UPR003526-15 Manual 2942.0 SHSM Vol I DRAFT master

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DoDEA School Health Services Manual 2942.0 Volume 1 Revised: 2016 DRAFT
(HIPAA)To Student Health Records. (2008). U.S. Department of Health and
Human Services and U.S. Department of Education. Available at:
The Privacy Act of 1974 (5 U.S.C. § 552a). Available at:
C-3 Protection of Student Health Information
C-3-1 Related Federal Guidelines
Developing, maintaining, and protecting health information is a DoDEA
requirement as well as following the nurse practice standards. As a Federal agency, all
records whether written on paper documents or electronic media, including email
traffic, videos, tapes, CDs, DVDs, etc., that originate from or are received by a DoDEA
employee are presumptively agency records governed by the Federal Records Act.
(Note: There are exceptions for written notes, such as personal memory joggers
written to oneself by the nurse; these notes are not used to make official decisions and
are not shared with anyone.)
The following provisions apply to all agency records:
1) All agency records are required to be filed in accordance with an agency file
plan that has been approved by the National Archives (see AI-15).
2) All agency records are subject to public disclosure under the Freedom of
Information Act (FOIA), a statute that exists to allow the public knowledge of how the
agency performs its duties.
3) All agency records that are retrieved by name or personal identifier are PA
records, meaning that the person whom the record pertains has a virtually absolute
right to access the record and to challenge its accuracy, relevance, timeliness and
completeness in formal proceedings.
a. Such records contain information about an individual and are generally
referred to as personally identifiable information (PII).
b. Such records/information must be maintained in official agency files in
accordance with DoDEA AI-15 and identified as PA files in the agency’s system of
records notice (SORN). Under the PA, a record that contains any PII that is retrievable
by name or personal identifier of a person is probably a PA-protected record/piece of
information.
c. Student education records, including health records, are identified in DoDEA’s
SORN 26, which can be found at: