Security Camera Acceptable Use Policy

Policies and Procedures
Security Camera Acceptable Use Policy

Security Camera Acceptable Use Policy

Information Technology

Approved: Senior Team
Date Established: Summer 2024
Responsible Office: Public Safety and Service; Library, Information, and Technology Services
Date Last Revised: –&�Բ��;
Responsible Administrator: Vice President of Student Life and Dean of Students, Vice President for Finance and Administration, Chief Information Officer

Statement

�鶹��ý��’s duty is to promote a safe environment for all community members while recognizing an individual’s right to be free from unreasonable invasion of privacy. This policy is intended to help the College balance those interests in regards to the use of security cameras on �鶹��ý�� property, primarily as a means of deterrence and investigation.

Scope/Responsibilities

This policy addresses the use of security cameras on �鶹��ý�� property. It seeks to balance the safety and security of the College community — including staff, faculty, students, vendors and visitors — with the reasonable privacy interests of all its members and guests, and is not intended to address the use of video equipment for academic, media or operational purposes.

This policy does not apply to the recording of public events, lectures and performances; the use of College-sponsored webcams; or other filming for purposes unrelated to property safety and security. Additionally, this policy does not apply to monitoring equipment installed in automated teller machines (ATMs) by sponsoring banks.

This policy does not address the use of recording equipment for educational, research or marketing/communications purposes by approved College personnel. Examples include the recording of research experiments or projects, lectures, interviews, concerts, athletic events, plays and other public performances. Such recording may be subject to other policies governing research with human subjects and academic, privacy and event-specific policies, as well as applicable federal, state and local laws.

The policy is intended to establish internal standards and procedures governing the use of security cameras on �鶹��ý�� property; it is not meant to create rights for any individual to seek redress for action in accordance with the policy. This policy, rather, seeks to enhance public safety and security, as well as the quality of life of the �鶹��ý�� community, in a professional and ethical manner, consistent with accepted legal rights to privacy.

The objectives of this security camera policy include:

Enhancing community safety
Preventing and deterring crime
Protecting the safety and property of the �鶹��ý�� community
Identifying suspects of policy violations and/or criminal activity
Aiding investigations of policy violations and/or criminal activity

Policy

Introduction

�鶹��ý�� is committed to enhancing the safety of the campus community by integrating best practices of safety and security with enhanced technology. The use of security cameras is a critical component of a comprehensive security and crime prevention program.

Policy Statement

�鶹��ý�� deploys security cameras (hereinafter also referred to as “cameras”) on its property to advance legitimate public safety and security interests, including, without limitation:

Protection of individuals, property and buildings
Investigation of criminal activity
Investigation of alleged misconduct and policy violations, whether or not rising to the level of a criminal offense
Monitoring of access control systems
Confirmation of security and safety alarms
Situational awareness of property happenings and events
Incident response

�鶹��ý�� students and employees are not permitted to install personal security cameras for surveillance purposes. Students should direct queries to the Vice President for Student Life or their designee; employees should contact the Department of Human Resources.

The use of security cameras is to be conducted at all times in a professional, ethical and legal manner in accordance with this policy and other relevant College policies, as well as with any applicable federal and state laws. Security camera recordings may be used as evidence for issues including, but not limited to, vandalism, trespassing, violations of the Student Code of Conduct, violations of the Employee Handbook and violations of federal law, etc. (this list is not exhaustive).

Video monitoring and recording for safety and security purposes will be conducted in a manner that respects the reasonable expectation of privacy among members of the Mount Holyoke community while balancing the College community’s interest in safety and security.

All video monitoring and recording will be conducted in a manner consistent with all existing College policies.

Monitoring based on the characteristics and classifications outlined in the College’s Non-Discrimination Policy (e.g., race, color, religion, sex, age, national origin, disability, pregnancy, sexual orientation, marital status, familial status, status as a victim of domestic violence, alienage or citizenship status, creed, genetic predisposition or carrier status, unemployment status or any other protected status or characteristic as established by law) is strictly prohibited.

The use of the camera system for investigations — including the monitoring, searching, playing back and downloading of still images and videos — relating to employee performance or conduct issues must be approved in advance by the Director of Public Safety and Service or their designee and the Associate Vice President for Human Resources or their designee.

The use of the camera system for investigations — including the monitoring, searching, playing back and downloading of still images and videos — relating to student conduct issues must be approved in advance by the Director of Public Safety and Service or their designee.

No audio recording will occur unless the person(s) being audiotaped have been explicitly informed that they are being audiotaped.

Definitions

These definitions apply to terms as they are used in this policy.

Security camera: A video camera device that is capable of capturing images (not audio) viewable by the naked eye and transferring such images to a data storage system through closed-circuit channels. Image capture may use a technological format. Cameras may be permanently mounted, temporarily placed, overtly or covertly displayed and operated from either remote locations or by automated devices.

Public area: An area of �鶹��ý�� property at which there is no reasonable expectation of privacy. This includes, but is not limited to, exterior locations on property, common areas of academic and administrative buildings, common areas of residential buildings and areas of surrounding streets. It does not include private rooms or suites in residential buildings, locker rooms or restrooms in any facility or private offices in administrative or academic buildings.

Private area: Areas such as private offices; student residence hall rooms; employee apartments and residential units; bathrooms; showers; locker rooms; changing rooms (or other areas where individuals might reasonably change clothing). Unless the use of a camera has been authorized for investigation purposes, monitoring by security cameras in private locations is generally prohibited. The only exceptions are cameras used to safeguard College money, documents or supplies from theft, destruction or tampering.

Video surveillance: The act of capturing motion picture images of a targeted area.

Monitoring: The viewing of live video images as they are happening.

Parking lot: All property owned, leased or operated by �鶹��ý��, divided into individual spaces designated by the Board of Trustees to provide space for motor vehicle parking. Primary parking lots are designated as any lot containing 50 or more spaces. Secondary parking lots contain 15-50 spaces. Tertiary parking lots are designated as lots containing fewer than 15 spaces or temporary overflow parking, such as the Morgan Street grass lot, which holds approximately 200 spaces.

Procedures

When security cameras are in use they shall be placed in public areas, except as specified in the definition of private areas, with viewing angles set to meet security and law enforcement requirements. Signage will be present wherever cameras are placed, unless an on-going investigation requires temporary placement of a camera for the purposes of the investigation. Except as otherwise provided herein, security cameras may not be established to view or monitor employee computer screens or workstations or other areas where there is a reasonable expectation of privacy, nor will cameras be directed or zoomed into the windows of any private residential buildings, including residence halls.

Responsibilities

A panel composed of representatives from Public Safety and Service (PSS); Library, Information, and Technology Services (LITS); Office of the Provost; and Human Resources, as well as a Dean of Students designee, shall review and approve or deny any requests for the installation of security camera systems covered by this policy. Panelists will be selected from those who serve on the IT/Data Governance Committee. The panel may field questions about this policy.

PSS and LITS will identify and designate personnel to:

Monitor requests for the installation and/or enhancement of security camera systems and maintain a record of the location and type of security cameras approved for installation.
Document requests to view footage in a master log maintained for that purpose. This log shall include the requester’s name, date of request, reason for the request, approximate date and time of the alleged incident, approver’s name and date of approval.
Document abuse and misuse of security camera monitoring systems and equipment.
Oversee the installation of security camera systems or manage any vendor who installs the systems.
Ensure compliance of security camera systems with applicable regulation.
Control and limit access to security camera data storage systems.
Create procedures for storage, disposal and retrieval of security camera content.
Conduct regular review/audit of camera footage to ensure quality control.
Provide training on appropriate use of security cameras.

Retention and Release of Information

Security camera data will be maintained for 32 days unless it must be preserved for longer periods pursuant to a lawful order, in connection with litigation or potential litigation, or as part of a College or governmental investigation or an agency or court proceeding (criminal or civil).

Security camera data may only be accessed by authorized PSS staff and designated LITS personnel. Security camera data may only be used by authorized PSS personnel. If the Director of Public Safety and Service or their designee(s) identify a legitimate institutional need, data may be shared with other authorized College personnel on a need-to-know basis only. Requests for the review or release of recordings to authorized College personnel should be directed to the Director of Public Safety and Service or their designee.

Camera data will be treated sensitively and as Restricted according to �鶹��ý��’s Data Classification policy. It will not be shared outside of the College except (a) with its authorized agents, e.g., attorneys, investigators or insurance providers, on a need-to-know basis; (b) subject to a lawfully issued subpoena or court order; or (c) as needed with law enforcement or other public officials in the case of an emergency situation involving threats to the life, health or safety of any person, or of theft or destruction of property. Notwithstanding the foregoing, the distribution of camera data through Clery Crime Alerts and equivalent warnings is permitted.

Policy Violations

Violations of College policies are adjudicated according to procedures outlined in the Student Handbook and the , with disciplinary consequences imposed by the adjudicating authority up to and including dismissal. Certain offenses are punishable under state and federal laws.

Exceptions

This policy does not apply to cameras used for academic purposes or security cameras installed in on-campus employee housing. Cameras used for research purposes are governed by other policies involving human subjects and are, therefore, excluded from this policy. Camera requests for on-campus employee housing still require approval through the Director of Public Safety and Service or their designee.

This policy does not address the use of webcams for general use by the College (e.g., on the official College website). In addition, this policy does not apply to the use of video equipment for the recording of public performances or events, interviews or other uses for broadcast or educational purposes. Examples of such excluded activities include the videotaping of athletic events for post-game review, the videotaping of concerts, plays and lectures or the videotaping of interviews. ATMs, which may utilize cameras, are exempt from this policy. Lastly, cameras used to safeguard College money, documents or supplies from theft, destruction, or tampering are also exempt.

Related Information

�鶹��ý�� Policies

Data Classification policy
Data Retention Schedule
Acceptable Use of Information Technology
Audiovisual Recordings in the Classroom (found in the Student Handbook)
Student Code of Conduct (found in the Student Handbook)
Image Release Policy (found in the Student Handbook)

References

Clery Act
Security breaches
Right of privacy
Taking or transmitting images of crime victims by first responders prohibited without consent
Interception of wire and oral communications
Photographing, videotaping or electronically surveilling partially nude or nude person or the sexual or other intimate parts of a person around the person’s clothing; exceptions; punishment

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