PRIVACY NOTICE

THE BRIDGE NOVA´s STUDENT WELLBEING

SUBJECT

This privacy notice is applicable to the personal data processing of students carried out in the context of
the operation of The Bridge Platform of SASNOVA.

WHO ARE WE?

The Bridge NOVA´s Student Wellbeing is a platform created by SASNOVA – the social and welfare
services of Universidade NOVA de Lisboa – designed to optimize and ease the University students’
access to resources and professionals that may contribute towards their well-being and health.
SASNOVA is an organic unit with administrative and financial autonomy, which is responsible for the
University’s welfare and social services, through the provision of aid, benefits, and services, aimed to
increase the chances of the students’ educational success.
For the purposes of the applicable Personal Data Protection legislation, the personal data will be
processed by Universidade NOVA de Lisboa, legal person n. 501559094 with headquarters in Campus de
Campolide, 1099-032 Lisboa, telephone number 213 715 600.
The Universidade NOVA de Lisboa (hereinafter “NOVA”) is, therefore, responsible for the processing of
the personal data, according to all definitions and provisions present in GDPR (General Data Protection
Regulation).

WHAT PERSONAL DATA IS COLLECTED AND PROCESSED?

To comply with the principle of data minimization, NOVA collects and processes the strictly necessary
personal data for the provision of psychological support to the NOVA students, depending on the
context of their interaction with psychologists on The Bridge platform. Given the nature of this
interaction and the goals of the platform, some of the referred personal data may belong to special
categories of data.
In the context of The Bridge platform, students are asked to fill a formulary in which they provide their
institutional e-mail, and, in case they choose to identify the main motives that led them to look for
psychological support. As such, the content of the answer may include special categories of data (such
as racial or ethnic origin, political opinion, religious or philosophical beliefs, genetic and biometric data,
health data or data related with sexual life or the sexual orientation of a person). The same applies to
the conversations between the students and the psychologists, during which such subjects may arise.

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The chat application, used to establish contact between the students and psychologists, keeps a record
of conversations, which is stored, securely and confidentially, without harming the students’ exercise of
rights, as stated in this privacy notice.

WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA?
The processing of personal data by NOVA in the context of the platform The Bridge has, as the legal
basis for the data processing, the consent of the students which have resorted to the platform.

WHAT ARE THE PURPOSES OF THE PROCESSING CARRIED OUT BY THE

BRIDGE?

The main priority of the platform The Bridge is to provide psychological support to the NOVA students.
Besides this purpose, the data collected also aims to provide a better understanding of the needs of
NOVA students’ and the reasons why they seek help from psychologists.
Occasionally, we might establish contact with the students, to assess their opinion regarding the
platform, and regarding other topics that may be of the student’s interest.
NOVA will only process the personal data for the purposes for which they were collected, except when
NOVA considers that those are necessary for other purposes, and only when that purpose is compatible
with the original intent of collection. This may occur for scientific or historical research and statistic
purposes, which must comply with other legal requirements for the reuse of personal data.

HOW LONG WILL THE PERSONAL DATA BE RETAINED?

In order to comply with the storage limitation principle and keep the personal data for no longer than
the required time to fulfill the purposes established in this privacy policy, NOVA will establish time limits
for the erasure and/or anonymization of personal data, or, alternatively, for the periodic review of the
need for retaining the personal data.
These periodic reviews will occur once a year, to evaluate the relevance of the personal data being
processed for scientific or historical research or statistical purposes. In certain cases, personal data
might be stored for longer periods, particularly when the Law requires it.

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WHAT SECURITY MEASURES HAVE BEEN ADOPTED IN ORDER TO PROTECT PERSONAL

DATA?

Information security and data protection are priorities for NOVA. For that reason, a Data Protection
Impact Assessment was conducted regarding the platform The Bridge.
Additionally, NOVA has implemented and has since maintained a set of technical and organizational
measures that, considering the most advanced available techniques, implementation costs, nature,
scope, context, and purposes of each processing of personal data on the platform The Bridge, allow to
mitigate the risks for the data subjects and prevent the occurrence of personal data breaches and
security incidents in general.
In particular, the following measures will be taken:
 Access to the personal data is limited only to the NOVA psychologists, which are bound by the
Deontological Code of the Ordem dos Psicólogos Portugueses. This access occurs only when the
the data is necessary for the performance of the psychologist’s functions.
 Personal data processed by NOVA is stored in servers that offer security guarantees, namely
encryption, access controls and backups.
 Period reviews of security systems and policies, to ensure that personal data is secure.

IS THE DATA TRANSFERED OUTSIDE OF THE EUROPEAN UNION?

No. In the context of the regular operation of the platform The Bridge, no personal data will be
transferred outside of the European Economic Area. Therefore, personal data of the data subjects is not
stored or accessed in States whose legal systems do not provide a degree of protection equivalent to
the one required by the GDPR.

WHAT ARE THE RIGHTS OF THE STUDENTS AS DATA SUBJECTS?
The students can, at any time, exercise their rights, in particular, their right to request additional
information about the processing of their data, the right to rectification of the data, as well as, with
certain limits, the right request the erasure of their data, the right to withdraw the given consent or the
right to oppose to the processing of their personal data, among others, via email address
sasnova@unl.pt. The students may, as well, contact the Data Protection Officer at dpo@unl.pt.

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The data subjects must be aware that, in certain cases (for instance, due to legal obligations) their
request might not be complied with. In any case, the data subject will be informed of the measures
taken, within one month counting from the moment the request was submitted.
The data subjects also have the right to submit a complaint to the Portuguese National Data Protection
Commission at https://www.cnpd.pt/.
This page should be consulted regularly by the students, as this privacy note may be updated.

January 25th 2021