Annual Notice - Procedures for Maintenance of Student Records

The Ohio State University Wexner Medical Center Clinical Pastoral Education Program

I.  This ACPE CPE center/program guarantees to its students the rights 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 Education and Privacy Act (FERPA) rights.

II. Student Directory Information is defined as: student information not generally considered harmful or an invasion of privacy if released.  Within the OSU Wexner Medical Center CPE Center, directory information is defined as:  name, address, email, and telephone, date of birth, religion, previous education, and photograph. This information can be released without specific consent unless a CPE student opts out by submitting a written statement to the ACPE Certified Educator which specifies information to be restricted from release.  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.


III. Definition of Student Records: The Student Record is defined as: (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 Ohio State Wexner Medical Center CPE Program or a person acting for the institution. CPE Official Student Record at Wexner Medical Center CPE Program consists of: As required by ACPE, the CPE student record includes the ACPE application form face sheet with directory information, the ACPE Certified Educator's Final Evaluation report, and the student’s own Final Evaluation report, if submitted. The record at Wexner Medical Center also consists of any written response or addendum to the ACPE Certified Educator’s Final Evaluation. After 10 years, all material in the file may be destroyed except for a face sheet with identification information.  


IV. Details of the Center’s Record Management Protocols:
1.  The CPE Center will keep the student's official record on file for at least ten (10) years.  After this time, all material in the file may be destroyed, except for a face sheet with identification information.  Paper records will be shredded; tapes or recordings will be destroyed.
2. The ACPE Certified Educators are the education officials who are the primary custodians of all student records.  The Chaplaincy and CPE Department Administrative Assistant provides administrative support for the CPE Program and has a legitimate education interest, and may occasionally access records for specific business purposes at the direction of the ACPE Certified Educators.  The administrator to whom the Chaplaincy and CPE Program reports also has a legitimate education interest and becomes the custodian of the student records in the event that the CPE program is without ACPE Certified Educators.  These education officials can access student records without consent being provided for specific educational/business purposes.
3. Although access to student records is normally restricted as described above, certain exceptions apply:  access to students’ records is permissible to protect the health or safety of the student or others, for the purpose of an ACPE Accreditation review or a complaint or appeal involving that student, or as otherwise permitted for legal processes.  Before releasing information in any of these circumstances, there will be a consultation discussion with an ACPE official (ACPE Associate Director).
4. 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.
5. The CPE student must give written permission for a copy of the student's and ACPE Certified Educator's Final Evaluation to be sent to other programs, institutions, individuals, or to his or her theological school.
6.  In order to register the completed CPE unit with the ACPE, 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.
V. Violations of these protocols may be reported to the Chair of the Accreditation Commission at: ACPE, One West Square, Suite 325, Decatur, GA 30033.

July 2017