SEC-034: Use of University Networked Cameras that View University Assets and Public Spaces

In order to provide a safe and secure environment while respecting individual privacy rights in accordance with University standards and state and federal laws, the University has established a process for the installation of all networked cameras that view University assets and public spaces in University facilities and on University property; and the handling, viewing, retention, dissemination, and destruction of records in accordance with the regulations of the Virginia Public Records Act 42.1-76 et seq. of the Code of Virginia.

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.

1. Authorization and Installation:
   University department/schools, organizations, vendors and contractor’s requests for authorization will include the proposed location of cameras that view University facilities or public spaces, justification of the proposed installation, and identification of funding source(s) for purchase and on-going maintenance of cameras. The University Police Department (UPD) and the department/school will execute a Memorandum of Understanding for all camera installations..

   University department/schools, organizations, vendors or contractors complete the Camera Installation Request Form and submit it to UPD requesting an assessment of the proposed installation. The Camera Installation Request Form will be reviewed by the Camera Oversight Group. The group will either approve or deny the request. Cameras in retail or other environments intended to primarily prevent theft or preserve assets or for purposes other than public safety may require an alternative funding source for installation.

   Upon approval by the Camera Oversight Group, UPD will coordinate with the department/school and oversee all activities associated with completing the request. Information Technology Services (ITS) will assist with securing and surveying network access.

   If the Camera Oversight Group denies the request, the requesting department/school, program, contractor or University organization may seek approval of their department/school vice-president/dean or chief executive officer who may decide installation is critical to their operation. If this is the case, they may go forward with the following requirements:

   The installation of "dummy" cameras that do not operate is prohibited

   Removal of cameras without authorization of UPD and the Camera Oversight Groups is prohibited.

   1. The camera must connect to the University’s centralized video management system and must fulfill current University standards for the equipment and equipment maintenance.

   2. Purchase, installation, and maintenance shall be the sole responsibility of the department, school, program, or University organization.

   3. The department, school, program, University organization or University contractor will be required to maintain the camera in working order including funding any repairs or replacement necessary. All repairs or replacement shall be completed in a timely manner after notification that the camera is non-functioning or requires maintenance.

2. Placement of Cameras:
   Camera assessments will be completed by UPD to identify threats, security vulnerabilities, and other needs. Cameras will not normally be installed in areas where there is a reasonable expectation of privacy including, but not limited to: restrooms, private student resident hall rooms, medical patient rooms, and locker rooms.

   All public notifications that reference camera installation will be maintained and disseminated at the discretion of UPD.

3. Access and Camera Monitoring:
   Not all University cameras are monitored continuously under normal operating conditions but may be monitored by UPD for legitimate safety and security purposes that include, but are not limited to: monitoring restricted access areas/locations, monitoring traffic for special events, conducting criminal investigations, and enhancing response of public safety agencies such as police, fire, and emergency medical services.

   Access to live or recorded video from cameras shall be limited to authorized personnel approved by UPD who may include consultation with the Camera Oversight Group.

   The UPD Monitoring Station Supervisor or designee will review all requests, including those pre-approved, regarding the release or review of recorded video. Release or review of recorded video images will not occur without authorization by UPD. Release or withholding of such records shall be in accordance with the law, and when appropriate, consultation with University Counsel.

4. Appropriate Use and Confidentiality:

   1. Personnel are prohibited from using or disseminating information acquired from University cameras, except for official purposes. All information and observations made in the use of cameras are considered controlled data and can only be used for authorized University and law enforcement purposes, or as otherwise required by law. University Counsel will have access to the recordings as needed and/or requested.

      Sharing of user credentials and passwords for camera access is strictly prohibited.

   2. The camera system may not be used to unlawfully harass, intimidate, or discriminate against any individual or group.

   3. Camera recordings may not be used in the course of personnel policy infractions unless approved by the Vice President & Chief Human Resources Officer (or designee).

   4. The use of camera recordings for any purpose not detailed within this policy is subject to review by UPD who may consult with University Counsel.

5. Training:
   UPD Camera Control Operators will receive regular training in the technological, legal, and ethical parameters of appropriate camera use.

   All other individuals that have been granted camera access shall receive a copy of this policy and provide written acknowledgement that they have read and understand its contents.

6. Storage, Retention, Disposal of Recordings and Maintenance:

   1. Storage, retention, and disposal of recordings will follow the regulations of the Virginia Public Records Act 42.1-76 et seq. of the Code of Virginia.

   2. Recorded video will be stored for a period of no less than seven (7) days. When retained as part of a criminal investigation or court proceeding (criminal or civil), or other bona fide use as approved by the Chief of Police or designee and the University Records Officer, retention may be longer. (If additional storage time of recorded video is approved for other bona fide use, the department may be required to bear the cost the additional storage.)

7. Exemptions:
   This policy does not apply to stand-alone cameras which are principally used for purposes other than safety and security functions such as video recording classroom lectures, athletic events, broadcasts or for post-game review; concerts; plays; or research experiments.

8. Responsibilities:

   1. The Office of Safety and Emergency Preparedness (OSEP) is responsible for:

      • Convening the Camera Oversight Group as necessary;

      • On-going enterprise assessments and camera placements in conjunction with UPD;

      • Improving security and access across Grounds; and

      • Collaborating with department/schools to implement camera security recommendations.

   2. The University Police Department is responsible for:

      • Selecting, coordinating, operating, managing, and monitoring all University cameras pursuant to this policy;

      • Assessing new camera locations in coordination with OSEP, ITS, the Office of the Architect, and Office of Facilities Management;

      • Conducting an evaluation of existing camera locations as required/needed with OSEP; and

      • Maintaining and testing of the video management system and, with OSEP, reviewing any complaints regarding the utilization of cameras and adherence to the policy. (Appeals of a decision made by the Chief of University Police will be made to and reviewed by the Executive Vice President & Chief Operating Officer.)

   3. Information Technology Services is responsible for:

      • Assessing new camera locations in coordination with UPD and OSEP;

      • Maintaining a separate virtual network for the video management system; and

      • Enabling networking for camera locations as needed.

   4. Office of the Architect is responsible for:

      • Assessing new camera locations in coordination with UPD and OSEP; and

      • Assisting in installation of cameras as needed.

   5. Departments Using the Video Management System are responsible for:

      • Implementing and complying with this policy; and

      • Maintaining installed cameras in coordination with UPD and ITS, if applicable.

   6. University Faculty and Staff and Medical Center Employees are responsible for:

      • Reporting any person who tampers with or destroys video cameras or equipment to the University Police Department.

   7. Office of Facilities Management is responsible for:

      • Assessing new camera locations in coordination with UPD and OSEP;

      • Assisting in installation of cameras as needed; and

      • Facilitating compliance of this policy with subcontractors.

9. Compliance with Policy:
   Failure to comply with the requirements of this policy may result in disciplinary action up to and including termination and expulsion in accordance with relevant University policies.

   Anyone who tampers with or destroys video cameras or equipment (including hacking intercepting, interrupting or interfering with service) will be subject to criminal prosecution and University action, as applicable.

   Questions about this policy should be directed to the Contact Office(s).