Security Camera Policy

This policy applies to the University of Connecticut at Storrs, the University’s regional campuses and the University’s School of Law. The determination of whether a facility leased by the University, whether as lessor or lessee, will be subject to this policy will be made by the Chief of Police on a case-by-case basis, taking into consideration factors including the location of the facility, facility attributes, and the terms of the pertinent lease agreement.

This policy applies to all faculty and staff employed by, and to all schools and departments within, the University. This policy shall not apply to use of cameras for reasons unrelated to surveillance activity, including remote monitoring of facilities construction and progress, videotaping of athletic events for post-game reviews, the use of cameras in connection with human subject and animal research (which use shall be governed by University policies governing research) the use of cameras in certain laboratories to ensure safe research practices, and the use of cameras for legitimate educational purposes. Nor shall this policy apply to cameras used by law enforcement in the following manners: covert operations for the purpose of criminal surveillance; or mobile cameras used in, on, or about law enforcement or parking services vehicles; or body-worn or otherwise portable cameras used during the course of investigations or normal law enforcement functions; or parking enforcement cameras.

II. Purpose

The purpose of this policy is to provide guidelines for the use of security cameras on property owned and/or utilized by the University in a way that enhances security and aids law enforcement while respecting the privacy expectations of members of the University community.

The primary purpose of utilizing security cameras in public areas is to deter crime and to assist law enforcement in enhancing the safety and security of members of the University community and University property. The primary use of security cameras will be to record video images for use by law enforcement and other University officials charged with investigating alleged violations of law or University policy.

The existence of this policy does not imply or guarantee that security cameras will be monitored in real time continuously or otherwise.

III. RELATED POLICIES

• Acceptable Use, Information Technology
• University Code of Conduct
• General Rules of Conduct
• The Student Code

IV. Definitions

As used within and for the purposes of this policy, the following terms are defined as follows.

Chief of Police: the head of the Division of Public Safety or his or her designee.

Private areas: areas in which a person has a reasonable expectation of privacy, including, but not limited to,non-common areas of residence halls, residence hall corridors, bathrooms, shower areas, locker and changing rooms and other areas where a reasonable person might change clothes. Additionally, areas designed for the personal comfort of University employees or the safeguarding of their possessions, such as lounges and locker rooms, and areas dedicated to medical, physical, or mental therapy or treatment shall be considered private areas for the purpose of this policy.

Public areas: areas made available for use by the public, including, but not limited to, campus grounds, parking areas, building exteriors, loading docks, areas of ingress and egress, classrooms, lecture halls, study rooms, lobbies, theaters, libraries, dining halls, gymnasiums, recreation areas, and retail establishments. Areas of the University in which persons would not have a reasonable expectation of privacy, but to which access is restricted to certain University employees, such as storage areas, shall also be considered public areas for the purpose of this policy.

Security camera: a camera used for monitoring or recording public areas for the purposes of enhancing public safety, discouraging theft and other criminal activities, and investigating incidents.
Security camera recording: a digital or analog recording of the feed from a security camera.

Security camera system: any electronic service, software, or hardware directly supporting or deploying a security camera.

V. Responsibilities and Authority

Responsibility for oversight of installation, maintenance, and utilization of security cameras and associated policies, standards, and procedures is delegated by the President of the University to the Chief of Police. This responsibility includes:

1. creation, maintenance, and review of a campus strategy for the procurement, deployment, and use of security cameras, including this and related policies;
2. designation of the standard campus security camera system or service;
3. authorizing the placement of all security cameras;
4. authorizing the purchase of any new security camera systems;
5. reviewing existing security camera systems and installations and identifying modifications required to bring them into compliance with this policy;
6. creating and approving campus standards for security cameras and their use; and
7. creating and approving procedures for the use of security cameras.

VI. Control Elements

VI.1 Training

All personnel involved in the installation, maintenance or monitoring of security cameras: (a) will be instructed in the technical, legal and ethical parameters of appropriate camera use; and (b) will receive a copy of this policy and provide a written acknowledgment that they have read and understood its contents.

VI.2 Security Camera Placement

1. University Police shall be solely responsible for the oversight of temporary or permanent security cameras on campus. As such, all installations must be approved by them. Schools, departments and offices desiring the installation and use of security cameras shall submit a request for such installation to University Police. All proposals for the deployment of security cameras will include proposed sites for the placement of notifying signs (see Section VI.3. below). Installation of video security applications shall be the financial responsibility of the requesting school, department or office.
2. University schools, departments and offices presently utilizing security cameras shall promptly advise the University Police Department, which will review the location and utilization of the cameras and identify actions necessary to bring such usage into conformance with this policy.
3. Consistent with the requirements of state law, security cameras utilized by the University will not record or monitor sound. Audio recordings shall be prohibited unless permitted by law and specifically authorized by the Chief of Police.
4. Use of security cameras shall be limited to public areas. Video surveillance shall be not conducted in private areas of the campus unless specifically authorized by the Chief of Police pursuant to a search warrant or otherwise. If needed, electronic shielding will be placed in the security camera so that the security camera cannot be used to look into or through windows into private areas.
5. Where Security Cameras are permitted in private areas, they will, to the maximum extent possible, be used narrowly to protect persons, money, real or personal property, documents, supplies, equipment, or pharmaceuticals from theft, destruction, or tampering.
6. Security cameras shall not be directed at the windows of any privately-owned residence not located on University property.
7. Inoperative, placebo, or “dummy” security cameras shall NEVER be installed or utilized, as they may lead to a false sense of security that someone is monitoring an operational camera.

VI.3 Security Camera Monitoring and Review

1. The University Police may monitor and review security camera feeds and recordings as needed to support investigations and to enhance public safety. It is not intended or expected that security cameras will be routinely monitored in real time.
2. With the prior approval of the Chief of Police, other University personnel may monitor and review security camera live feeds and recordings for purposes of public safety.
3. Monitoring individuals based on characteristics of race, gender, ethnicity, sexual orientation, disability, or other protected classification is prohibited. Seeking out and continuously viewing people becoming intimate in public areas is prohibited.

VI.4 Notification Requirements

Except in emergency or investigative situations, all locations with security cameras will have signs displayed that provide reasonable notification of the presence of security cameras. The placement of the signs and the text on the signs will be subject to the approval of the Chief of Police.

Notification signs shall be placed in conspicuous areas in close proximity to the security cameras. For buildings with interior cameras, this shall include, at a minimum, the placement of signs at all primary building entrances. All such signs shall contain a notification that the cameras may or may not be monitored.

VI.5 Use of Recordings

Security camera recordings, with the approval of the Chief of Police, shall be used for the purposes of enhancing public safety, discouraging theft and other criminal activities, and investigating incidents (including the release of recordings by the Division of Public Safety to external law enforcement agencies). Recordings from cameras whose primary function is not security (such as classroom lecture capture) may, with the authorization of the Chief of Police, be used for these purposes.

Security cameras shall not be utilized to conduct personnel investigations, such as those related to (but not limited to) work place attendance or work quality. However, the University may utilize routine security camera recordings in support of disciplinary proceedings against employees and/or students, or in a civil suit or other proceeding involving person(s) whose activities are shown on the recording and relate to the proceeding. For example, the situation could be an arbitration or other proceeding and the proceeding could be by or against such person. Information obtained in violation of this policy may not be used in a disciplinary proceeding against a University student or employee.

The use of security cameras and/or recordings for any purpose not detailed within this policy is subject to including §6 of the campus policy on the Appropriate Use of Computers and Network Systems.

Records of access to and release of, Security Camera recordings must be sufficient so as to demonstrate compliance with this policy.

VI.6 Protection and Retention of Security Camera Recordings

Video footage will be stored on servers accorded appropriate computer security with access by authorized personnel only.

Security camera recordings will be retained in accordance with the records retention policies of the State of Connecticut. This retention period may be extended at the direction of the General Counsel or the Chief of Police or as required by law.

VI.7 Release of Recorded Material

Requests for release of recorded material must be approved by the Chief of Police. Requests for release of recorded material set forth in subpoenas or other legal documents compelling disclosure should be submitted to the General Counsel.

VII. Compliance

It shall be the responsibility of the Chief of Police to see that records related to the use of security cameras and recordings from security cameras are sufficient to demonstrate compliance with this policy. Units that maintain or support security camera technology must also maintain records and configure systems to ensure compliance with this policy. Before procuring security camera systems, units will need to ensure compatibility with the system identified as the campus standard by the Chief of Police.

The Chief Information Officer, or his or her designee, in conjunction with the Chief of Police, or his or her designee, may review the deployment and utilization of security cameras at the University, whenever and as frequently as they deem necessary. A finding that a school, department or office has failed to comply with the requirements of this policy may result in the loss of its privilege to support, maintain, or deploy security cameras and may result in other remedial action at the direction of the President or the President’s designee.

VIII. Exceptions

Uses of security cameras beyond those described in this security camera policy shall be governed by applicable University policies and procedures. Persons having questions about the use of monitoring cameras not subject to this policy should direct those questions to the Chief of Police or the General Counsel.

IX. REVIEW OF POLICY

This policy will be reviewed, and revised as necessary, by the Department of Public Safety, annually or more frequently as circumstances require.