Privacy and Confidentiality of Student Records

The Chattanooga Association for Clinical Pastoral Care

PURPOSE

As an ACPE accredited center the Chattanooga Association for Clinical Pastoral Care guarantees to its students the right to inspect and review education records, to seek to amend them, to specify control over release of record information, and to file a complaint against the program for alleged violations of these Family Education and Privacy ACT (FERPA) rights.

CACPC maintains student records with a policy and procedure which addresses privacy, confidentiality, access, content, and custody of student records in a manner consistent with ACPE Standards, and in compliance with federal (The Family, Educational and Privacy Rights Act), and state laws. ACPE STANDARD 4 (Appendix I of Student Handbook).

DEFINITIONS

Student Record: A student record is (1) any record (paper, electronic, video, audio, biometric, etc.) maintained by the education program/institution or a person acting for the institution and (2) directly related to the student from which the student’s identity can be recognized.

Directory Information:  Directory information is student information not generally considered harmful or an invasion of privacy if released.  This may include name, address, email, telephone, date of birth, religion, previous education and photograph.

“Opting Out:” Release of any directory information of a student file is not generally considered harmful or an invasion of privacy.  CACPC will protect the privacy of each student and refrain from releasing any information except as appropriate and necessary for administrative functioning of the department and institution. A student may opt to have directory information available for release only upon a written and signed permission statement. 

POLICY STATEMENT

Student records are maintained under lock and key within the Pastoral Care and Education Department of Erlanger Health Systems.  Access to student records is limited to the Clinical Pastoral Education Certified Educators of CACPC and administrative individuals designated by the Director of Pastoral Care and Education.  The center’s ANNUAL NOTICE on student records will designate such individuals.

PROCEDURE:

·         The official student record consists of (a) a face sheet, (b) application materials and any interview summary/report, (c) documentation of completion of orientation, (d) signed agreement for work form, (e) final evaluation written by the student, (f) the Certified Educator’s final evaluation and (g) a signed release of information form, if needed

·         Application materials of students not admitted and enrolled in the CPE program will be destroyed or returned to the applicant by request

·         Student records are maintained by CACPC for at least ten (10) years, following conclusion of the last unit of CPE.  Supervisor’s evaluations are maintained as part of the student record. A signed copy is provided to the student.  Copies of supervisor evaluations are made available for others only upon written request/consent of the student.  Students are expected to maintain their own files. Copies may not be available after the ten (10) year time frame

·         As long as student records are kept, they will be handled in keeping with ACPE standards of confidentiality, federal and state laws, and only available to the CPE student, the CPE center and others upon written request of the student. Upon written request, a student will be able to review their record within 45 days of the request. Copies of student records containing identifiers of another student will be redacted by the center for protection of student identity

·         A student has the right to object to record content.  If not negotiable, the written objection will be kept with and released with the record.  Grades are exempted from this right

·         The designated administrative assistant may keep directory information from the ACPE Face Sheet on file as part of the student’s application materials. This includes name, address, email and phone number, date of birth, religion, previous education, photograph and designated references.  A student may “opt out” of allowing access to this information by signed statement

·         Upon the student’s successful completion of a CPE unit, the Educator will verify such completion on the ACPE website.

·         Student social security numbers will be required for employment and/or volunteer status according to the policy of the related institutions of the program

·         Health Records (mental and physical) are kept in locked, limited access files separate from other student records. Their use and release is also subject to ADA and HIPAA regulations. Certain safety and employment records are also subject to other federal regulations and state laws and are kept separately

·         Verbatim reports and other student written documents are not considered a part of the student’s official file. Process notes made by the supervisor are not part of the official file. These materials are retained for the duration of training, and then destroyed at the conclusion of the CPE unit

·         If CACPC ceases to be accredited as a center offering programs of Clinical Pastoral Education, the center supervisor or appointed designee will secure all student records and ship the records to ACPE, c/o Accreditation. Records held more than ten years may be destroyed.

·         Research: If information in the student records or in a CPE Certified Educator record is considered of research value, and ACPE center or ACPE desires to collect and use such material for research, a release form shall be made available for the person’s signature.  No personally identifiable material will be released for research without written permission for its use.

·         Violations of these procedures may be reported to the Chair of the Accreditation Commission at: ACPE, 1 Concourse Parkway, Suite 800, Atlanta, GA 30328. email: accreditation @acpe.edu