Security Camera Use Policy

 

No. 5-36b 
Rev.   NEW 
Date 8-23-16    

 


I. REFERENCES

PPM 10-1, Information Security Policy
PPM 10-2, Acceptable Use Policy
20 USC § 1232g, Family Education Rights and Privacy Act ("FERPA")

II. PURPOSE

Security camera equipment use is intended to deter crime, assist in protecting the safety and property of the Weber STate University community, and assist in law enforcement efforts.  This policy is intended to address the University's safety and security needs while considering individual privacy rights, in accordance with University policy and state and federal law.  This policy governs the installation oand usage of security camera equipment and the handling, viewing, dissemination, and retention of security camera equipment records, as described herein.
 
The existence of this policy does not imply or guarantee that security camera equipment will be used in any particular location or monitored in real time continuously or at any given moment.

III. DEFINITIONS
 

1. For the purposes of this policy, “Security camera equipment” means any software and/or hardware used to capture, record, and/or monitor visual, audio, thermal and/or nonvisual electromagnetic radiation for Weber State University safety or security purposes and for other law enforcement purposes. Such equipment may be temporary or permanent.

2. “University entities” means any employee, department, college, program, or organization of the University.

3. Security Camera Oversight Committee (SCOC): a committee established, as needed, comprising of the following members or designees; WSU Chief of Police, Vice President for Information Technology, Vice President over the area in question and Associate Vice President for Facilities Management. The SCOC is responsible for reviewing petitions regarding denial of installation of security camera equipment, and reviewing and approving requested exceptions to this policy.

IV. POLICY

A. Scope

1. This policy applies to all University entities in the use of security camera equipment. Security camera equipment may be installed in situations and places where the security and/or safety of property or persons would be enhanced. Such situations may include the following:

a. Property Protection: Where the main intent is to capture video and store it on a remote device so that if property is reported stolen or damaged, the video may show the perpetrator. Examples: an unstaffed computer lab, an unstaffed science lab, or a parking lot.

b. Personal Safety: Where the main intent is to capture video and store it on a remote device so that if a person is harmed, the video may show the perpetrator. Examples: a public walkway, or a parking lot.

c. Extended Responsibility: Where the main intent is to have the live video stream in one area and be monitored by a staff member in close proximity. In this case video may or may not be recorded. Example: a computer lab with multiple rooms and only one staff.

2. This policy does not apply to recording equipment used for academic purposes, such as classroom capture. Recording equipment that is used for research is generally governed by other policies involving human subjects and is, therefore, excluded from this policy. This policy does not address the use of Webcams for general use by the university (e.g., office

webcams used for videoconferencing). This policy also does not apply to the use of video equipment for the recording of public performances or events, interviews, or other use for broadcast or educational purposes. Examples of such excluded activities would include videotaping of athletic events for postgame review, videotaping of concerts, plays, and lectures, or videotaped interviews of persons. Automated teller machines (ATMs), which may utilize cameras, are exempt from this policy. Usage of other recording devices is governed by other University policies and laws.

B. Responsibilities

1. The Weber State University Police Department (“WSUPD”) has the authority to coordinate, operate, manage, and monitor the selection and use of all security camera equipment on campus and all data collected on campus pursuant to this policy. All usage of security camera equipment must be approved through the WSUPD. WSUPD may create processes for submitting requests for usage of security camera equipment and exceptions to this policy.

2. WSUPD shall consult with the Information Technology Department (“IT”) and the Facilities Management Department (“FM”) prior to approving any requests for installation of security camera equipment. These entities will review proposals and recommendations for security camera equipment installation and review possible security camera equipment locations to ensure that locations and the perimeter of view of fixed location security camera equipment is appropriate.

3. WSU Facilities Management and WSU IT shall oversee the installation of all approved security camera equipment with the assistance of the WSUPD, as required.

4. Purchasing will not accept, approve, or process any order for security camera equipment without the approval of the Chief of Police, or if necessary the SCOC.

5. All University entities using security camera equipment are responsible for complying with this policy in their respective operations. Installation of camera equipment shall be the financial responsibility of the requesting University entity.

6. Exceptions to this policy will only be granted through the exception process explained herein. Any security camera equipment found not to comply with this policy will be subject to removal.

7. IT, WSUPD, and FM are responsible for advising University entities regarding appropriate use of security camera equipment. These entities may provide technical assistance to University entities and personnel in preparing proposals for the purchase and installation of security camera equipment.

8. University entities that have installed approved security camera equipment are responsible for regularly verifying that the security camera equipment in their area is maintained in good working order. If the security camera equipment is not working properly, the University entity must notify FM. The University entity is responsible for all costs associated with repair or replacement.

C. Placement and Usage of Security Camera Equipment

1. Security cameras may be placed in areas such as the following:

a. Those containing security systems, such as:

b. Access control systems, which monitor and record restricted-access at entrances to buildings and other areas.

c. Security alarms, including intrusion alarms, exit-door controls, hold-up alarms, cashier locations, etc.

d. Those containing sensitive institutional data, technology operations, or core infrastructure

e. Sections of the university campus and buildings that are high-traffic, such as shopping areas, perimeters, testing centers, computer laboratories, eateries, unrestricted entrances, exits, lobbies, corridors, and receiving docks

f. Those housing sensitive operations, such as storage areas for special materials, laboratories, select agents, etc.

g. Those containing rare, high-value, or merchandise property

h. High-crime areas

i. Areas subject to active criminal investigation surveilled in accordance with federal and state laws

2. Security camera equipment will not be placed in areas solely dedicated to private office space unless: 1) the primary occupant consents; or 2) the primary occupant is subject to an active criminal investigation and the security camera equipment placement is in accordance with federal and state laws.

3. Security camera equipment positions and views of residential housing shall be limited to community areas unless: 1) the primary occupant consents; or 2) the primary occupant is subject to an active criminal investigation and the security camera equipment placement is in accordance with federal and state laws.

4. Under no conditions will the university install security camera equipment in bathrooms or locker rooms; however, the university reserves the right to install security camera equipment near the entrances to bathrooms or locker rooms for purposes of criminal investigations, as permitted by law.

5. No audio shall be recorded except in areas where no one is routinely permitted. Requests to utilize audio surveillance that does not comply with this requirement will be evaluated on a case by case basis by the SCOC.

6. The installation of "dummy" security camera equipment that does not operate is prohibited.

7. Unless being used for criminal investigations, all security camera equipment should be visible.

D. Access and Monitoring

1. All recording or monitoring under this policy will be conducted in a professional, ethical, and legal manner. All personnel with access to security camera equipment shall undergo a background check, as described in PPM 3-5a, and shall be trained in the effective, legal, and ethical use of security camera equipment.

2. Security camera equipment is not monitored continuously under normal operating conditions but may be monitored for legitimate safety and security purposes that include, but are not limited to surveillance of high risk areas, restricted access areas/locations, in response to an alarm, special events, and specific investigations authorized by the Chief of Police or designee.

3. To protect the university, its employees, students, visitors, and the preservation of evidence, access to live video or recorded video from camera equipment shall be limited to WSUPD and other persons authorized by the Chief of Police or designee, except as required by law. The copying, duplicating, and/or retransmission of live or recorded video must be authorized by the Chief of Police or designee.

E. Appropriate Use and Confidentiality

1. Personnel are prohibited from using or disseminating information acquired from security camera equipment, except for purposes described herein and/or as authorized by the WSUPD.

2. Information must be handled with an appropriate level of security to protect against unauthorized access, alteration, or disclosure in accordance with PPM 10-1, Information Security Policy.

3. All appropriate measures must be taken to protect privacy rights identified by law or policy and to hold university information securely through its creation, storage, transmission, use, and deletion.

4. Security camera equipment records are considered confidential, to the extent permitted by applicable law, and can only be used for official university and law enforcement purposes.

5. Except for records falling within the records of a law enforcement unit as defined in 34 CFR § 99.8 and other exceptions under 34 CFR § 9.3, all other security camera equipment records directly related to students and maintained by WSU are deemed to be education records pursuant to FERPA. Usage and dissemination of such records will be governed by FERPA.

6. In instances in which the security camera equipment records may be subject to GRAMA, security camera footage is generally designated as “protected” and/or “private” under GRAMA, however, WSU reserves the right to re-classify all such records as appropriate.

7. The Chief of Police or designee will review all internal and external requests to view or release security camera equipment records. The Chief will consult with University Legal Counsel related to any request for release.

8. WSUPD shall create a retention schedule and procedures for storage of camera equipment records.

F. Security Camera Oversight Committee

1. The SCOC shall be advised by University Legal Counsel. Any member may appoint a designee to act in his or her place.

2. This policy is intended to comply with state and federal law in all respects.

3. Nothing in this policy shall be construed to restrict law enforcement’s ability to undertake legitimate law enforcement activities or investigations to the full extent permitted under the law.