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Annual Notice and Student Records

Catholic Health Services of Long Island
Annual Notice - Maintenance of Student Records 
ACPE Standard 304.4, Standards Manual
and 
ACPE Appendix 7B, Accreditation Manual
For Level I and Level II Students


Purpose
To ensure that this Association for Clinical Pastoral Education (ACPE) CPE center/program guarantees to its students the rights to inspect and review education records, to seek to amend them, to specified 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.
 
Policy
Catholic Health Services of Long Island (CHS) shall maintain records in a manner consistent with the Guidelines for Student Records as they appear in Appendix 7B of the Association for Clinical Pastoral Education (ACPE) Accreditation Manual.

A Student Record is (1) any record (paper, electronic, video, audio, biometric etc.) directly related to the student from which the student’s identity can be recognized; and (2) maintained by the education program/institution or a person acting for the institution. CHS recognizes that the student owns the information about them and is permitted to know what is being collected and how it is being used. Student records will not be released without the written consent of the student. A release form is included in the Student Records Guidelines in the student handbook.

CPE student records consist of the application face sheet, directory information, the CPE supervisor’s written evaluation report(s) and the student’s own written evaluation report(s), if submitted. Materials written by students, such as verbatim, case histories and electronic recording that identify the students, and or, that contain information about other persons, including other students, will be destroyed at the conclusion of each unit. The only exception is when written permission has been given by the student for the purposes of pastoral or supervisory research. A copy of the CPE supervisor’s evaluation report will be available to the student within 45 days of the end of the unit. (ACPE Standard 308.8.1)

Directory Information is student information not generally considered harmful or an invasion of privacy if released. Common directory information include: name, address, email, telephone, date of birth, religious background, previous education, and photograph – and can be released without specific consent unless a student wishes to “opt out” of some or all directory information. Before releasing directory information, students must have received the Annual Notice. A student may opt out in writing, including a signature and date, in a letter to their ACPE supervisor as to what information specifically they want to opt out of for the directory. Further information regarding the handling of student information can be found in the training agreement. (ACPE Standard 304.9)

Current students can restrict directory information and/or record access at any time during attendance.  Restrictions must be honored even after the student’s departure.  Former students cannot initiate new restrictions after departure. Students can review their record within 45 days of student’s request (may be less). Record inspection cannot be denied based on the student’s inability to come to the site or outstanding financial obligations. In such case as outstanding financial obligation, the center can note on the copy sent, “not available for official use.” Copies of the file will be made available to the student for pick up. At that time, they will be asked to sign a release form, included in the student handbook. In the event a student cannot pick up their records, they may be mailed after consent is given in writing with their legal signature and an appropriate address for mailing is offered. Student records that contain identifiers of another student will be redacted.

Record Management Protocol
CHS will retain student records (either digitally or on paper, for a period of ten (10) years. ACPE requires that the CPE student record include the face sheet with directory information, the CPE supervisor’s written evaluation and the student’s written evaluation, if submitted. Identifiable information about everyone other than the student will be redacted from these written materials. After that period the file will be thinned and only a face sheet will be held. All records will be shredded except for the application face sheet.

A copy of the CPE supervisor’s evaluation report will be given to the student. The student will be informed that the center will keep this evaluation for a period of ten (10) years and it will not be available to anyone else except with written permission from the student.  Exceptions: Certain exceptions concerning the release of information exist to protect the health or safety of the student or others, and/or the purpose of accreditation or complaint review, or as required for legal processesBefore releasing material in any of these circumstances, the ACPE Executive Director or Program Manager will be consulted.

Students are responsible for maintaining their own files for future use and are informed of this when the final evaluation is signed by both the supervisor and student. A copy is kept in the program’s file and the other copy is handed to the student. No evaluation reports will be released from the file without the written request/consent of the student.
Student files are maintained at CHS corporate headquarters. Access to student records is restricted to the Supervisor(s) at the Center and other specified pastoral care personnel; i.e., Administrative Assistant or Assistant for Special Projects. Student information is kept in a locked filing cabinet and/or a locked office.

In the event that the Clinical Pastoral Education program closes, the center supervisor or appointed designee will secure all student records and ship the records to ACPE, c/o Accreditation. Prior to closing, CHS will notify the ACPE Regional Director and the Regional Accreditation Commission Chair of the records’ location. When the 10 year limit has expired, all but the face sheet will be destroyed.  In the absence of an ACPE Supervisor or Associate Supervisor, the appointed designee is the Administrator to whom the CPE program reports. 

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. Certain safety and employment records are also subject to other federal regulations and state laws and are kept separately.

At the conclusion of a successful unit, and not later than 45 days after the published end date of the unit, the CPE Supervisor shall register/certify the unit by reviewing the information that the student entered (end date, level of CPE, and type of unit) and then assigning 0, .5, or 1 credit for the unit. Subject to notification, the student’s name, address, denomination and unit of CPE successfully completed will be sent to the ACPE office on the student unit report at the completion of each unit of CPE.

Persons seeking certification as a CPE Supervisor:
Students must give written permission to the use of their clinical material as well as recorded and/or live observation media pertinent to the supervisor’s process toward certification as an ACPE Supervisor by signing Appendix 5 Consent Form, (ACPE 2016 Certification Manual).  Note: Only the Appendix 5 Consent From is acceptable for obtaining students’ written permission to use personally identifiable material.  Students being accepted into a unit of CPE are to review and sign the Appendix 5 Consent Form prior to formal admission to the CPE program or a unit of CPE Level I/Level II supervised by a Supervisory Candidate or Associate Supervisor. (See ACPE 2016 Certification Manual, General Certification Policies.)

Annual Notice will be published annually on the www.chsli.org web page and in the CPE Student Handbook.  It will also be made available to each student prior to admission interview.  (ACPE Standard 304.4-Requirements for Student Records.)

In addition to the information stated above, CHS guarantees to its students the rights to inspect and review education records, to seek to amend them, to specified control over release of record information, and to file a complaint against the program for alleged violations of these Family Education Rights and Privacy Act (FERPA) rights. Students also have 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. (ACPE Standard 308.8.1)

Violations of these protocols may be reported to the Chair of the Accreditation Commission at: ACPE, One West Court Square, Suite 325, Decatur, GA 30030.

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