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DoDEA School Health Services Manual 2942.0 Volume 1 Revised: 2016 DRAFT
DoDEA’s PA restriction on disclosure applies to
any
type of disclosure, including
written, spoken or electronic transfer of student health information. Additionally,
because health records are highly personal and contain information not often known to
the public, they are particularly sensitive. Thus, hard copy health records (such as
special education records) are protected by storing them apart from other student
academic records that also qualify as PA records. Thus, access to health records for the
purpose of any further disclosure is generally limited to the school nurse and the
principal, as directed by the principal to enable a staff member to perform an official
duty or as prescribed by written agency rules. Disclosures outside of the school should
be made only upon consultation with the principal, and in conjunction with the DoDEA
Privacy Officer or the DoDEA Office of the General Counsel when needed.
C-3-5
Guidelines for Disclosure of Student Health Information
School nurses and principals with access to student health records are
required by law to protect the privacy of student health records and to disclose them
within DoDEA (or DoD) only with the consent of the sponsor/parent/guardian or without
consent in a limited number of circumstances described as routine uses in the published
SORN. Nurses are advised to consult with school principal prior to any such disclosure.
Disclosure without consent is permissible within DoD when:
1) a particular record or data is requested by a DoD official with an official need
to know;
2) the information sought to be collected is for a purpose that is consistent with
the reason that DoDEA collected the information for its own records; or
3) when the information is required by a DoD official with a compelling need to
protect the life, health or safety of the individual whom the record pertains (or another
person), such as when the student is suspected of self-injury or suicide, to protect
another person from imminent harm, or when it is required by law (such as in
connection with a case of suspected child abuse).
A.
All DoDEA employees are expected to know the principles of privacy
protection under the PA and to protect against the disclosure of PA-protected
information or PII without prior consent.
B.
The principal or designee(s) supervises the administration of the Privacy
Program in each building.
C.
If written informed consent has not been secured, nurses should consider
that health information generally will not be shared except as instructed by
the principal.
D.
Generally, when a requestor within the school or within the DoD can assert
an official duty for which he or she requires the student health information,
DoDEA may disclose that information to that person if it determines that the