It is the policy of the Pastoral Services department to maintain students’ educational records in such a way as to protect the student’s right to privacy. To ensure appropriate respect of privacy with regards to students’ records, this CPE Center adheres to the 2010 Standards of the Association for Clinical Pastoral Education (ACPE, Inc.) and the Family Education Rights and Privacy Act (FERPA).
Educational records are defined by FERPA as: "Records that directly relate to a student and that are maintained by an educational agency or institution or by a party acting for the agency or institution."
These records are of two types: Directory information (name, date of birth, address, email address, telephone numbers, ethnicity, gender, denomination, education and photograph), and Non-directory information (application material, written reports and essays, evaluations, transcripts, and any other paper, electronic, video, audio, biometric records, which are directly related to the student and from which the student’s identity and history can be recognized). FERPA gives students the following rights regarding educational records:
- The right to access, inspect and review educational records within 45 days of the time the request is received.
- The right to request an amendment of the student’s educational records that the student believes are inaccurate, misleading or otherwise in violation of the student’s privacy rights under FERPA. If mutual agreement about amendment cannot be negotiated, a student may provide a written objection which is to be kept with and released with the record.
- The right to provide written consent before the program discloses personally identifiable information (non-directory information) from the student’s educational records.
- The right to restrict release of directory information.
- The right to file complaints against the program for disclosing educational records in violation of FERPA.
The Baptist Hospital Clinical Pastoral Education Program will not release non-directory information to anyone without the prior written consent of the student. This center will not release CPE evaluations to anyone other than the student and those whom the student authorizes by a signed release. A student’s evaluation is destroyed after 10 years of the end of the student’s CPE program.
The Baptist Hospital Clinical Pastoral Education Program reserves the right to disclose directory information to a third party without the written consent of the student unless the student exercises the option to restrict the release of directory information by submitting a formal written request to limit disclosure. This can be done either prior to entering the program or at any time while participating in the program.
This ACPE CPE center/program guarantees to its students the rights to inspect and review education records, to seek to amend them, to retain specified control over release of record information and to file a complaint with the U.S. Department of Education for alleged violations of the Family Education Rights and Privacy Act (FERPA) rights. Students can request access to their records by written communication to the Director of Clinical Pastoral Education.
*MAINTENANCE OF STUDENT MEDICAL RECORDS:
Applicants for admission to CPE programs: Student records will include the complete application material, face-sheet/application form, autobiographical essays, helping incident or verbatim, impressions of CPE, assessment interview report.
Students admitted and matriculated in current CPE programs: Students records will include application materials, signed agreement for training, signed acknowledgement of policies, signed position description, certificates of specific trainings, references, verbatims/clinical records, copies of chart notes, mid unit assessments, past CPE evaluations.
Former CPE Students (from 10 years ago to current):
Student records include: the face sheet/application form, the supervisor’s evaluations, and the student’s self-evaluation. A student has the right to object to record content and/or to respond in writing to the supervisor’s evaluation. The supervisor can also choose to respond to the student’s response. If not negotiable, the written responses will be kept with, and released with the evaluation record. Grades are exempted from this right.
Former CPE Student (older than ten years ago): Student records include the face sheet. *This center disposes of all confidential material by shredding provided by a commercial records and information management company.
Exceptions: The law provides for certain exceptions concerning the release of information to protect the health and safety of the student and for the purpose of accreditation review or a complaint or appeal involving that student or as otherwise permitted and required for legal processes. The ACPE executive director and the general counsel of Baptist Hospital shall be consulted before releasing material in a legal process.