06.06.05 Security Camera and Video Surveillance Policy

Scope: This policy applies to all students, faculty, staff, and visitors while on the UAH campus or at off-campus locations controlled by UAH.

Uses of video surveillance technology in applications covered under University policies governing research with human subjects or animal subjects are excluded from this Policy.

Policy Statement: UAH is committed to providing a safe environment by integrating security best practices and policing with state of the art technology. A critical component of a comprehensive security plan is a security camera system - technology that can remotely monitor and record activity on campus.

The purpose of this Policy is to provide guidelines for the use of security cameras and video surveillance on UAH property in a way that enhances security, but also respects the expectation of reasonable privacy among members of the community.

The purpose of security camera monitoring is to deter crime and to protect the safety and property of the University community. Safety and security purposes include, but are not limited to:

• Protection of individuals, including students, faculty, staff and visitors;
• Protection of University-owned and/or operated property and buildings, including building perimeters, entrances and exits, lobbies and corridors, receiving docks, special storage areas, laboratories, and point-of-sale locations;
• Verification of alarms and use of access control systems;
• Patrol of common areas and areas accessible to the public, including transit stops, parking lots, public streets and pedestrian walks; and
• Investigation of criminal activity and serious disciplinary activity in accordance with this Policy.

Any use of security technologies for purposes other than the safety and security purposes contemplated by this Policy, except as outlined in Requirements (f) below, is prohibited.

Security camera monitoring will be conducted in a professional, ethical, and legal manner. Personnel involved in monitoring will be appropriately trained and supervised in the responsible use of this technology. Violations of procedures below may result in disciplinary action consistent with the rules and regulations governing employees and/or students of the University.

Monitoring will be conducted in a manner consistent with all existing University policies, including the non-discrimination policies, the Sexual Harassment Policy, and other relevant policies. Monitoring based solely on the characteristics and classifications contained in the non-discrimination policies (e.g., race, gender, sexual orientation, national origin, disability, etc.) is strictly prohibited.

Monitoring shall be limited to uses that do not violate the reasonable expectation to privacy. Students have a greater expectation of privacy in their personal residential rooms/suites and in the hallways of residential facilities. Therefore, monitoring for safety and security purposes will not be used in residential hallways unless the Chief of Police, in consultation with the Director of Housing and Residential Life, determines that a specific safety/security risk exists. Monitoring of residential rooms or suite common areas is not permitted under this Policy without authorization from all residents of the subject suite or room.

The existence of this Policy does not imply or guarantee that cameras will be constantly monitored in real time.

The University administration may amend this Policy at any time provided that notice is given to the University community by the posting of a revised Policy on the University website.

Only security camera and video surveillance equipment, applications, and monitoring specifications which are included in the University’s approved security camera standard (approved by Facilities and Operations) shall be applied to University-owned or occupied property. Appropriate standard operating procedures shall be applied to all security camera and video recording applications to ensure effective and ethical management of equipment and that the recorded information is appropriately maintained by authorized users. All security camera systems will comply with the following:

• All security camera equipment shall be compatible with and integrated into the University’s wider electronic security network to enable effective monitoring by the UAH Police Department (UAHPD).
• Stand-alone security cameras or other video surveillance systems shall not be permitted.
• Mobile or portable surveillance equipment may be used to enhance safety and security in situations where it is deemed necessary by UAHPD.
• The use of web-based cameras (web cams) for monitoring or surveillance is prohibited without special approval from the UAHPD Chief of Police or designee. Exemptions for web cams will only be temporary in nature and must have a specified beginning and end date for deployment not to exceed 120 days. Groups operating approved web cameras on campus must make any recorded video available to UAHPD upon request

Responsibilities:

1. The UAHPD and/or the Associate Vice President for Facilities and Operations (AVPFO) or designee has the responsibility to authorize all security camera monitoring and to oversee the use of security camera monitoring for the safety and security purposes of UAH.
2. All University areas using security camera monitoring are responsible for implementing this Policy, including the procedures contained of this Policy, in their respective units/departments.
3. The AVPFO shall appoint a security camera system administrator who in coordination with UAHPD is authorized to oversee and coordinate the use of video surveillance equipment at UAH.
4. Facilities and Operations, which includes UAHPD, has the primary responsibility for disseminating and implementing security-related policy, procedures, and specifications for video surveillance equipment and video management software.
5. All new and existing unit/department security camera and video surveillance installations will follow this Policy.
6. Units/departments wishing to install temporary web-based monitoring systems shall petition the UAHPD Chief of Police. The written petition should include the following information:
   1. A description of the safety or security issue warranting the installation of a video surveillance system;
   2. The number and proposed location of camera(s) to be installed;
   3. Whether the location of cameras involve the recording of activity by students, faculty, staff and/or the general public and to what extent;
   4. The names and titles of the individuals who will be responsible for monitoring the cameras;
   5. The frequency by which the recordings will be reviewed (e.g., real time, daily, randomly, when an alarm is sounded);
   6. The length of time recordings will be stored;
   7. The location where recordings will be stored; and
   8. Security plans for storage locations and equipment.

      UAHPD will consider the petition and make a decision of approval or denial of the temporary installation. UAHPD can propose and require an installation that is less or more extensive than described in the original unit/department petition. UAHPD will make the final decision regarding the appropriateness of an installation weighing the concerns of the unit/department making the requests and safety and security of the entire community and the privacy interests of those whose activity may be recorded. Appeals to the decision of the UAHPD Chief of Police shall be submitted to the AVPFO. The decision of the AVPFO shall be final.

7. UAHPD and/or the security camera system administrator may audit any unit/departmental temporary video surveillance operations, including recording storage retention and physical and electronic security protocols, for compliance with this Policy.
8. The Chief of Police, in consultation with the Office of Counsel, will review and respond to subpoenas from outside law enforcement to release recordings obtained through video surveillance monitoring. Requests for security camera recordings made in connection with internal investigations of University disciplinary matters will be forwarded to the UAHPD Chief of Police or designee. The Chief of Police or designee, in consultation with the Office of Counsel and/or other University administrators as appropriate, will make the final decision regarding the appropriateness of releasing the recordings, weighing the concerns of the disciplinary official/committee making the request against privacy interests and safety and security of the entire community.
9. No recorded image or digital image file is to be released to the media or any other party without the written approval of UAHPD, Office of Counsel, and University Advancement, and may be released only in accordance with applicable privacy laws and applicable University policies. No images or digital image files may be distributed to external law enforcement agencies except as part of an ongoing criminal investigation, missing person case, or as required under court-issued subpoena.

   Requirements:

10. All operators and supervisors involved in video surveillance will perform their duties in accordance with this Policy.
11. The UAHPD will limit camera positions and views of residential housing in compliance with this Policy.
12. Surveillance centers will be configured to prevent camera operators tampering with or duplicating recorded information.
13. Recordings may be retained for a period not to exceed 90 days unless retained as part of a criminal investigation or court proceedings or other bona fide use as approved by the Chief of Police. Excluded from this requirement are recordings of construction sites as allowed for in this Policy under Requirements (m).
14. Recordings and recording equipment will be maintained in a secure location with access by authorized personnel only.
15. Camera control operators who view recordings must do so in the presence of a supervisor to maintain the integrity of the recording.
16. Camera control operators will be trained in the technical, legal and ethical parameters of appropriate camera use. Camera control operators will receive a copy of this Policy and provide written acknowledgement that they have read and understood its contents.
17. Camera control operators will not monitor individuals based on characteristics of race, gender, ethnicity, sexual orientation, disability, or other classifications protected by the Campus's Non-Discrimination Policy and applicable federal and/or state statutes. Camera control operators will monitor based on suspicious behavior, not individual characteristics.
18. Camera control operators will not view private rooms or areas through windows.
19. Camera control operators will not spot and continuously view people becoming intimate in public areas.
20. Hidden cameras with recording equipment will only be used for criminal investigation by the UAHPD with the approval of the Chief of Police or designee.
21. Portable security cameras with recording equipment may be used for special events or other purposes where approved by the Chief of Police and where such use is consistent with this Policy and in the interest of public safety and security.
22. Video surveillance equipment may be utilized by Facilities and Operations for the purposes of monitoring and recording the progress of campus construction projects. Construction-related video may be retained for the duration of the project or longer if deemed necessary for warranty-or other construction-related issues, or for promotional purposes (e.g., time lapse construction images).
23. The UAH Office of Information Technology shall not provide campus network access for IP-based security cameras or related equipment for any reason unless the access request originates from the security camera system administrator or the Chief of Police or UAHPD.

Definitions:

1. Authorized User: A person authorized by the UAHPD Chief of Police (or designee) to operate security camera or video surveillance equipment or to supervise those who do, or who has access to security camera equipment and has successfully completed University-provided FERPA training and received training from UAHPD and/or the security camera system administrator in the proper operation of applicable security camera and video surveillance equipment, and who is familiar with this Policy and applicable privacy laws and regulations.
2. Camera Control Operator: An authorized user who has authority granted by UAHPD to view live camera images, view and play back recorded images, and/or remotely operate security camera focus, pan, tilt, and zoom functions.
3. Security Camera or Video Surveillance System: Any combination of cameras, lenses, video/digital recorders and/or accessories installed for the purpose of monitoring and/or recording visual activity.
4. Security Camera Equipment: Any equipment that is intended for viewing, recording, playback, or exporting of security camera images, audio, or other data. This includes security cameras, network video recorders (NVRs), computer workstations with access to live or recorded video surveillance images, and any other equipment connected to or associated with the security camera system.
5. Security Camera System Administrator: An individual designated by the AVPFO to manage and maintain UAH security camera systems including but not limited to software maintenance, hardware maintenance, system design, equipment specifications, and construction design review and approval for security camera systems.

Related Documents:

• Student Handbook.
• Staff Handbook.
• Faculty Handbook.

1. Determining Requirement for Security Cameras
   1. Prior to selecting, installing, maintaining and operating security camera equipment on or near University premises, consultation with and prior approval from the UAH Police Department (UAHPD) must be obtained in order to ensure a maximum benefit is attained. Where security camera equipment is first being considered for the purposes of security in or near any University-controlled property, the UAHPD Chief of Police or designee and the security camera system administrator must be contacted for consultation and review of the application. This applies to any person or entity seeking to select, install, maintain, or operate security cameras or video surveillance equipment on or near University controlled premises.
   2. UAHPD and the Facilities and Operations designated security camera system administrator will work with groups to determine the most appropriate and effective security option and to ensure that all legal and organizational issues including equipment selection, network compatibility, and suitable monitoring and/or recording arrangements are handled in accordance with the University’s Security Camera and Video Surveillance Policy.
   3. All video surveillance solutions will be developed in coordination and consultation with UAHPD and the Facilities and Operations security camera system administrator throughout the development, installation, and implementation process.
2. Authorized Security Camera Users
   1. To ensure effective operation, ethical use and legal compliance of all UAH security camera applications, approval must be obtained from the UAH Police Department (UAHPD) before any staff member can become a security camera user/operator.
   2. Staff approved to operate security camera equipment must undertake training and induction on the physical operation of the system and use of the recorded information in compliance with legislative and regulatory requirements.
   3. UAHPD will compile and maintain a register of all security camera systems installed on campus or at University-controlled locations and operated and/or maintained by UAH personnel.
3. Security Camera Information Protocols
   1. Any information retrieved from security cameras on campus must be stored in a secure environment. Recorded images and digital image files remain the property of the University and are subject to the provisions of all applicable privacy and copyright laws.
   2. Viewing of recorded security camera images must only be carried out by authorized University staff.
   3. No recorded image or digital image file is to be released to the media or any other party without the written approval of UAHPD, Office of Counsel, and University Advancement, and may be released only in accordance with applicable privacy laws and applicable University policies. No images or digital image files may be distributed to external law enforcement agencies except as part of an ongoing criminal investigation, missing person case, or as required under court-issued subpoena.