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I work daily with a great team of seven guidance counselors and four school psychologists. Each is highly skilled. It is not unusual for us to discuss, or even debate, a variety of counseling issues. One that resurfaces on a fairly routine basis is the issue of student records, particularly concerning our COUNSELING NOTES. I’d like to take a minute to quickly review what the American School Counselor Association (ASCA) recommends regarding our records on students:
- First and foremost, make sure you are keeping educational records that are required by your school board policies, as well as state and federal laws/regulations. This extends beyond counseling notes and refers to all student records. Be familiar with FERPA (Family Education Rights and Privacy Act, 1974) and how this impacts educational records.
- Keep your counseling notes, referred to by ASCA as sole-possession records, separate from educational records, per state laws on this issue.
- Remember that sole-possession records are designed to be a way for you, the counselor, to remember your sessions with students (e.g., what the topic of discussion was, what strategies for coping may have been taught, what the student’s reason for seeking support was, what day you saw the student, etc.). Here are potential limitations to sole-possession counseling notes:
- Even though they are not typically part of the student’s educational records, they could become so if shared with others or if they are available to others in written or verbal form. So, keep your counseling notes private, period.
- Sole-possession records could also become part of a student’s educational records if they include information beyond your professional opinion or personal observations.
- Likewise, be advised that individual student notes can possibly be subpoenaed. What you are required to disclose may depend on your state laws, your credentials, and the situation-at-hand so it is advisable to consult with your school board’s attorney if subpoenaed.
Bottom line, your sole-possession counseling notes are for YOUR EYES ONLY. Keeping these notes in a confidential, secure location and keeping them only for your individual reference in order to document student contacts by date, name, and reason, is paramount in protecting your counseling notes from becoming public. My rule of thumb is that I create these notes with the expectation that they will stay private but with the knowledge that they COULD become public. Thus, I only put information in my counseling notes that I am comfortable having someone else know should that happen.
Following are two excellent articles by ASCA that further discuss counseling notes:
The American School Counselor Association’s Code of Ethics is found at: