Purpose
The University of West Alabama is committed to enhancing the quality of life of the campus community by integrating the best practices of safety and security with technology. A critical component of a comprehensive security plan is the proper utilization of a security and safety camera system. The surveillance of public areas is intended to deter crime and assist in protecting the safety and property of the UWA community. This policy addresses the University's desire to meet its safety and security needs while respecting and preserving individual privacy.
To ensure the protection of individual privacy rights in accordance with the University's core values and state and federal laws, this policy is adopted to formalize procedures for the installation of surveillance equipment and the handling, viewing, retention, dissemination, and destruction of surveillance records. The purpose of this policy is to regulate the use of camera systems used to observe and record public areas for the purposes of safety and security. The existence of this policy does not imply or guarantee that cameras will be monitored in real time 24 hours a day, seven days a week.
Scope
This policy applies to all personnel, departments, and colleges of UWA in the use of security cameras and video monitoring and recording systems. Security cameras may be installed in situations and places where the security and safety of either property or persons would be enhanced. Cameras will be limited to uses that do not violate the reasonable expectation of privacy as defined by law. Where appropriate, the cameras may be placed campus-wide, inside and outside buildings. Although the physical cameras may be identical, the functions of these cameras fall into three main categories:
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.
Personal Safety: Where the main intent is to capture video and store it on a remote device so that if a person is assaulted, the video may show the perpetrator. Examples: a public walkway, or a parking lot.
Extended Responsibility: Where the main intent is to have the live video stream in one area 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.
Information obtained from the cameras shall be used for safety and security purposes and for law and policy enforcement, including, where appropriate, student judicial functions. However, prudence should be exercised by parties requesting such information to ensure that requests are limited to matters of substantial consequence. The availability of surveillance does not remove the responsibility of supervisors to work to prevent, detect, and address issues as they should normally do. Information must be handled with an appropriate level of security to protect against unauthorized access, alteration, or disclosure.
All appropriate measures must be taken to protect an individual's right to privacy and hold university information securely through its creation, storage, transmission, use, and deletion.
All camera installations are subject to federal and state laws.
Departments requesting security cameras will be required to follow the procedures outlined in this policy.
Responsibilities
The University Surveillance Oversight Committee (SOC) is established by the President to oversee implementation of this policy, to revise the policy as needed, and to grant authorization to personnel to access video.
The University Police Department (UWAPD) will manage all campus security surveillance systems pursuant to this policy.
UWAPD and Information Technology (IT) are responsible for implementation of this policy, specifically for the following:
- Advising departments on appropriate applications of surveillance technologies and providing technical assistance to departments regarding security camera systems.
- Monitoring developments in the law and in security industry practices and technology to ensure that camera surveillance is consistent with the best practices and complies with all federal and state laws.
- Reviewing proposals and recommendations for camera installations and specific camera locations to determine that the perimeter of view of fixed location cameras conforms to this policy and forwarding recommendations to the SOC.
- Annually evaluating camera locations.
- Testing and maintaining the camera systems.
UWAPD will review any complaints regarding the use of surveillance camera systems and determine whether this policy is being followed. Appeals of a decision made by the Chief of Police will be reviewed by the SOC, which will make a recommendation to the President, who will render a final decision.
The SOC shall be responsible for reviewing and approving or denying all proposals for security camera equipment recommended by the Chief of Police and for approval of any requested exceptions to this policy. The SOC shall propose to the President appropriate changes to this policy as needed. Items approved by the SOC will be sent as a recommendation to the President, who will render a final decision.
The SOC shall be comprised of the Chief of Police, Provost, Vice President for Student Affairs, Director of Information Technology, the Director of Emergency Preparedness, a representative of the Physical Plant, and a student representative from the SGA. A Chairperson will be appointed from the membership.
The President or his or her designee will review all external requests to release records obtained through security camera surveillance and will seek consultation and advice from University Legal Counsel related to these requests prior to the release of any records.
Placement of Cameras
The locations where cameras are installed may be restricted access sites such as a departmental computer lab; however, these locations are not places where a person has a reasonable expectation of privacy. Cameras will be located so that personal privacy is maximized.
No audio shall be recorded except in areas where no one is routinely permitted. Requests to use audio surveillance that do not comply with this requirement will be evaluated on a case-by-case basis by the SOC.
Camera positions and views of residential housing shall be limited. The view of a residential housing facility must not violate the standard of a reasonable expectation of privacy.
Unless the camera is being used for criminal investigations, monitoring by security cameras in the following locations is prohibited:
- Student dormitory rooms in the residence halls
- Bathrooms
- Locker rooms
- Offices
- Classrooms not used as a lab.
The installation of "dummy" cameras that do not operate is prohibited.
Unless being used for criminal investigations, all video camera installations should be visible.
Access and Monitoring
All recording or monitoring of activities of individuals or groups by University security cameras will be conducted in a manner consistent with University policies and state and federal laws and will not be based on the subjects' personal characteristics, including age, color, disability, gender, national origin, race, religion, sexual orientation, or other protected characteristics. Furthermore, all recording or monitoring will be conducted in a professional, ethical, and legal manner. All personnel with access to University security cameras shall be trained in the effective, legal, and ethical use of monitoring equipment and shall receive a copy of this policy and provide written acknowledgement that they have read and understand its contents.
Access to live video or recorded video from cameras shall be limited to the UWAPD, designated IT personnel and other personnel as authorized by the SOC. The copying, duplicating and/or retransmission of live or recorded video shall be limited to persons authorized by the Chief of Police.
University security cameras are not monitored continuously under normal operating conditions but may be monitored for legitimate safety and security purposes that include, but are not limited to, the following: high risk areas, restricted access areas/locations, in response to an alarm, special events, and specific investigations authorized by the Chief of Police.
Personnel are prohibited from using or disseminating information acquired from University security cameras except for official purposes. All information and/or observations made in the use of security cameras are considered confidential and can only be used for official University and law enforcement purposes.
Any use of security cameras for reasons other than those cited in this policy is strictly prohibited. Violations of this policy or the procedures outlined therein will result in disciplinary actions consistent with the rules and regulations governing employees and students of the University.
Use of Cameras for Criminal Investigations
Mobile or hidden video equipment may be used in criminal investigations by the UWAPD. Covert video equipment may also be used for non-criminal investigations of specific instances that may be a significant risk to public safety, security and property as authorized by the Chief of Police.
Exceptions
This policy does not apply to cameras used for academic purposes. Cameras that are used for research are governed by other policies involving human subjects and are, therefore, excluded from this policy.
This policy does not address the use of webcams for general use by the University. 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 include videotaping of athletic events for post-game review, videotaping of concerts, plays, and lectures, or videotaped interviews of persons. Automated teller machines (ATMs) that use cameras are exempt from this policy.
Request for Video System Installation
Individual colleges, departments, programs, or campus organizations wishing to have video surveillance equipment installed shall submit a written request to the Provost or appropriate Vice President describing the proposed location of surveillance devices and justifying the proposed installation.
- The Provost or Vice President will review the request and recommend it to the Chief of Police, if appropriate, who will review the request and forward it to the SOC with a recommendation.
- The SOC shall be responsible for reviewing and approving or denying all proposals for security camera equipment recommended by the Chief of Police. Items approved by the SOC will be sent as a recommendation to the President, who will render a final decision.
- Information Technology, in conjunction with the Physical Plant, shall oversee the installation of all approved security camera systems with the assistance of the UWAPD.
Request for Access to Live and/or Recorded Video
Individual colleges, departments, programs, or campus organizations wishing to have access to live and/or recorded video shall submit a written request to the Provost or appropriate Vice President describing the requested access, with justification.
- The Provost or Vice President will review the request and recommend it to the Chief of Police, if appropriate, who will review the request and forward it to the SOC with a recommendation.
- The SOC shall be responsible for reviewing and approving or denying all access requests recommended by the Chief of Police. Items approved by the SOC will be sent as a recommendation to the President, who will render a final decision.
Training of Camera Operators
Camera control operators shall be trained in the technical, legal, and ethical parameters of appropriate camera use.
Camera control operators shall receive a copy of this policy and provide written acknowledgement that they have read and understand its contents.
Storage and Retention of Recordings
No attempt shall be made to alter any part of any surveillance recording. Surveillance centers and monitors will be configured to prevent camera operators from tampering with or duplicating recorded information.
Surveillance records shall not be stored by individual departments. All surveillance records shall be stored in a secure location for a period of 30 days and will then be erased or written over, unless retained as part of a criminal investigation or court proceedings (criminal or civil), including, where appropriate, student judicial functions, or other bona fide use as approved by the Chief of Police. Individual departments shall not store video surveillance recordings.
A log shall be maintained by the authorized individuals of all instances of access to or use of surveillance records. The log shall include the date/time of the use, camera(s) viewed, evidence found (or none) and any action taken related to the use. The Chief of Police will also maintain a list of personnel approved by the SOC to monitor live and/or recorded video feeds, with validation of each person's having completed the required training.
Revised September 4, 2014
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