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Student Health Records Privacy Interim Policy


​Purpose/Background

Students who use the university's health services expect their health information to be kept private. Student Health Records maintained by the university have a special status in that they are not covered by HIPAA. Instead, they are covered by FERPA and California laws regarding the confidentiality of medical information. The Department of Education has urged universities to create clear policies to avoid confusion, encourage the disclosure of records when necessary to prevent harm and protect student's privacy rights.  

This policy and its associated procedures will provide clear guidance to those who are responsible for determining when and with whom Student Health Records can be shared and aid in making those determinations consistent.

Applicability/Responsibility

This policy applies only to records regarding students maintained by Student Health Services and the university's Counseling and Psychological Services.

All members of the university community must comply with this policy, and should not access, copy or remove Student Health Records in violation of the policy. The following individuals are responsible for the management and enforcement of this policy, and for ensuring appropriate training is provided to affected personnel.

 

ContactResponsible Items
Chief Privacy OfficerAdvising, enforcement, training, policy review
Director, Student Health ServicesMaintenance of Health Records, operational supervision, handling of records requests.
Director, Counseling and Psychological Services (CAPS)Maintenance of Health Records, operational supervision, handling of records requests.
Vice President for Student LifeSupervision of SHS and CAPS
RegistrarMaintenance of general student records

 

Definitions

Confidentiality of Medical Information Act (CMIA)California state law protecting the confidentiality of individually identifiable medical information. CA Civil Code Sections 56-56.16
DisclosureThe release, transfer, provision of access to, or divulging of information in any manner.
Family Education Rights and Privacy Act (FERPA)A Federal law that protects the privacy of student education records. 20 U.S.C. § 1232g; 34 CFR Part 99
Student Health RecordsRecords regarding treatment maintained by either Student Health Services (SHS) or Counseling and Psychological Services (CAPS).

 

Policy Statement

The university will maintain, manage, use, and disclose Student Health Records in compliance with the Family Educational Rights and Privacy Act (FERPA), the California Confidentiality of Medical Information Act (CMIA), other applicable California law and according to this policy and related procedures.

Except when the disclosure is for treatment purposes, when the university discloses information contained in Student Health Records the disclosure will be limited to the minimum amount of information necessary to accomplish the intended purpose.

Students have the right, with limited exceptions, to look at or obtain copies of their health record. The University will honor all students' rights granted by FERPA and California law to view, obtain and amend the information contained in their health record. The University will only deny a request for access when allowable under FERPA and state law, and will provide written notice of the denial in accordance with FERPA and state law.

The Director of Counseling and Psychological Services (“CAPS") and the Director of Student Health Services (“SHS") will act as the custodian of records for health records maintained by their respective departments and are responsible for supervising the receiving and processing of all requests related to records for their departments.

The university will maintain appropriate administrative, technical, and physical safeguards to ensure the privacy of Student Health Records. The university will reasonably safeguard student health information from intentional or unintentional use and disclosure that is in violation of FERPA or state law.

Where required by FERPA, the university will record the disclosure of student health information in the Student's Health Record. If the university discovers a possible breach of unsecured health information, the university will investigate and when appropriate provide timely notification in compliance with California law.

The university will maintain Student Health Records for at least seven (7) years from the date of the last appointment. When the university destroys or disposes of Student Health Records it shall do so in a manner that preserves the confidentiality of the information contained therein.

Any amendments or changes to this policy must only result from collaboration with the University Privacy Officer, Vice President of Student life (or designee) and the Chief Compliance Officer.

Violations

Any university member failing to adhere to this policy are subject to disciplinary action in accordance with the Disciplinary Action Policy for Compliance Misconduct [link].
 

Contact Information

SubjectDepartment PhoneWebpage/Email
Privacy inquiries, concerns, information

University Privacy Officer

 

415.351.7124Privacy Program webpage
Chief Compliance Officer209.932.7579

Office of Compliance & Ethics webpage

compliance@pacific.edu

Clinical operationsStudent Health Services209.946.2315Student Health Services webpage
Counseling and Psychological Services (CAPS)209.946.2315CAPS webpage
Administrative oversightStudent Life209.946.2365

Division of Student Life webpage

studentlife@pacific.edu

FERPA (Family Educational Rights and Privacy Act)Registrar (Stockton)209.946.2135

Office of the Registrar webpage

registrar@pacific.edu

Registrar (Sacramento)

 

916.739.7106sacregistrar@pacific.edu

Registrar (San Francisco)

 

415.929.6461sfregistrar@pacific.edu

Complaints, questions, anonymous reports

 

 

Compliance Helpline1 (800) 854.8443Compliance Helpline


Related Information

Item

 

Description

University Links

 

Disciplinary Action Policy for Compliance Misconduct

Privacy Program webpage

Office of Compliance & Ethics webpage

Student Health Services webpage

CAPS webpage

Division of Student Life webpage

Office of the Registrar webpage

Compliance Helpline

 

Forms

 

 

Related Links

 

 
Procedures 
 
Student Health Services Procedures
Counseling and Psychological Services Procedures

 ​



About This Policy
Last Updated
2/8/2022
Original Issue Date
2/8/2022

Responsible Department
Compliance