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Counseling: Confidentiality, Privacy & Records Policy

SECTION: Counseling NEXT REVIEW DATE: August 2017
APPROVED: August 2012 REVIEWER: Compliance Coordinator
APPROVED BY: William C. Rickle, S.J. REVISION DATE: November 2016

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Ensure confidentiality for the recipients of the student counseling service as well as the protection and containment of the Personal Health Information (PHI) of the students served.


2.1 Policy Statement

2.1.1 All consumers of the WJU Counseling Services will receive both the Professional Disclosure of Providers and a Notice of Privacy Practices at the intake consult.

2.1.2 Confidential records of all student counseling services will be generated as an intrinsic part of the service provision.

2.1.3 Confidentiality will be maintained on an as-needed or need-to-know basis congruent with best practice standards (American Counseling Association Code of Ethics) and legal parameters (HIPAA).

2.1.4 Records of all PHI relevant to the clinical intake process will only occur within the student counseling record.

2.1.5 Releases of information will be utilized to ensure informed consent of dissemination of any personal health information of the students.

2.1.6 All Clinical Records are hardcopy, non-electronic, to ensure full compliance with privacy standards.

2.1.7 The records of the students will be kept for 7 years and then destroyed per current confidentiality standards.

2.2 Definitions

2.2.1 PHI - Personal Health Information

2.2.2 Non-Electronic Records - A term inclusive of electronic/digital software, audio, and visual recording.

2.2.3 Records - Refers to the folders and files of non-electric, documented, student counseling content.

2.2.4 LPC: Licensed Professional Counselor

2.2.5 ALPS: Approved Licensed Professional Supervisor

2.3 Procedure

2.3.1 Privacy Practices

  • All student counseling records will be non-electronic and secured in locked file cabinets to which only the Licensed Professional Counselors and/or Supervised Interns and Practicum students will have access.
  • All students seeking counseling services will be presented with an informed consent and authorization for treatment document to be reviewed and signed; the document outlines the parameters of privacy and confidentiality as well as their informed consent to treatment.
  • The signed documents will be retained in the student's file in the Counseling Center; however, a copy will be retained in a separate file by the Counselor and available upon request.

2.3.2 Confidentiality

  • The Licensed Professional Counselors, Graduate Interns, and Administrative Staff will maintain confidentiality of clients as required by privacy laws and the WJU Counseling Service Policies and Procedures.
  • All employees of the service, inclusive of practicum students and interns, will sign the attached statement of confidentiality.
  • The signed statements of confidentiality will be retained on file by the Counselor and available upon request.

2.3.3 Comprehensive Record
The Counseling staff will ensure safe and secure management of the student counseling records.

2.3.4 Release of Information

  • Authorization of Release of Information will be required by the client in order for the WJU Counseling service to Release their records to others.
  • No third party records, or records provided elsewhere that have been acquired, will be released.

2.3.5 Non-Electronic Records

All documentation of service by providers will be handwritten on standard forms and securely stored as student counseling records without duplication.

The signed Authorization of Release of Information will be retained by the Counselor and available upon request.

2.3.6 Duration of Records

  • At the end of the academic year the Licensed Professional Counselor will completely shred all student counseling files that have attained seven (7) years of duration.
  • No electronic records are retained; therefore, no electronic data destruction techniques need to be documented.

2.3.7 Information Release Oversight

  • Authorized release of information will be utilized by the counselors exclusively.
  • The LPC / ALPS will personally manage all authorizations of release of information.


The Director of the Counseling Center may change this policy at any time, with or without notice, to maintain compliance with changes in regulations. All changes must be approved by the Compliance Coordinator.


Counseling Services Informed Confidentiality Commitment
Counseling Services Release of Information

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