Dissenting opinion by
BATTAGLIA, J.which RAKER, J., joins.
I respectfully dissent. The enforceability of the subpoena at issue in this case is directed not only to the treatment records of Jane and John Doe, but to all the other clients of Ms. F., the licensed social worker in this case. I believe that those other clients have a privacy interest at stake1 and that under the circumstances presented here, the State has not presented a sufficient compelling state interest to overcome the confidentiality and statutory privilege attached to those records. A social worker’s client has a strong interest in preventing disclosure of treatment records because of the personal, private intimate nature of the information ordinarily contained therein. In addition, the client has an interest in keeping private the fact that he or she was even in treatment. Although this privacy interest is not absolute, the burden is on the State to show that the individual privacy interest is outweighed by a legitimate interest of the State in securing this information. In this case, the State has failed to satisfy its burden.
The majority’s inference regarding the breadth of the Board’s authority is not grounded in any indicia of systemic wrongdoing by Ms. F. Further, although the majority espouses the Westinghouse factors, which provide the framework for balancing the government’s interest in disclosure *193against the clients’ privacy interest in the information, no application of the factors is made with respect to the disclosure of all treatment records of all of Ms. F’s clients. Moreover, the Maryland statute does not provide adequate safeguards to prevent unauthorized disclosure of the treatment records.
In the present case, the Board initiated an investigation into Ms. F’s failure to report after a complaint was filed concerning child abuse by John Doe that was not reported by Ms. F while she was acting in her professional capacity as a licensed social worker. The Board has not shown any connection between the investigation and the requested disclosure of all of Ms. F’s clients’ files for unrelated individuals. To permit the Board to delve into apparently unrelated files without any indication that the wrongdoing was not confined to this particular instance would in fact result in a “fishing expedition.” Before the Board should be permitted to intrude on the sensitive and highly personal information of all people who sought treatment by social workers, something more must be required than mere interest by the Board in the files. Otherwise, we invite a potential witch hunt into the emotional lives of people who have not been notified nor been given the opportunity to be heard about the disclosure of their mental health records in the name of protecting the public, whenever an allegation of wrongdoing is made with respect to the treatment provider.
I agree with the majority that United States v. Westinghouse Electric Carp., 638 F.2d 570 (3d Cir.1980) sets out the proper analytical framework for balancing the competing interest of the individual and the State. See maj. op. at 185, 862 A.2d at 1009. Those factors are as follows:
the type of record requested, the information it does or might contain, the potential for harm in any subsequent nonconsensual disclosure, the injury from disclosure to the relationship in which the record was generated, the adequacy of safeguards to prevent unauthorized disclosure, the degree of need for access, and whether there is an express *194statutory mandate, articulated public policy, or other recognizable public interest militating toward access.
Westinghouse, 638 F.2d at 578.
The first Westinghouse factor requires this Court to consider the type of record requested. The majority, however, did not apply those standards when it decided to permit a wholesale review of all of Ms. F’s treatment records, without notice and an opportunity to be heard. All of Ms. F’s treatment files for her clients are properly classified as “mental health records” under Md.Code (1982, 2000 Repl.Vol., 2004 Supp.), §§ 4-301, et seq. of the Health — General Article, due to the highly sensitive personal information contained in them. As such, all of Ms. F’s treatment files are confidential.
Moreover, the second and third Westinghouse factors, concerning the information contained in the files and the potential for harm in subsequent nonconsensual disclosure, mandate the conclusion that disclosure of Ms. F’s files for all of her clients must not be permitted. Such files contain all types of information that could potentially be harmful to the client should it be revealed subsequently, including thoughts of suicide, information about a client’s emotional needs and desires, and other personal struggles generally not disclosed to the public. Certainly it does not require much imagination to devise any number of disastrous outcomes for a client should any of that potentially damaging personal information be revealed, including even the person’s identity.2
Because the majority has not required the Board to articulate why current treatment records for all clients are disclosa-*195ble, it does not in any way address the potential injury to the relationship between Ms. F and all of the clients caused by disclosure. Without something more than mere unsupported suspicion, disclosure would result in chilling the free discourse required between any treatment provider and her clients and deter clients from seeking help from any other treatment provider. It could irreparably harm the relationship and deprive all such clients of much needed counseling and services.
The majority concludes that the Legislature has provided adequate safeguards against disclosure by the Board of any information that it seeks to obtain through the subpoena power. See maj. op. at 182, 862 A.2d at 1008. I disagree. The majority does not consider the impact of Section 5-704 of the Family Law Article, which sets forth the circumstances in which social workers are considered mandatory reporters of child abuse. Section 5-704 provides in pertinent part:
(a) In general. — Notwithstanding any other provision of law, including any law on privileged communications, each health care practitioner, police officer, educator, or human service worker, acting in a professional capacity in this State:
(l)(i) who has reason to believe that a child has been subjected to abuse, shall notify the local department or the appropriate law enforcement agency
Md.Code (1984, 1999 Repl.Vol., 2004 Supp.), § 5-704(a) of the Family Law Article. Nine of the members of the Board of Social Work Examiners are social workers, Md.Code (1981, 2000 Repl.Vol., 2004 Supp.), § 19-202(a)(2) of the Health Occupations Article, who conceivably continue to be bound by their statutory obligation to report what they believe may be abuse to the proper authorities. It is not too difficult to conceive of situations in which a social worker’s notes could refer to “striking” or “spanking” for instance, where the Board could identify an obligation to report child abuse or if not so reported, and injury subsequently occurred, there may be potential civil liability under Horridge v. St. Mary’s County *196Department of Social Services, 382 Md. 170, 854 A.2d 1232 (2004).
What would happen if the Board discovers information indicating that a client intended to commit suicide or intended to commit a non-violent crime, such as shoplifting or illicit drug use? What if the Board discovered notes about a client’s comments, made during a domestic dispute, that she would like to kill her husband? There is an inherent conflict for the Board members who are social workers between their obligations as professionals and their statutory duty to prevent redisclosure. There are no guidelines for the Board’s actions where there is wholesale disclosure of treatment files.
The final Westinghouse factors are the government’s need for access and whether there is an express statutory mandate, public policy, or other public interest militating access. Although the majority correctly states that the Board was established by the General Assembly “to protect the public by: (1) Setting minimum qualification, education, training, and experience standards for the licensing of individuals to practice social work, and (2) Promoting and maintaining high professional standards for the practice of social work,” Md. Code (1981, 2000 Repl.VoL), § 19-102 of the Health Occupations Article, neither of these purposes justify an unwarranted intrusion into the treatment records of other clients, who neither know about the disclosure nor have they been given an opportunity to be heard. Without any evidence specific to the other clients supporting the belief that further wrongdoing by the social worker occurred, this indeed becomes a “fishing expedition.”
The majority cites Dr. K v. State Board of Physician Quality Assurance, 98 Md.App. 103, 632 A.2d 453 (1993), and the opinion by the United States District Court for the District of Maryland in Patients of Dr. Barbara Solomon v. Board of Physician Quality Assurance, 85 F.Supp.2d 545 (D.Md.1999), with approval. Although those opinions support the determination that the Board properly subpoenaed the *197Does’ records, they fall far short of justifying a subpoena, in this case, for Ms. F’s records for all of her clients.
Both Dr. K and Patients of Dr. Solomon involved subpoenas for records of specific patients. Dr. K, 98 Md.App. at 105-06, 632 A.2d at 454-55; Patients of Dr. Barbara Solomon, 85 F.Supp.2d at 546. In Patients of Dr. Barbara Solomon, as in the present case, the patients asserted that disclosure of their medical records violated their privacy interest. Patients of Dr. Barbara Solomon, 85 F.Supp.2d at 546. Because the District Court opinion did not summarize the facts of the underlying case, the following facts are found in the Court of Special Appeals case addressing the merits of the case. The nineteen patients who sought the temporary restraining order and preliminary injunction from the United States District Court were randomly selected from Dr. Solomon’s appointment logs by the Board in its investigation of her consent and disclosure procedures, billing practices, and use of experimental procedures. Solomon v. Board of Physician Quality Assurance, 155 Md.App. 687, 700-01, 845 A.2d 47, 55 (2003). Because the scope of the complaint implicated practices that occurred with all of Dr. Solomon’s patients, the Court of Special Appeals found the information sought by the subpoena to be relevant to the investigation and the demand sufficiently limited. Id. In the case of Dr. K, the subpoena at issue directed Dr. K to deliver “any and all medical records” of patient A; Dr. K. was patient A’s psychiatrist. Dr. K, 98 Md.App. at 115, 632 A.2d at 459.
In the instant case, the allegations in the complaint against Ms. F do not reflect systemic practices, but rather her conduct with a specific client in a particular situation. We are not talking about billing records here we are talking about notes reflecting the innermost concerns of individuals. Significantly absent from the majority discussion is any means of notification to Ms. F’s other clients prior to the disclosure of their files. Unlike the case involving Dr. Solomon, where the patients were clearly notified that their medical records were subpoenaed by the Board of Physician Quality Assurance, the majority grants the Board unfettered access to any treatment *198provider’s files, without allowing the clients any opportunity to be heard.
In Dr. K, the State Board of Physician Quality Assurance initiated an investigation of Dr. K following a complaint alleging that he and his former patient were involved in a romantic relationship and that he was depressed and abusing alcohol. Dr. K, 98 Md.App. at 105-06, 632 A.2d at 455. Dr. K asserted the patient’s privacy interest to bar the disclosure of her mental health records. Id. at 106-07, 632 A.2d at 454-55. The case did not involve an attempt by the Board of Physician Quality Assurance to obtain access to all of Dr. K’s patient files. As in Dr. K, the complaint against Ms. F only implicated her actions with respect to the Does and did not extend beyond her treatment of that family. The reasoning of Dr. K cannot be twisted to support access to any files beyond those prepared for the Does.
Therefore, the caselaw cited does not support disclosure of all treatment files for all of Ms. F’s clients. Any analysis of the Westinghouse factors would show that the privacy interests of Ms. F’s other clients would substantially outweigh the interest that the Board would have in obtaining access to Ms. F’s files for all of her clients, had that analysis occurred. The majority’s sweeping opinion is a dangerous intrusion into the private lives of individuals without any due process — “taking” their private thoughts apparently has less value than a “taking” of their property. Under the majority’s reasoning, no client’s private information is safe from exposure, and no client can feel secure in the knowledge that their innermost thoughts and fears will remain sheltered from prying eyes. The consequences are far-reaching and beyond the majority’s consideration.
Judge Raker authorizes me to state that she joins in this dissent.
. A social worker has standing to raise the privacy interests of her clients. Cf. Singleton v. Wulff, 428 U.S. 106, 117, 96 S.Ct. 2868, 49 L.Ed.2d 826 (1976) (allowing a physician to assert privacy rights of his or her patients); Griswold, v. Connecticut, 381 U.S. 479, 481, 85 S.Ct. 1678, 14 L.Ed.2d 510 (1965) (holding that a physician has standing to raise his or her patient's privacy rights).
. There may be federal law implications with respect to wholesale disclosure of all of the treatment files under the privacy provisions of the Health Insurance Portability and Accountability Act (HIPAA), Pub. Law 104-191, 110 Stat.1936 (1996) (codified at 18 U.S.C. §§ 24, 669, 1035, 1347, 1518, 3486 (2000); 26 U.S.C. §§ 220, 4980C to 4980E, 6039F, 6050Q, 7702B, 9801-9806 (2000); 29 U.S.C. §§ 1181 to 1187 (2000); 42 U.S.C. §§ 300gg, 300gg-ll to 300gg-13, 300gg-21 to 300gg-23, 300gg-41 to 300gg-47, 300gg-91, 300gg-92, 1320a-7c to 1320a-7e, 1320d-l to 1320d-8, 1395b-5, 1395ddd (2000)), that have not been explored.