Acceptable Use Policy on Safety & Security Cameras
Policy Statement
91暗网 is committed to creating a safe and supportive environment for all members of our community while respecting and preserving individual privacy. Consistent with this commitment, the College utilizes a safety and security camera system in public and common areas as one element of its comprehensive security plan. The purpose of recording and monitoring safety camera systems in public and common areas is to deter crime, create an overall sense of security on campus, and to protect the safety and property of the 91暗网 community. Any diversion of security technologies and/or personnel for other purposes undermines the acceptability of these resources for critical safety goals and is therefore prohibited.
Information obtained from security cameras is considered College property and will be used solely for safety and security purposes, including to assist the Department of Campus Safety and potentially law enforcement in investigating offenses of law and violations of 91暗网 policies.
The purpose of this policy is to outline the responsibility, decision-making process and regulations regarding the use of safety and security cameras to monitor and record activity in public or common areas to improve safety and security at 91暗网.
Types of Safety and Security Cameras
There are two categories of safety and security cameras utilized by the College: cameras that are part of the College鈥檚 Safety and Security Camera System and Temporary Safety and Security Cameras.
- The College鈥檚 Safety Camera System includes any video or still camera or other image recording technology installed in a permanent position on campus and the accompanying components of the system to record, store, view, search, or otherwise access the data contained within the system. Safety Camera Systems include commonly referred to devices as; security cameras, closed circuit television (CCTV), license plate readers (LPR). Safety Camera Systems do not include handheld camera such as smartphones, portable video cameras, body cameras, dashboard cameras or mobile LPRs.
- Temporary Cameras are used on a short-term basis to provide monitoring capabilities for specific event(s), such as festivals or assemblies, or in response to specific campus safety or security concerns as determined by the Department of Campus Safety, General Counsel and Vice President for Human Resources and the Dean of Students and/or Dean of the Faculty.
Security Camera Placement and Installation
The decision to deploy safety and security cameras and the specific placement of those cameras falls under the authority of the Department of Campus Safety. The decision to deploy cameras will be based on mitigating risks, vulnerabilities, and historical acts of criminal behavior. Safety and security cameras will not be installed in areas where individuals have a reasonable expectation of privacy and are subject to federal, state and local laws.
When developing strategies for camera placement and installation, the Department of Campus Safety conducts security surveys, risk analyses and threat assessments to individual buildings, areas and the 91暗网 community as a whole. This information is critical in determining the types of safety camera equipment most appropriate for each situation. These factors might inform the decision to use fixed, pan/tilt/zoom (PTZ), color, night vision or day/night cameras.
Safety and security cameras may be installed in public and common areas, such as entrances and exits to buildings, walkways, parking lots and pathways. Cameras may also be installed at residence hall entrances, lobbies and laundry rooms, or within or outside, offices located within residence halls. When used here the term 鈥渞esidence hall鈥� shall mean any student housing facility including traditional residence halls, apartment buildings or other student housing.
The Department of Campus Safety will not approve the installation of cameras with positions and or views of areas that are traditionally considered private. These areas include: residence hall rooms, bathrooms, shower areas, locker and changing rooms, areas where a reasonable person might change clothing, or private offices. Additionally, rooms used for medical, physical, or mental health therapy or treatment are private. Recording for safety and security purposes will not be used in residential hallways unless Campus Safety, in consultation with the General Counsel and Vice President for Human Resources and the Dean of Students, determines a specific safety or security risk exists (e.g., a serious or pattern of unlawful activity where other investigative means have not identified the responsible person(s) and there is a continuing risk to community members or their property). No cameras will be installed in areas prohibited by collective bargaining agreements.
Safety and security cameras will not be installed for the purpose of monitoring protected activities, including political, union or religious activities. Cameras will be located to maximize personal privacy and audio will not be recorded.
Safety and Security Camera Visibility Standards
To the greatest extent possible given the location and intent of the safety and security camera, all safety and security cameras will be placed in easily visible locations and will be accompanied by signage providing notice to the community that they are being video monitored. The purpose of this requirement is to ensure that individuals are aware that they are being recorded and to provide a deterrent effect against crime.
To maintain an informed 91暗网 community, the Department of Campus Safety will provide information describing the purpose and location of cameras used as part of the College鈥檚 Safety Camera System and the guidelines for their use annually.
Access and Monitoring of Safety and Security Cameras
Use of safety and security cameras in public areas for security purposes will be conducted in a manner consistent with all federal, state and local laws and College policies, including but not limited to the Non-Discrimination Policy, the Unlawful Discrimination and Harassment Policy and other relevant policies. This policy prohibits monitoring based on legally protected bases outlined in 91暗网鈥檚 Equal Employment Opportunity, Diversity and Anti-Harassment Policy and Procedure.
Personnel involved in video monitoring will be appropriately trained in the application of this policy and continuously supervised in the responsible use of this technology. Users will also receive appropriate diversity/cultural awareness training.
Safety and security cameras are not monitored continuously under normal operating conditions but may be monitored for reasons consistent with this policy. The Department of Campus Safety will not use camera technology to monitor staff, faculty, student鈥檚, vendor鈥檚, contractor鈥檚 or other visitor鈥檚 conduct unless there is an investigation pertaining to conduct contrary to the law or 91暗网 policy. Any such monitoring or review must be accompanied by a written complaint, report, memo, email or any correspondence as to the nature, scope and level of action to be taken. However, the College may utilize security camera recordings captured during normal operating conditions to investigate suspected unlawful conduct or conduct that violates College policy. The Department of Campus Safety will seek guidance from 91暗网 Human Resources or Student Conduct as deemed appropriate, and, in all instances, Legal Counsel, to ensure legal and policy compliance.
Information obtained through system monitoring will be used exclusively for security, safety and significant policy violation purposes. Information obtained through video monitoring will only be released when authorized by appropriate administrative personnel in accordance with this policy.
Appropriate Use and Confidentiality
Users of the College鈥檚 security camera system are prohibited from using or disseminating information obtained from safety and security cameras except as provided in this policy. All information acquired or observations made in the use of safety and security cameras is confidential and can only be used for official College and law enforcement purposes. Users will receive a copy of this policy and provide written acknowledgement that they have read and understood its content.
Responsibilities
The Department of Campus Safety is the department authorized to oversee and coordinate the use of camera installation and monitoring for safety and security purposes at 91暗网. The Department also has the primary responsibility for disseminating and implementing policy and procedures. The Department of Campus Safety will ensure that responsible and proper camera monitoring practices by operators is continuous by periodically reviewing stored images.
The Associate and Assistant Directors of Campus Safety will ensure that the Department of Campus Safety adheres to established policy and procedure in the use of safety cameras and will review camera locations and requests for release of video media with 91暗网鈥檚 Director of Campus Safety and will monitor new developments in relevant law and in security industry practices to ensure that camera monitoring and recording at 91暗网 are consistent with the standard practices.
The Department of Campus Safety, Information Technology and Requesting Department, if applicable, will configure systems to reasonably prevent anyone from tampering with, accessing or duplicating recorded information without authorization.
Security and/or Legal Counsel
- The Associate and Assistant Directors of Campus Safety, will review camera locations to insure the view of fixed location cameras conforms to this policy. The locations of temporary cameras to be used for special events will be reviewed by the Vice President of Finance and Administration or designee for approval before the event.
- Included with the list of camera locations will be a general description of the technology deployed and the capabilities of the cameras. If concern over camera placement should arise, concerned persons may petition the Vice President of Finance and Administration for the removal of an existing camera. The Vice President of Finance and Administration will review the request weighing the concerns of the person(s) making the request, the safety and security of the entire community, and any infringement of individual privacy.
- The Director of Campus Safety or designee will review all requests received by the Department of Campus Safety to release recordings obtained through the safety camera system. No release of recordings will occur without authorization by the Vice President of Finance and Administration. The Vice President of Finance and Administration will only approve release of recordings for legitimate purposes, such as to protect 91暗网 College and its members from lawsuits or harm. The Vice President of Finance and Administration will consult the legal counsel in these cases prior to the release of recordings.
- The Vice President of Finance and Administration, or designee will audit the Department of Campus Safety 鈥檚 camera monitoring operations, including video media storage, on a semi-annual basis and make procedural changes to ensure standards and operations conform to this policy.
Implementation
All existing systems used for video monitoring and recording will be brought into compliance with this policy within twelve months of the approval of this policy. Any new video systems must be reported to and approved by the Director Campus Safety prior to the installation. For the purposes of this policy 鈥渧ideo monitoring and recording鈥� does not include video recordings made for traditional purposes of marketing, engagement, training, research or education.
Review and Update of Policy
This policy shall be subject to review by the College鈥檚 Safety Committee on a biennial basis and will monitor new development in the law, industry best practices and protections. The Department of Campus Safety will continuously evaluate this policy to ensure its effectiveness and is responsible for ensuring its compliance with applicable laws, regulations and College policies.