Video Surveillance and Monitoring Policy

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GENERAL POLICY

  1. Purpose

    In combination with other crime prevention and community policing initiatives, widespread public awareness of the presence of video surveillance cameras in campus public spaces may serve as a potential deterrent to some criminal behavior. Therefore, the University has established a public safety strategy that incorporates the judicious use of video surveillance technology in public spaces. Such technologies will be used to meet the University's desire to protect persons and property, while avoiding unnecessary intrusions upon academic freedom or individual civil liberties including privacy, freedom of expression and freedom of assembly.

    Video surveillance devices are not a guarantee for a person's individual safety or protection. However, video surveillance does serve as a useful and timely investigative aid in regard to criminal acts or omissions. Relevant and useful evidence may be obtained in order to investigate and solve a crime.

    This policy establishes guidelines for Southern Illinois University Carbondale (SIU) in regard to the installation and operation of video surveillance systems.

  2. Scope

    This policy applies to all property that is under the ownership or control of SIU and regulates the actions of SIU personnel who are responsible for installing, recording or monitoring video surveillance equipment and systems. This includes video surveillance technology installed during either the course of capital construction or as an independent project.

    This policy does not apply to video recording devices that are used for educational purposes by faculty, staff or students in accordance with an academic course, research or training program, such as video recording devices used for mass communication classes or secure testing activities specifically equipped for such a purpose. Video recording equipment used by the Department of Public Safety for evidentiary or investigative purposes is exempt from this policy. This policy is not intended to prohibit the use of video recording devices used to record campus life activities such as sporting events, campus club events, or other University-sponsored events.

    Audio recordings are not authorized under this policy. Audio or visual recordings not utilized for educational purposes are strictly prohibited. The utilization of personal camera or recording equipment is strictly prohibited.

  3. Use of Video Surveillance Equipment
    1. In the interest of safety and security, SIU may monitor areas under the ownership or control of SIU through the use of video surveillance equipment in order to promote, maintain and enhance the safety and security of its faculty, staff, students, visitors and property. This may include the installation of video surveillance devices or other video recording equipment upon any property owned or controlled by SIU, the monitoring of information obtained or collected from such devices (either in real time or recorded), and the recording of such information.
    2. Video monitoring for security purposes will be consistent with all existing University policies, including but not limited to the SIU Non-Discrimination Policy, the SIU Sexual Harassment Policy, the SIU Department of Public Safety policies and general orders, the SIU Emergency Management Plan, and other applicable state or federal laws, regulations or judicial orders.
    3. Video monitoring will not be used in the evaluation of employee performance, to monitor employment-related duties or functions or as evidence for reprimand, discipline or arbitration purposes. However, if video surveillance reveals a criminal act or criminal offense committed by an employee, such information may be used for law-enforcement or disciplinary purposes.
    4. SIU respects the privacy of University community members. Any video surveillance or monitoring conducted upon SIU property pursuant to this policy shall occur in public areas. Public areas include, but are not limited to, parking lots, bus stops, sidewalks, bike paths, building entrances and lobbies, staircases and stairwells, hallways and corridors, ATMs and point of sale/monetary transaction areas. Private areas such as the following shall not be subject to video surveillance: residence hall rooms, bathrooms, shower areas, lockers and changing rooms, areas where a reasonable person might change clothes, and private offices such as faculty offices. Additionally, rooms for medical, physical, or mental therapy or treatment are private.

      Where video cameras are permitted in other non-public areas, they will to the maximum extent possible be used narrowly to protect money, real or personal property, documents, supplies, equipment, or pharmaceuticals from theft, destruction, or tampering.

      At all times, SIU shall adhere to all applicable state or federal privacy laws.
    5. Signs shall be conspicuously displayed in all areas under video surveillance. The minimum text for these signs must state, "This area is subject to video surveillance and may or may not be monitored."

  4. Approval Process
    1. Units wishing to install new, temporary or replacement video surveillance systems must obtain prior approval.
    2. The Chancellor hereby delegates the Vice Chancellor of Administration and Finance (or designee) the responsibility of authorizing the use of video surveillance across campus, and with assigning appropriate personnel to record and review the information obtained from video surveillance as required by the operational needs and security of the unit.
    3. The Vice Chancellor for Administration and Finance (or designee) will be responsible for the oversight of the security devices and associated policies including:
      1. Authorizing placement of all cameras and associated signage;
      2. Authorizing the purchase of any new camera systems and associated signage;
      3. Reviewing existing security camera systems and installations and associated signage;
      4. Insuring that all security installations are in compliance with this policy; and
      5. Creating and approving the procedures for use of security cameras.
    4. If the Vice Chancellor for Administration and Finance (or designee) determines that video surveillance is necessary and appropriate in a particular area, the Vice Chancellor for Administration and Finance (or designee) shall consult with appropriate personnel in that area regarding specific placement, installation and maintenance of video surveillance equipment on University property.
    5. Written requests for surveillance shall include:
      1. Name of designated campus authority and review/approval date;
      2. Name and contact information of the person requesting installation;
      3. List of operators (name or position) who will have access to the surveillance system and its images;
      4. Purpose and justification for the surveillance system consistent with the permitted uses under this policy;
      5. Explanation of how the surveillance images may be reviewed and/or used;
      6. Measures that have been taken to minimize the impact on personal privacy;
      7. Assertion that the planned installation and operation of the surveillance system shall comply with applicable laws and this policy;
      8. Nature of the physical space in which surveillance will occur and other activities likely to be captured by the system;
      9. Implementation details including physical location, field of view, capabilities of the camera, where and how long the images will be stored and retained;
      10. Cost of purchase, installation and maintenance as well as source of the funding;
      11. Manner in which affected units will be notified of the surveillance; and
      12. The locations and/or areas in which the signs will be posted.
    6. Exceptions to the prior review and written approval requirements may be made in the event of an emergency or other situation reasonably appearing to pose an imminent threat to the safety and security of the University community and only in accordance with the procedures outlined in this policy. In such circumstances the Vice Chancellor for Administration and Finance (or  designee) or the Director of Public Safety (or  designee) shall make all reasonable efforts to obtain verbal approval from the designated campus authority prior to deployment of the surveillance system, and obtain written approval within five (5) working days.

  5. Notification of Employees and Bargaining Units
    1. The University, or specific unit where surveillance is proposed (if applicable), will notify the affected members of the campus community and applicable collective bargaining units, in writing, of the University's intent to install video surveillance equipment at a particular location and/or area upon University property no less than thirty (30) calendar days prior to its operation, unless such intent is in response to criminal activity on campus or by state or federal directive.
    2. If required by state law, contract or judicial order, the University will negotiate the installation, use and monitoring of the video surveillance equipment that directly affects members of a particular bargaining unit recognized by a labor agreement. If lawfully required, the University shall post notices in designated locations to alert the campus community that the particular location is monitored by video surveillance.
    3. Conspicuous public signage must be displayed at all video surveillance locations, except at emergency or investigative locations. Surveillance installations may or may not be monitored continuously. Therefore units with active installations shall post signage stating, "This area is subject to video surveillance and may or may not be monitored."

  6. Monitoring and Recording Evidence
    1. Any information collected through the use of video surveillance equipment is considered University property and/or records. The Vice Chancellor for Administration and Finance (or designee) will be responsible for determining the specific personnel in the unit who will have access to video surveillance equipment and recordings.
    2. Upon notification of potential criminal or unauthorized activity in a particular location, the Department of Public Safety may review information obtained from the video surveillance equipment in conjunction with its investigation of such activity. The Department of Public Safety will facilitate access to recorded images of possible crimes and incidents requiring law enforcement investigation.
    3. Disclosure of information obtained from video surveillance to non-University officials or personnel will be subject to review by the SIU Office of General Counsel, and will be handled in accordance with any applicable state or federal laws or regulations.
    4. The Department of Public Safety may conduct and/or monitor temporary or permanent video surveillance upon any area that is open and accessible to the campus community in accordance with state and federal privacy laws.
    5. This policy does not apply to covert surveillance utilized by the Department of Public Safety or other authorized law enforcement agency for criminal surveillance as governed by Illinois law.
    6. The University will take reasonable security precautions to prevent unauthorized access to, use or disclosure of data recorded by video surveillance systems.
    7. It is the responsibility of the applicable unit to remove any system access given to an individual at the time of separation from the University.
    8. The Vice Chancellor for Administration and Finance (or designee) will bear the cost of video surveillance across campus. In instances where specific units on campus expressly request video surveillance equipment, the requesting unit will bear the burden of the cost.

  7. Training
    1. Operators must receive a copy of the standards of appropriate use, and must sign that they have read and understood its contents. Such standards prohibit the targeting of individuals based upon perceived individual characteristics or classifications such as race, gender, ethnicity, sexual orientation or disability.
    2. Surveillance equipment operators will:
      1. Receive training on technical, legal and ethical use of such equipment;
      2. Provide written acknowledgement that they have read and understand this policy;
      3. Perform their duties in accordance with this policy; and
      4. Access images only to the extent permitted by this policy.
    3. Operators are prohibited from:
      1. Monitoring individuals based on inappropriate characteristics such as race, gender, ethnicity, sexual orientation, or disability;
      2. Viewing the interior of residential rooms through windows, doors or other means;
      3. Duplicating images or permitting access to others of surveillance images except as specifically permitted by this policy; and
      4. Viewing, recording, accessing or otherwise using a surveillance system or surveillance images in any manner that is inconsistent with this policy and/or outside the scope of the usage approved by the designated campus authority.

  8. Collection and Storage of Information
    1. Video surveillance equipment has the ability to record, collect and store information, which then may be preserved as an official record or kept temporarily.
    2. Information not requested or utilized by the Vice Chancellor for Administration and Finance (or designee) shall only be stored temporarily. Security camera recordings will be retained for a minimum period of thirty (30) calendar days. This retention period may be extended at the request of the Office of the General Counsel, the Vice Chancellor for Administration and Finance (or designee), or as otherwise required by law.
    3. Recordings from surveillance equipment may be preserved and retained longer than thirty (30) calendar days under specific circumstances. This retention may only occur:
      1. Upon receiving credible notification of a University or law enforcement investigation for alleged illegal activity;
      2. Upon receiving notice from the Office of General Counsel that such copying and storage is otherwise needed to comply with legal obligations to retain materials;
      3. Upon receiving authorization from the Chancellor or Vice Chancellor for Administration and Finance indicating that such retention reasonably appears necessary to protect University operations;
      4. Where there is a reasonable belief that the surveillance information may be related to illegal activity that has occurred, is occurring or is imminently about to occur; or
      5. Where the surveillance information has historical significance.
    4. Video surveillance recordings must be destroyed in a secure manner as soon as they are no longer needed for the purpose for which they were retained.

  9. Compliance with Laws

    The Vice Chancellor for Administration and Finance (or designee) in consultation with the Department of Public Safety, Facilities and Energy Management, and the Office of General Counsel, will monitor new developments in the relevant law and in security industry practices to ensure that the manner in which the University utilizes video surveillance is consistent and compliant with the highest standards and protections, and any applicable laws.

  10. Violations and Sanctions

    Violations of any aspect of this policy may subject the violator to discipline, up to and including termination and/or  civil or criminal action, as permitted by University policy, applicable collective bargaining agreement(s), and/or any applicable laws.

  11. Acknowledgements

    The following resources and agencies were utilized in the development of this policy: Southern Illinois University, Edwardsville Video Surveillance Policy; Cornell University Responsible Use of Video Surveillance Systems; Indiana University PS 02.1 Procedures: Administrative Electronic Surveillance; Oakland University Surveillance and Monitoring Technology; Owens Community College Safety and Security Department Video Monitoring Procedure; St. Francis Xavier University Video Surveillance Policy; SUNY College of Environmental Science and Forestry Video Surveillance Policy; University of Illinois Security Camera Policy; Western Carolina University Policy 101, Policy for Installation and Use of Video Camera for Non Academic Purposes.