The Family Education Rights and Privacy Act (FERPA) applies to all ACPE CPE programs. FERPA addresses privacy, not confidentiality issues. This means students own the information about them and must know what is being collected and how it is being used. Their information cannot be shared without their written permission. Each CPE Center must publicize Annual Notice of its protocols for proper handling of student records. The following guidelines are used for implementation of protocols and the required Annual Notice.
Annual Notice Regarding CPE Records at Beaumont CPE Center
- The Clinical Pastoral Education (CPE) programs offered at Beaumont CPE Center, 3601 West 13 Mile Road, Royal Oak MI 48073, are accredited by the Association of Clinical Pastoral Education, Inc., 1549 Clairmont Road, Suite 103, Decatur, Georgia 30033. Beaumont offers Level I & Level II and Supervisory CPE programs and guarantees its students the right to inspect and review education records, to seek and amend them, to specify control over release of record information, and to file a complaint against the program for alleged violation of the Family Education and Privacy 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 exempt from this right.
- Directory information is the student information not generally considered harmful or an invasion of privacy if released. That information which may be released without specific consent includes student’s name, address, e-mail address, telephone number, date of birth, religion, previous education, and photograph(s). If a student desires to opt out of the unauthorized release of directory information to anyone outside the ACPE, he/she must submit this intent in writing no later than 30 days following receipt of this notice.
- A student record is any record (paper, electronic, video, audio, biometric, etc.) related to the student from which the student’s identity can be recognized and that is maintained by the Clinical Pastoral Education Center at Beaumont or a person acting for that institution. The Beaumont CPE facility will keep records according to the protocol included in the CPE student handbooks and as outlined below.
Within the Beaumont CPE facility an “education official” is anyone of an ACPE supervisory, associate supervisory, or supervisory candidate status. A “legitimate education interest” is anyone directly involved in the CPE Interdisciplinary Consultation Committee. Within the CPE center at Beaumont, these people may have access to student records without student consent. Additionally, the administrative assistant may handle student files as part of the regular duties of recordkeeping or if so directed.
- The Beaumont CPE center records management protocol: ACPE requires that non-electronic copies of the face sheet with directory information, the CPE supervisor’s evaluation report, and the student’s own evaluation be kept for ten (10) years from the date of student’s first joining the CPE program. These are maintained in a locked file for one year. At the end of the first year, these records are transferred to Beaumont’s contracted secure storage facility in accordance with the record retention guidelines stated in record retention policy #188. After ten years, a disposal form is sent to the contracted secure storage facility management requesting that the records be destroyed by means of shredding through Beaumont’s paper recycling program. Additionally, electronic copies of these evaluations will be stored on the secure Beaumont Spiritual Care and CPE network (“S:” drive) and deleted ten (10) years after the completion of the student’s unit(s). Access to this network drive is restricted to persons authorized by the director of Spiritual Care and CPE in compliance with ACPE Standards.
During the ten-year storage period, the records can be retrieved upon request of the director of Spiritual Care and CPE, but may not be reviewed or obtained by any outside party without the written authorization of the student, or in other cases which are listed in the ACPE standards such as legal or complaint issues. In the event of a complaint, the student’s record will be made available.
The law provides for certain exceptions concerning the release of information to protect the health or safety of the student and for the purpose of accreditation review or complaint review, or as required for legal processes. No such material will be released without consulting the ACPE interim executive director, ACPE executive director, or assistant director.
Written materials produced by the student, such as verbatims and case studies, will be destroyed at the conclusion of the CPE unit, unless the student authorizes an exception (e.g. for publishing purposes) in writing.
- Registration of unit(s) completed: At the conclusion of a full unit (400 hours) or a half unit (240 hours) of CPE training at Beaumont, a report is registered with the national ACPE office which gives the student’s name, gender, religious affiliation, category, CPE level, and the successful completion of a whole or half unit of CPE.
- In the event that the Beaumont CPE program no longer is accredited by ACPE, or a period of three (3) years has elapsed since any CPE supervisor has served on the staff of the Beaumont CPE program, in consultation with the regional accreditation chair, the student records shall be forwarded to the ACPE national office, either for storage or for transfer to an accredited ACPE center.
- Violations of these protocols may be reported to the chair of the Accreditation Commission at The ACPE (Association of Clinical Pastoral Education) Offices, 1549 Clairmont Road, Suite 103, Decatur, Georgia USA 30033.
Protocols for Maintenance of Student Records
ACPE requires that the CPE student record include the face sheet with directory information, the CPE supervisor’s evaluation report, and the student’s own evaluation report, if submitted.
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.
- 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 specified period of time, and it will not be available to anyone else except with written and signed permission from the student. If the student’s own evaluation is included, it will be kept with the supervisor’s subject to the same provisions (Note Exceptions below).
- Students are responsible for maintaining their own files for future use. The center will not keep a permanent file or evaluation reports. Students will be informed at the time copies are given to them that it is their responsibility to keep copies for future use.
- CPE students are expected to give written consent for copies of the supervisor’s evaluation reports (and their own if applicable) to be sent to their theological school.
- 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 record. Such notes will be kept separately from the student record.
In compliance with the Family Educational Rights and privacy Act (FERPA) of 1974 as Amended: Beaumont CPE Center will not release student evaluations, grades, reports, schedules, or financial information to parents, spouses, denominational judicatories, or others unless written permission is given by the student. Under no circumstances will the Beaumont Health System CPE Center release any medical information, nor will we change a student’s information (address, phone, etc.) for anyone other than the student. Submitting a written request with signature to release an education record via postal mail or fax is permissible; e-mail requests are not acceptable. The Beaumont student information release form is available for this purpose. The completed student information release form and the student information request form will be retained in the student’s file at the Beaumont Health System CPE Center.
Certain exceptions concerning the release of information exist to protect the health or safety of the student or others, and for the purpose of accreditation or complaint review, or as required for legal processes. Before releasing material in any of these circumstances, the Beaumont Health System CPE center director or supervisor will consult with the ACPE interim executive director, ACPE executive director, or associate director.
Centers must have written protocols for student record retention and destruction (how long records are kept, where, custodian; how destroyed) and for student review of records. Protocols must be followed consistently.
- When an ACPE program closes, the regional accreditation chair arranges the secure storage of all student records of the closed program. The accreditation commission chair and ACPE office will be informed of the records’ location.
- The 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. (Note Exceptions above). After ten years, the center may destroy the student record except for a face sheet with identification information.
- Health records (mental and physical) will be kept in locked, limited-access files separate from other student records. Their use and release is also subject to the Americans with Disabilities Act (ADA) and the Health Insurance Portability and Accountability Act (HIPAA). Certain safety and employment records are also subject to other federal regulations and state laws and are kept separately.
- Material written by students, such as verbatims and case histories that 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.
- FERPA requires students be able to 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 the latter case, a center can note on the copy sent, not available for official use. When a student record contains identifiers of another student, those must be redacted. The Annual Notice details records maintenance protocols and should include whether/how students may copy their records.