Guide for Student Records

Overview

Students own information about them and must know what information is being collected and how it is being used. A student’s information cannot be shared without their written permission. Every ACPE program must publicize an Annual Notice (see template below), outlining its protocols for the handling of student records. Written protocols must include: how long records are kept, where they are kept, who is the custodian; how are they destroyed, as well as a process for a student review of their own record. Protocols must be followed consistently. See additional requirements below under Records Management.

*ACPE defines a student record as 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.

ACPE requires that:

1. The center retain the following items indefinitely:
   1. The application face sheet
   2. The Use of Clinical Materials Consent Form
2. The program retain the following items from the student record for ten (10) years:
   1. Certified Educator’s end of unit evaluation
   2. The student’s response to the end of unit evaluation, if submitted
   3. The student’s self-evaluation.

!If a file is incomplete, the ACPE Certified Educator shall document the efforts undertaken to make the file complete, noting what it missing and requests for documents from the student.

*Please note that: Application materials are often subject to particular state privacy laws for their retention, use, and destruction. These laws may also apply to the storage, use, retention, and destruction of all other student record materials. If no applicable laws exist, the center creates, publicizes, and follows its own Annual Notice protocol.

Annual Notice Template

Annual Notice must be published annually prior to the start of any CPE program and be included in the handbook, in addition to other sources, at the program’s discretion. Publishing may include posting the Annual Notice on the program’s website.

Items in bold must appear in the Annual Notice as stated here.

• This ACPE CPE program guarantees to its students the right to inspect and review education records, to seek to amend them, and to specify control over release of record information.
• What constitutes directory information at that center and how to opt out;
• The definition of student records (ACPE’s definition must be used; the center can add additional items);
• Details of the program’s record’s management protocols. Must include: 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.
• Define within the program and indicate in the program’s record management policy, who constitutes an “education official” and what constitutes “a legitimate education interest.” Within the program, these people may have access to student records without student consent;
• Violations of Annual Notice protocols may be reported to the Chair of the Accreditation Commission at:

ACPE, Inc.
1 Concourse Parkway
Suite 800
Atlanta, GA 30328

Or via email: accreditation@acpe.edu

Guidelines for the Development of the Annual Notice

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

• Each program defines directory information that will be released without specific consent unless a student “opts out.”
• Common directory information includes: name, address, email, telephone, date of birth, religion, previous education, and photograph. All other information is released only with the student’s written, signed, dated consent specifying which records are being disclosed, to whom, and for what limited purpose.
• Before releasing information, students must have received the Annual Notice.
• 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.

Evaluations and Process Notes

• A copy of the ACPE Certified Educator’s end of unit evaluation report will be given to the student. The student will be informed that the program will keep this evaluation for ten years and it will not be available to anyone else except with written permission from the student. If the student submits a written response, it will be kept with the educator’s evaluation and 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 of evaluation reports (See Annual Notice for program’s particular protocol). 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 educator’s end of unit evaluation reports (and their own if applicable) to be sent to any outside party.
• Supervisory Notes: The ACPE Certified Educator 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. They must be kept separately from the student record.

!Exceptions: 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, consult with the ACPE Executive Director or ACPE Associate Executive Director.

Records Management

• When an ACPE program closes, the program’s certified educator or appointed designee secures all student records and ships the records to the ACPE office, c/o Accreditation.

• The program’s policy and procedure about student record management must indicate the name or role of the appointed designee within the program’s institution who is responsible to secure student records in the absence of an ACPE Certified Educator or Associate ACPE Certified Educator.

• In the absence of an ACPE Certified Educator or Associate ACPE Certified Educator, only the appointed designee indicated in the program’s policy for student record management is authorized to retrieve student records with a student’s written request and written authorization.

• The program shall keep educator’s evaluations and student’s written responses, if submitted, for at least ten years. These records shall not be open to anyone outside the CPE program except with the student’s written request. (Note “Exceptions” above). After ten years, the program must keep the face sheet with identification information, but may destroy the educator’s evaluation report and the student’s written response (if submitted).

• Health records (mental and physical) must be kept in locked, limited access files, separate from other student records. Their use and release is subject to ADA and HIPAA. Certain safety and employment records are also subject to other federal regulations and state laws, and are to be 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. When peers are referenced in student’s evaluations, only initials should be used.

• Students are allowed to review their record within 45 days of a written request. 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 program 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.

Digital and Electronic Student Records

• Programs must maintain student records, either digitally or on paper, in compliance with ACPE Standards and the program’s policy for student records management.

• Digital and Electronic student records have the same storage requirements as paper records.

• Digital records must have at least one backup separate from the original hardware location. Backups should be dated and updated at least monthly or in accordance with institutional guidelines.