ANNUAL NOTICE

Policy Name: Maintenance of Student Files (ACPE Standard 304.4)

Purpose: To assure proper maintenance of current and non-current student records in a manner that addresses confidentiality, access, content, and custody of student records.

Policy: Centra guarantees to residents and students the right to inspect and review education records, and to seek to amend them in a timely manner. The Clinical Pastoral Education component of the Department of Pastoral Care also guarantees specified control over release of educational record information. Residents and students may file complaints against the CPE programs for alleged violations of these Family Education and Privacy Act (FERPA) rights.

Definitions:

A student record is: any record (paper, electronic video, audio, biometric, etc.)

  • directly related to the student from which the student’s identity can be recognized: and
  • maintained by the education program/institution or a person acting for the institution.

Directory information is student information not generally considered harmful or an invasion of privacy if released.

  • Common directory information includes name, address, email, telephone, date of birth, religion, previous education, and photograph.
  • Directory information may be released without student consent unless a student “opts out”.
  • Student can restrict directory information and/or record access at any time during attendance.
  • Before releasing information the student will have received the Annual Notice.

Procedure:

  1. The Manager of Clinical Pastoral Education will exercise general oversight for the keeping of all CPE records.
  2. The following materials will be kept in each resident and student master file: (a) application face sheet; (b) all supervisor and student evaluations; (c) all committee action reports; (d) any applicable complaint documentation.
  3. Health records (mental and physical) will be kept in locked, limited access files separate from other student records. Their use and release is subject to ADA and HIPPA regulations. Certain safety and employment records are also subject to other federal regulations and state laws and will be kept separately.
  4. Students will be given access to a written evaluation from the CPE Supervisor within 45 days of the course’s completion unless an extension has been granted for “rare unusual circumstances.” (Reference Standard 308.8.1 located in the policy and procedure section of the Student Handbook, on the flash drive, in the ACPE Standards Manual and on the ACPE website.)
  5. Students shall be able to review their record within 45 days of request. Records shall be inspected without regard of student’s inability to come on site or outstanding financial obligations. If outstanding financial obligations exist the copy sent shall note “not available for official use”. All identifiers of other students shall be redacted.
  6. Resident and student records as indicated above will be maintained for a minimum of 10 years in accordance with ACPE standards. After 10 years, the only records kept will be the face sheets.
  7. All residents and students are required to keep copies of their supervisory and student evaluations.
  8. Centra ACPE-certified supervisor and the Centra chaplaincy administrative assistant will have access to all resident and student records in the CPE programs. Such named people are responsible for placing appropriate materials in each resident or student’s master file and for checking periodically (at least quarterly) to assure that records are up-to-date.
  9. All resident and student records will be located in a locked file cabinet in the office of the Clinical Pastoral Education administrative assistant.
  10. A student/resident’s record may be released to an outside source, such as a denominational committee on ministry, but only with the written consent of the student/resident to the student/resident’s direct supervisor. Students are expected to give written consent for copies of supervisor’s evaluation reports (and their own if applicable) to be sent to their theological school.
  11. Certain exceptions concerning the release of information exist to protect the health and safely of the student or others, and for the purpose of accreditation review. In the case of complaints, grievances, and appeals, students should be aware that their records may become available to those processing the complaint, including Centra legal counsel. Before this information is released the ACPE supervisor will consult with the ACPE Executive Director of Associate Director at the National ACPE office.
  12. In the event that this center should cease to be an accredited CPE center, the regional accreditation chair will arrange for the secure storage of all student records. The Accreditation Commission Chair and ACPE office will be informed of the records’ location. If the center should be without a CPE supervisor and is actively conducting a search to obtain another ACPE qualified supervisor the records will remain at Centra.
  13. ACPE program unit reports will be submitted online to the National ACPE office at the end of each CPE unit.
  14. Students and residents have the right to object to their student record content. A student or resident may negotiate content with his or her supervisor during the written supervisory evaluation process. If there is a disagreement about possible changes, the student or resident has the right to write an objection, which will be kept with the supervisor’s evaluation and released with the record.
  15. Violations of these protocols may be reported to the Chair of the Accreditation Commission at: ACPE, 1549 Clairmont Road, Suite 103, Decatur, GA 30033.
  16. Student and resident information will not be used in any material developed and publicized by Centra Department of Pastoral Care and Clinical Pastoral Education without the student/resident’s written permission. This includes any internet-based material as well as any marketing or public relations material developed for Pastoral Care Week or other Department of Pastoral Care and Clinical Pastoral Education initiatives. Students and residents may not use any such material for any personal or professional reasons without the written permission of the director of the Department of Pastoral Care and Clinical Pastoral Education. This includes information such as the student having been a chaplain at Centra.
  17. A copy of this policy will be sent to each student and resident upon acceptance into the CPE program. This shall constitute “Annual Notice” of Centra protocols for CPE students and residents. A copy shall also be included in each CPE handbook.

Please sign and date below.

Return to: Sandie Greene

Dept. of Pastoral Care

Centra

1920 Atherholt Rd.

Lynchburg, VA 24503

I have received the annual notice______

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