Clinical Records in the Form of Private Notes Kept in the Sole

Clinical records in the form of private notes kept in the sole possession of the counselor:

A) are not subject to the Family Educational Rights and Privacy Act (FERPA) even thought administrative records are.
B) are subject to the Family Educational Rights and Privacy Act (FERPA)
C) should be kept in a separate folder in the counselors' office
D) should be kept in files on the counselors' office computer