Purpose
Waldorf University 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 utilization of a security and safety camera systems. The surveillance of public areas is intended to deter crime and assist in protecting the safety and property of the Waldorf University community. This policy addresses the university’s 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. The University supports the use of video cameras on the campus as a means to monitor and maintain a safe campus for students, employees and guests.
Policy
Waldorf University Security as a unit in the Office of Student Life and in conjunction with Institutional Technology (IT), has the authority to select, coordinate, operate, manage, and monitor all campus security surveillance systems pursuant to this policy. All departments using camera surveillance are required to coordinate surveillance operations through the Office of Student Life/Security and IT and comply with this policy in their respective operations. IT and the Office of Student Life are responsible for advising departments on appropriate applications of surveillance technologies and for providing technical assistance to departments preparing proposals for the purchase and installation of security camera systems.
These offices shall monitor 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.
The university will review proposals and recommendations for camera installations and review specific camera locations to determine that the perimeter of view of fixed location cameras conforms to this policy. IT and the Office of Student Life will review any complaints regarding the utilization of surveillance camera systems and determine whether this policy is being followed.
The Office of Student Life will review all external requests to release records obtained through security camera surveillance. The university will seek consultation and advice from the General Counsel as needed related to these requests prior to the release of any records outside of the university. Video surveillance records will generally not be released to the public, students, general employee, and parent or law enforcement agency. The content of the video is a student and university record subject to administrative regulations regarding confidential student records. In most instances, only those persons with legitimate educational or security purpose may view video. Exceptions-the person or persons requesting to view video has a part in or serves a purpose in the investigation of a crime, code of conduct violation, significant campus safety concern or campus policy violation.
Scope
This policy applies to all personnel, departments of Waldorf University in the use of security cameras and their 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.
A. 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.
B. 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.
C. 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.
General Principles
Information obtained from the cameras shall be used exclusively for campus policy enforcement, including, where appropriate, student judicial functions or to assist local law enforcement and campus/local crime. 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.
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. 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:
- Bathrooms
- Student dormitory rooms in the residence halls
- Locker rooms
- Classrooms not used as a lab
The installation of “dummy” cameras that do not operate is allowed.
Unless being used for criminal investigations, all video camera installations should be visible.
The exact location, number and function of all cameras will generally be considered confidential for security purposes and not be released to the general public, guest or employee.
Access and Monitoring
All recording or monitoring of activities of individuals or groups by college security cameras will be conducted in a manner consistent with university policies, 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 college security cameras should be trained in the effective, legal, and ethical use of monitoring equipment.
University security cameras are not generally 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, maintenance purposes, functionality purposes and specific investigations authorized by the Dean of Students or designee.
When an incident is reported, the personnel responsible for the area in question may request the Office of Student Life to review the images from the camera. As circumstances require, the Dean of Students may authorize others to review images. A record log will be kept of all instances of access to, and use of, recorded material.
Appropriate Use and Confidentiality
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 college and law enforcement purposes upon the approval of the Dean of Students or designee. Personnel are expected to know and follow this policy.
Use of Cameras for Criminal Investigations
The use of mobile or hidden video equipment may be used in criminal investigations. Covert video equipment may also be used for criminal investigations of specific instances which may be a significant risk to public safety, security and property as authorized by the Dean of Students or designee.
Exceptions
This policy does not apply to cameras used for academic purposes. Cameras that are used for research, communications, class projects or Communication’s department organizations would be governed by other policies involving human subjects and are, therefore, excluded from this policy.
Safety and Security Camera Acceptable Use Policy
This policy does not address the use of student/employee personal cameras Webcams, video taping events, live streaming 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 would include videotaping of athletic events for post-game review, videotaping of concerts, plays, and lectures, live stream activity or videotaped interviews of persons. Automated teller machines (ATMs), which may utilize cameras, are also exempt from this policy.
Procedures
Departments requesting security cameras will be required to follow the procedures outlined in this policy.
Installation
Individual colleges, departments, programs, or campus organizations installing video surveillance equipment shall submit a written request to their appropriate dean or vice president describing the proposed location of surveillance devices, justifying the proposed installation, providing a cost estimate, and identifying the funding source or sources for purchase and ongoing maintenance. The budget committee or council will review the request and recommend it to the Office of Student Life and IT, if appropriate. These two groups will be responsible for reviewing and approving or denying all proposals for security camera equipment recommended by the Office of Student Life or other departments.
IT shall oversee the installation of all approved security camera systems with the assistance of the Office of Student Life and Facilities, as required.
Training
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 acknowledgment that they have read and understood its contents.
Operation
Video surveillance will be conducted in a manner consistent with all existing university policies. Camera control operators shall monitor based on suspicious behavior, not individual characteristics. Camera control operators shall not view private rooms or areas through windows. All operators and supervisors involved in video surveillance will perform their duties in accordance with this policy. Abuse of standard operation policies or inappropriate camera control operations will result in disciplinary action.
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.
All surveillance records shall be stored in a secure location for a period of 14 days and will then promptly be erased or written over, unless retained as part of a criminal investigation or court proceedings (criminal or civil), or other bona fide use as approved by the Dean of Students. Individual departments shall not store video surveillance recordings.
A log shall be maintained of all instances of access to or use of surveillance records. The log shall include the date and identification of the person or persons to whom access was granted.