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Video Surveillance and Recording Systems Policy

University of Central Missouri Procedure

Procedure Name:  Video Surveillance and Recording Systems Policy

Date Approved:  August 24, 2017

Procedure Category:  University Operation

Date Effective:  August 24, 2017

Policy Authority:  1.2.040

Date Last Revised:  

Approval Authority:  University President

Review Cycle:

Responsibility: UCM Public Safety

 

Purpose/Policy Statement

The purpose of this policy is to provide guidelines for the installation, use monitoring, storage, and retention of video surveillance recordings.

The University uses video surveillance and recording systems to assist the Department of Public Safety in law enforcement, including providing for the security and safety of individuals and property.  The equipment will be used in a manner that enhances public safety and respects reasonable expectations of privacy of faculty, staff, visitors, and students.

Scope

This policy applies to all property owned or leased by the University.

Definitions

Department – Department of Public Safety, University of Central Missouri

Director – Director and Chief, Department of Public Safety, University of Central Missouri

Private Area – Anywhere a person has a reasonable expectation of privacy.  This may also include private office spaces except in those areas where monetary transactions occur or where surveillance is appropriate to deter property crimes.

Place Where a Person Would Have a reasonable Expectation of Privacy – Any place where a reasonable person would believe that a person could disrobe in privacy, without being concerned that the person’s undressing was being viewed, photographed or filmed by another.

Video Surveillance System – Technology that can be used to remotely monitor and/or record activity.

Procedure

Use and Confidentiality

  1. All information and/or observations made in the use of surveillance video are considered confidential.  Personnel are prohibited from using or disseminating information acquired from surveillance video except for official purposes as authorized under this policy.
  2. The Department may monitor and review all video surveillance feeds and recordings as needed to support investigations and to enhance public safety.
  3. Videos may be used for criminal, Title IX, and/or other investigations as appropriate.
  4. Requests from University personnel to view the recordings shall be initiated through the appropriate director, dean, vice-provost or vice-president who will consult with the Director to determine if the requested viewing is appropriate.  A log shall be maintained by the Director or designee of all persons given access to view video recordings and the specific recordings viewed.
  5. Requests by non-University personnel for access to a video surveillance recording shall be reviewed by the Office of General Counsel, as third party access to the recordings should be allowed only when the University is legally obligated to do so.  A log shall be maintained by the Director or designee of all persons given access to view video recordings and the specific recordings viewed.
  6. The Director may authorize the viewing of live images or recordings by other law enforcement agencies conducting a criminal investigation or who are assisting the Department during a campus emergency.

Limitations of Video Surveillance Systems

  1. Most University cameras are not monitored continuously.
  2. The video surveillance system has cameras that cover only a small fraction of the total campus.
  3. The system will not detect every incident taking place in areas of coverage.
  4. In areas where camera coverage exists, it may not provide the level of detail necessary to spot suspicious activity or identify criminals.

Prohibited Uses

  1. Cameras are not used to track the work habits or productivity of individual employees.
  2. Cameras will not be used in a place where a person would have a reasonable expectation of privacy.
  3. Monitoring individuals based on characteristics of race, gender, ethnicity, sexual orientation, disability, or other protected classification is prohibited unless the characteristic is part of a suspect’s description in a specific offense.
  4. Video monitoring shall not be used to harass, intimidate, or discriminate against any individual or group.
  5. The University will not use fake cameras. Inoperable cameras will be removed, replaced or repaired as soon as practicable.

Covert Monitoring

  1. Use of covert video surveillance equipment must be authorized by the Director and be directly related to the investigation of a suspected criminal offense.
  2. Covert monitoring must cease following completion of an investigation.
  3. Covert monitoring will not be used in areas where there is a reasonable expectation of privacy.
  4. The Director will cooperate with outside law enforcement agencies with the legal authority to conduct covert video surveillance on University property.

Management of the video surveillance system

  1. The Director or designee, in consultation with the Office of General Counsel, has the authority to coordinate and manage all campus video surveillance systems subject to this policy, including but not limited to final authority for approval of video camera deployment and placement.
  2. Web cameras installed by the University to communicate construction progress or other University related projects of general interest to constituents must be coordinated through the Director.
  3. The Vice Provost for Technology (CIO) shall in consultation with the Director create specifications for equipment and software.
    1. Cameras and the camera network should be equipped with only those features or capabilities reasonably necessary to serve the purpose of the system. Technological features like magnification, night vision, infrared detection, and automatic identification and tracking, should be used only where they are needed.
    2. The system shall be designed in a manner that allows for authentication and establishment of a chain-of-custody for data that will potentially be used as evidence.
    3. The system shall be capable of securing and storing data that must be retained as evidence.
    4. The system should provide for operator logon, access control, and other standard audit features to ensure a clear audit trail is maintained of access to the system.
    5. All video surveillance equipment purchased after effective date of this policy must meet the standards.
    6. The CIO may determine at a future date that equipment acquired prior to this policy can no longer be supported by the University and direct that its use be discontinued.
  4. Video storage hardware will be provided and maintained by the CIO in support of the Department.
  5. Concerns about violations of the policy, placement of cameras, or use of the video surveillance equipment or recordings should be referred to the Director.
    1. The Director or his/her designee is responsible for assuring compliance with this policy.
    2. They will weigh the potential security and safety benefits against any concerns expressed.
    3. Complainants will be notified of the Director’s decision in writing.
    4. Appeals of the decision will be referred to the University President or his/her designee.
  6. The Director and CIO in consultation with the Office of General Counsel will evaluate the system and policy annually.

Requests to Implement Video Surveillance

  1. Departments or areas desiring to implement video surveillance are required to obtain approval from the appropriate director, dean, vice-provost, or vice president.
  2. Departments must have an approved funding source.  They are responsible for the purchase of all necessary equipment, cameras, wiring, installation, repairs and software licenses associated with the camera.
  3. Departments must submit a proposal and justification to the Director of Public Safety which addresses at a minimum:
    1. Rationale for use (a brief description stating why cameras are necessary to the program or area and whether they are designed for crime prevention, investigation of crimes, and/or protection of vulnerable infrastructure).
    2. How the system will be monitored (real-time monitoring with footage streamed but not stored, real-time monitoring with footage stored, or footage stored but not monitored).
    3. Specific areas where video surveillance and/or recording equipment will be used.
    4. Any potential concerns and how they will be addressed.
    5. Point of contact for the Department.
    6. Funding source.
    7. Endorsements/approvals from appropriate director, dean, vice-provost, or vice-president.
  4. Prior to approval a site survey will be coordinated by Public Safety and the Office of Technology and Facilities, Planning and Operations with a cost estimate provided to the appropriate budget manager.

Tampering

  1. Any person who tampers with or destroys video surveillance equipment will be subject to University disciplinary procedures and/or criminal prosecution.
  2. Any person altering or attempting to alter any part of a surveillance recording will be subject to University disciplinary procedures and/or criminal prosecution.

Video Retention Requirements

  1. Audio/video surveillance recordings will be retained for a minimum of 30 days prior to destruction or re-use of the recording medium.
  2. The University will destroy all video surveillance recordings after 30 days unless otherwise required to retain.
  3. Videos depicting criminal or other liability issues should be preserved until all administrative/judicial proceedings are complete.

Policy Does Not Apply To

  1. Police body cameras worn by members, Department vehicle or dash cameras, or recordings of interrogations conducted by the Department.  See separate policies.
  2. Cameras used for academic purposes where notice has been given that video or audio recording is occurring.
  3. Cameras used for research that is regulated by the University’s Institutional Review Board or the Institutional Animal Care and Use Committee.
  4. General web broadcasts made by the University, i.e.; commencement, state of the university addresses, Board of Governor’s meetings, etc.
  5. Recording of public performances events, or interviews for broadcast, i.e.; athletic events, concerts, plays, lectures, etc.
  6. ATMs with video cameras are exempt from this policy.
  7. Cameras used for video conferencing and/or cameras attached to individual computers

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