)
Privately funded mentoring services
It applies to information relating to:
Current clients
Former clients
Prospective clients
Universities, employers, referrers and funding organisations where appropriate
Individuals making enquiries through the Mentorium Minds website or by email
3. Data Protection Principles
Mentorium Minds is committed to ensuring that personal data is:
Processed lawfully, fairly and transparently.
Collected for specified, explicit and legitimate purposes.
Limited to the information necessary to provide services.
Accurate and kept up to date where reasonably possible.
Stored securely and protected against unauthorised access.
Retained only for as long as necessary.
Processed in a manner that ensures appropriate security and confidentiality.
4. Information We May Collect
Depending on the services provided, Mentorium Minds may collect:
Name.
Contact details.
University or employer details.
Course or employment information.
Funding information (including DSA or Access to Work where applicable).
Session records and mentoring notes.
Emails and correspondence.
Appointment and scheduling information.
Goals, agreed actions and progress notes.
Emergency contact details where appropriate.
Invoice and payment information for privately funded services.
Where necessary, Mentorium Minds may also process special category data, including information relating to health, disability or neurodivergence, where this is necessary to provide appropriate support.
5. Lawful Basis for Processing
Personal information will be processed using one or more lawful bases under UK GDPR, including:
Performance of a contract.
Compliance with legal obligations.
Legitimate interests in delivering safe and effective mentoring services.
Explicit consent where required.
Special category data will only be processed where a valid legal basis and an appropriate condition under UK GDPR applies.
6. Confidentiality
Mentorium Minds respects the confidentiality of all clients.
Information shared during mentoring or coaching sessions will normally remain confidential and will not be disclosed without the client's knowledge or consent.
Exceptions may apply where disclosure is necessary:
To protect an individual from serious harm.
To safeguard children or adults at risk.
Where disclosure is required by law.
To comply with regulatory, funding, insurance or auditing requirements.
Where disclosure is otherwise legally justified.
Where appropriate and safe to do so, clients will normally be informed before information is shared.
7. Storage and Security
Mentorium Minds takes appropriate technical and organisational measures to protect personal information.
Information may be stored using:
Password-protected computers and mobile devices.
Secure email systems.
Secure cloud storage (including Google Workspace).
Password-protected electronic records.
Encrypted systems where appropriate.
Additional security measures include:
Strong passwords.
Two-factor authentication where available.
Regular software updates.
Access restricted to authorised individuals only.
8. Sharing Information
Personal information will only be shared where necessary and proportionate.
Information may be shared with:
Universities.
Employers.
Student Finance England.
Disabled Students' Allowance providers.
Access to Work.
Needs Assessment Centres.
Regulatory, professional or auditing organisations.
Professional advisers where appropriate.
Only the minimum information necessary for the relevant purpose will be shared.
Mentorium Minds does not sell personal information to third parties.
9. Data Retention
We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, including to meet our legal, contractual, insurance, regulatory and professional obligations.
Unless a longer retention period is required or permitted by law, we will normally retain:
Enquiry information (where no mentoring relationship is established): Up to 12 months after our last communication.
Client records and mentoring notes: Up to 6 years after support has ended.
Financial records (including invoices and payment records): 6 years in accordance with UK tax legislation.
At the end of the applicable retention period, personal information will be securely deleted or destroyed.
10. Your Rights
Under UK GDPR, individuals have the right to:
Request access to their personal information.
Request correction of inaccurate information.
Request erasure of personal information where appropriate.
Request restriction of processing.
Object to certain types of processing.
Request data portability where applicable.
Withdraw consent where processing relies upon consent.
Lodge a complaint with the Information Commissioner's Office (ICO).
Requests should be submitted in writing to:
11. Data Breaches
Any suspected or confirmed personal data breach will be investigated promptly.
Where appropriate, Mentorium Minds will:
Contain the breach.
Assess the potential impact.
Take steps to reduce any risk.
Notify affected individuals where required.
Report the breach to the Information Commissioner's Office (ICO) where legally required.
12. Good Practice
Mentorium Minds is committed to maintaining high standards of confidentiality, professionalism and data security.
Reasonable steps will be taken to ensure that personal information is handled responsibly, securely and in accordance with current legislation and professional standards.
13. Contact
Questions relating to this policy or requests concerning personal information should be directed to:
Maryam Aslam
Founder & Specialist Mentor
Mentorium Minds
14. Policy Review
This policy will be reviewed annually, or sooner if required due to changes in legislation, professional guidance or service delivery arrangements.
Approved by
Maryam Aslam
Founder & Specialist Mentor
Mentorium Minds
Date: 7 July 2026