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Indiana Wesleyan University Support Knowledge Base

In Process - Surveillance Camera Use

Overview

One component of the Indiana Wesleyan security plan is the use of security and safety cameras.  This policy is intended to address security needs while including individual privacy.

Purpose

This policy addresses the procedures for the installation of surveillance equipment and the handling, viewing , retention, and deletion of surveillance tapes.

Policy

 

Define General Principles

The perimeter of view of fixed location cameras needs to conform to policy.  In addition we would review any complaints regarding the use of surveillance.

  • Cameras will be limited to uses that do not violate the reasonable expectation of privacy as defined by law.
  • All camera installations are subject to federal and state laws.
  • All approved camera installations must have a specific stated purpose, that this purpose must be noted on the signage for the camera, and the video capture shall be limited to the specific stated usage. (RD suggestions)
  • Care must be taken with storage, transmission, use, creation and destruction of any tapes used.
  • Information shall be used exclusively for law and/or policy enforcement.

Placement of cameras

                Legitimate Uses:

  • Restricted access sites such as computer labs
  • Protection of buildings and property
  • Building perimeter, entrances and exits, lobbies and corridors, receiving docks, special storage areas, laboratories, cashier locations, etc.
  • Monitoring or access control systems
  • Verification of security alarms
  • Monitor and record restricted access transactions at entrances to buildings.
  • Intrusion alarms, exit door controls, hold-up alarms, etc.
  • Video patrol of public areas.
  • Transit stops, parking lots, public (enclosed and unenclosed streets, vehicle intersections)
  • Criminal investigation
  • Robbery, burglary and theft surveillance
  • Protection of pedestrians
  • Monitor pedestrian and vehicle traffic and vehicles in traffic areas at intersections
  • Monitoring fan behavior at sporting events.
  • Monitor ATM usage.

                     Camera positions and views of residential housing shall be limited.

  • No cameras in student dormitory rooms
  • Bathrooms
  • Locker rooms
  • Offices
  • Classrooms not used as labs

All video camera installations should be visible.

One school requires signage stating that “This area is subject to surveillance for security purposes and may be monitored.”

All monitoring will be conducted in an ethical and legal manner.

A database of all approved installations (including temporary) should be maintained.  If the reason for monitoring a specific location no longer exists it should be removed.

Personnel are not allowed to use information received from these security cameras except for

official reasons.

Several schools said monitoring is prohibited from being based on perceived individual characteristics or classifications such as race, sex. ethnicity, sexual orientation or disability.

Locations must be designed to prevent tampering with recorded material including unauthorized access to the output of the equipment.  Access must be over a secure channel.  Video output does not need to be encrypted but reasonable steps should be taken to prevent interception.

Use of cameras may be used in criminal investigations by Campus Police.

Exclusions:

Policy excludes use of Webcams.  Also does not include use of video equipment used for recording public events, performances or other use of broadcast purposes.

                Excluded:

  • Athletic events
  • Concerts, plays and lectures.
  • ATM which use cameras are exempt from policy.

Procedures

                Written request from appropriate dean or vice president needs to be submitted to committee.  This should include justification, cost estimates and funding sources.  These requests will be reviewed by someone decided on by committee in advance.  They will then relay this to the committee.  If approved it will be handled in a manner decided by committee.

Purchasing will not accept any request for security cameras without the approval of the committee.

Cameras should not view private rooms or areas through windows.

All operators will perform their job in accordance with policy.

 

Record Storage

All records will be stored in a centralized location for a period of (14 – 30)  days and will then promptly be erased unless retained as part of a criminal investigation.  No other area will be allowed to store these recordsl.

A log shall be maintained to include all who have access to these tapes (including time stamp).

FERPA

Any recording that includes personally-identifiable images of students is governed by the Family Education Right to Privacy Act.

Some statement regarding purchase of equipment.

Some statement regarding replacement and upgrades.

Repairs and maintenance

Not included under this policy:

Hand-held mobile cameras used for research, teaching, class work or personal use.

Web cameras for communication purposes in faculty and staff private offices.

 

Scope

“All existing uses of security camera systems shall be brought into compliance with this policy by ##/##/##.  Unapproved or nonconforming devices will be removed” 

 

History

18-Apr-2012 - This policy is a draft and is not yet in effect.

Owner

An oversight committee should be established by John Jones to oversee implementation of this policy.  The committee  in turn would establish and maintain standards for electronic security and access control.  Proposed revisions would be reviewed by a committee.  (This could be composed of a committee including Campus Police, Information Technology and Facilities, ).  Note:  One university includes the Head of Campus Police, CIO or designee, VP for Student Affairs or designee,  VP or Facilities or designee and Director of Emergency Management or designee) for their committee.  Another  university included VP for IT, IT Security , Human Resources, Campus Police, Student Affairs designate, General Counsel, Faculty Senate rep.  A third simply states that the committee shall be consisted of representatives from Physical Facilities and IT Services Networking.  The committee would be responsible for the appropriate application of surveillance and for technical assistance to the areas submitting proposals for installation of cameras.

Functions fall into two categories:

                Property protection and personal safety.

 

Policy Information

Equipment Policy

References

FERPA INFORMATION:

From “Balancing Student Privacy and School Safety:  A Guide to the Family Education Rights and Privacy Act for Elementary and Secondary Schools”  October 2007

            Security Videos

Schools are increasingly using security cameras as a tool to monitor and improve student safety. Images of students captured on security videotapes that are maintained by the school's law enforcement unit are not considered education records under FERPA. Accordingly, these videotapes may be shared with parents of students whose images are on the video and with outside law enforcement authorities, as appropriate. Schools that do not have a designated law enforcement unit might consider designating an employee to serve as the "law enforcement unit" in order to maintain the security camera and determine the appropriate circumstances in which the school would disclose recorded images.

 

Surveillance Cameras

According to Indicators of School Crime and Safety: 2005 (U.S. Departments of Education

and Justice, 2006), schools continue to implement a variety of tools to improve safety

and monitor activities. In fact, the report notes that “in 1999–2000, 14 percent of

primary schools, 20 percent of middle schools, and 39 percent of secondary schools

used one or more security cameras to monitor the school.”

School cameras are typically placed in areas that do not infringe on students’ right to

privacy, such as classrooms, hallways, common areas, and building perimeters. However,

recent reports of cameras in bathrooms have sparked a debate over the appropriate balance

between student privacy rights and the need for school security. While FERPA does not

specifically address this issue, school systems should have a surveillance camera policy

10 Forum Guide to the Privacy of Student Information

Outlining the rights and responsibilities of students, teachers, administrators, and other

school staff. As a best practice, the policy should include the following:

• a clear statement of appropriate reasons for using surveillance cameras;

• the role and responsibilities of individuals with access to the cameras;

• who will have access to any footage;

• how long will any footage be kept and how will it be destroyed; and

• a consent provision.

For FERPA purposes, surveillance videotapes (or other media) with information about a

specific student are considered education records if they are kept and maintained by the

school system. If the school’s law enforcement unit controls the cameras/videos and it

is doing the surveillance for safety reasons, the ensuing videos would be considered law

enforcement, rather than education, records. As soon as school officials use them for

discipline purposes, however, the tapes become education records and are subject to FERPA requirements.

 

From Forum Guide to The Privacy of Student Information – A Resource for Schools

http://nces.ed.gov/pubs2006/2006805

Policies reviewed from :

Penn State http://guru.psu.edu/policies/AD65/html

Privacy and Security Risks in Higher Education  http://www.educause.edu/Resources/PrivacyandSecurityRisksin Highe/243679

Texas A & M http://www.educause.edu/Resources/TexasAMUniversitySecuritySurve/249644

Virginia Tech  http://www.educause.edu/Resources/VirginiaTechSafetyandSecurityC/249654

Northwestern University http://www.northwestern.edu/up/docs/NorthwesternVideoPolicy.pdf

Miami University Fixed Installed Camera Policy http://www.educause.edu/Resources/MiamiUniversityFixedInstalledC/195212

Provide links to external references...

Additional Remarks

A group needs to be identified to review all external requests to release surveillance records.

In addition a group needs to be identified to review all requests for placement of surveillance cameras.

.

 

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