Guidelines For Student Records

Note:  A copy of this policy is sent (either as an e-mail attachment or through regular mail) to all students upon their admission to any CPE program at Deaconess Hospital.
NOTICE:  This ACPE CPE center/program guarantees to its students the right 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, Educational and Privacy Rights Act (FERPA) rights.  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.  Violation of these protocols may be reported to the Chair of the Accreditation Commission at:  ACPE, One West Court Street, Suite 325, Decatur, Georgia 30030
DIRECTORY INFORMATION:  Directory information is student information not generally considered harmful or an invasion of privacy if released.  This would include such information as name, address, email, telephone, date of birth, religion, previous education, and photograph and intended for public distribution unless the student “opts out.”  Thus as it applies to CPE it means that information concerning the student’s name, address, denomination and unit of CPE successfully completed will be sent to the ACPE office on a student unit report at the completion of each unit of CPE.  Current students may restrict directory information distribution at any time during their participation in a CPE unit, and such restrictions must be honored after the student’s departure.  However, former students cannot initiate new restrictions after departure.  Should students wish to limit distribution, they should make this known in writing, indicating the specific nature of the request, and submit it to their primary Supervisor.  The written request will become a part of the student record.  
STUDENT RECORD:  The 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.  This would include a face sheet with student information, Supervisor's Evaluation Cover Sheet (Appendix 7 D-1, ACPE 2016 Accreditation Manual), the CPE Supervisor's evaluation report and the student's own evaluation report.  Access to student records is restricted to ACPE Supervisors attached to Deaconess Hospital and to the administrative assistant, Religious Life Department, as an appointed designee, authorized to retrieve student records in the absence of the ACPE Supervisors.  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. 
ADMISSIONS MATERIAL:  The application face sheet must be retained indefinitely. At the ten year review, site visitors will reconcile the report of student units with the face sheets.  Within the federal laws, information such as recommendations in connection with student's admission to a unit(s) of CPE is considered to have served its purpose upon a student’s acceptance and is not necessarily a part of the student's record, but may be sealed off and not be available to anyone within or without the center.
SUPERVISORY NOTES:  The CPE Supervisor may keep process notes on a student.  These process notes are for the exclusive use of the writer and are not considered a part of the student's official record.
SUPERVISOR EVAUATION REPORTS:  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 a copy of this evaluation for a specified period of time, and it will not be available to anyone else except on written permission of the student.  If the student's own evaluation report is part of the official record, it will not be available to anyone else except on written permission of the student (Note “Exceptions” below). 
Students have the responsibility to maintain their own file for future use and the center will not keep a permanent file or evaluation reports.  Student will be informed at the time copies are given to the student that it is their responsibility to keep copies for future use.
CPE students are expected to give written permission for copies of the
Supervisor's evaluation report (and their own if applicable) to be sent to their theological school.
MAINTAINING STUDENT RECORDS:  The CPE center shall keep student records for at least ten years.  These records shall not be open to anyone outside the CPE center except with the student's written request.  After ten years the center may destroy the student record, except for a face sheet with identification information (Note “Exceptions” below).
HEALTH RECORDS (mental and physical):  Such records must be kept in locked, limited access files separate from other student records.  Their use and release is also subject to ADA and HIPAA guidelines.  Certain safety and employment records are also subject to other federal regulations and state laws and are kept separately.
ACCESS TO STUDENT RECORDS:  As long as student records are kept they must be handled in keeping with the federal and state laws, being available only to the CPE student, the CPE center and others on written request of the student. (Note “Exceptions” below) 
INFORMATION ABOUT OTHER PERSONS:  Material written by students, such as verbatims and case histories which contain information about other persons, including other students, will either be destroyed or if they are part of the student’s record, will have the identifiable information about everyone other than the student redacted. 
EXCEPTIONS:  The law provides for certain exceptions concerning the release of information to protect the health or safety of the student or others and for the purpose of accreditation review or a complaint or appeal involving that student or as otherwise permitted and required for legal processes.  Before releasing material in a legal process, the Manager, Religious Life Department or the ACPE Executive Director will be consulted.

This Center does not currently offer Supervisory CPE.
Persons seeking certification as a CPE supervisor. Students must give written permission for the use of their clinical material and 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 Form is acceptable for obtaining the 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 a Clinical Pastoral Education Program or unit of CPE Level I/II supervised by a Supervisory Candidate or Associate Supervisor. See ACPE 2016 Certification Manual , General Certification Policies.
APPEARANCE BEFORE A REGIONAL CERTIFICATION COMMITTEE OR THE CERTIFICATION COMMISSION:  Following the action of the committee or Commission, and when the time limit for appeal has lapsed, all material submitted about the student will be destroyed.
A regional certification committee and the Certification Commission may keep on file a face sheet of the person seeking certification, copies of the Presenter’s Reports, and copies of all Action Reports on the person seeking certification.  Other materials should be returned to the person seeking certification.
ACPE FILES:  ACPE may keep on file a copy of the face sheet and regional certification committee Action Reports, copies of all Certification Commission Presenters’ Reports, and copies of all Certification Commission Action Reports.
If information in student records or in CPE supervisor’s records is considered of research value, and a CPE center of the 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 used for research without the person’s written permission for its use.
--From Appendix 7 B, The Accreditation Manual of the Association for Clinical Pastoral Education, 2016, pp.139 of 245.