Security Camera Policy

Purpose

 The purpose of this policy is to provide for and regulate the University’s use of security cameras on campus while respecting the privacy expectations of members of the University community. The primary purpose of utilizing security cameras in public areas is to deter crime and to enhance the safety and security of members of the University community and University property. The primary use of security cameras will be to record video images for use by campus security, law enforcement, and other University officials charged with investigating alleged violations of law or University policy.

The existence of this policy does not imply or guarantee that security cameras will be monitored in real time continuously or otherwise.

Definitions related to this Policy:

Private areas are areas in which a person has a reasonable expectation of privacy, including, but not limited to non-common areas of residence halls, residence hall corridors, bathrooms, shower areas, locker and changing rooms and other areas where a reasonable person might change clothes. Further, areas dedicated to medical, physical, or mental therapy or treatment shall be considered private areas for the purpose of this policy.

Public areas are areas not defined as Private areas, including but not limited to campus grounds, parking areas, building exteriors, loading docks, areas of ingress and egress, classrooms, lecture halls, study rooms, lobbies, theaters, libraries, dining halls, gymnasiums, recreation areas, and retail establishments.

Security camera means a camera used by the university for recording public areas for the purposes of enhancing public safety, monitoring restricted areas or equipment, discouraging theft and other criminal activities, and preventing, investigating, and resolving incidents. The most common security cameras rely on closed circuit television or CCTV.

Security camera monitoring means the real-time review or watching of security camera feeds.

Security camera recording means a digital or analog recording of the feed from a security camera.

Security camera system means any electronic service, software, or hardware directly supporting or deploying a security camera.

Policy

1. Responsibilities and Authority - The Director of Campus Safety is responsible for oversight of installation, maintenance, and utilization of security cameras and associated policies, standards, and procedures. This responsibility includes:
   1. Creation, maintenance, and review of a campus strategy for the procurement, deployment, and use of security cameras, including this and related policies;
   2. Designation of the standard campus security camera system or service;
   3. Authorizing the placement of all security cameras;
   4. Authorizing the purchase of any new security camera systems;
   5. Reviewing existing security camera systems and installations and identifying modifications required to bring them into compliance with this policy;
   6. Creating and approving campus standards for security cameras and their use; and
   7. Creating and approving procedures for the use of security cameras.The Director of Campus Safety will consult with the Vice President of Student Affairs prior to authorizing a security camera unless there is a critical emerging situation in which consultation would happen directly with the General Counsel or another member of the Senior leadership team.
2. Security Camera Placement and Use
   1. The University will not record or monitor sound. Audio recordings shall be prohibited unless permitted by law and specifically authorized by the General Counsel.
   2. Use of security cameras shall be limited to public areas.
   3. Security cameras will be used in a professional, ethical, and legal manner in accordance with University policy and local, state and federal laws and regulations.
   4. Campus Safety will limit camera positions and views of residential academic spaces to exterior spaces and cameras will not be situated to allow viewing of resident hall rooms through windows.
   5. The security camera recording equipment will be configured so as to prevent the tampering with or duplicating of information.
   6. Use of security cameras to record public areas for security purposes will be conducted in a manner consistent with existing University policies, including Non-Discrimination Policy, the Sexual Harassment Policy, Family Educational Rights & Privacy Act (FERPA), and other relevant policies.
3. Security Camera Monitoring and Review
   
   1. Campus Safety may monitor and review security camera feeds and recordings as needed to support investigations and to enhance public safety. It is not intended or expected that security cameras will be routinely monitored in real time.
   2. With the prior approval of the Director of Campus Safety or Vice President of Student Affairs, other University personnel may monitor and review security camera live feeds and recordings for purposes of public safety or investigation of a University policy violation.
4. Use of Recordings - Security camera recordings, with the approval of the Director of Campus Safety, shall be used for the purposes of enhancing public safety, discouraging theft and other criminal activities, and investigating incidents (including the release of recordings by Campus Safety to external law enforcement agencies). Recordings from cameras whose primary function is not security (such as classroom lecture capture) may, with the authorization of the Director of Campus Safety, be used for these purposes.
5. Protection and Retention of Security Camera Recordings - Video footage will be stored on servers accorded appropriate computer security with access by authorized personnel only. Security camera recordings are the property of Willamette University and will be retained in accordance with the records retention policies of the State of Oregon and University policy. This retention period may be extended at the direction of the General Counsel or the Director of Campus Safety or as required by law.
6. Release of Recorded Material - Requests for release of recorded material must be approved by the Director of Campus Safety. Requests for release of recorded material set forth in subpoenas or other legal documents compelling disclosure should be submitted to the General Counsel.
7. Compliance - It shall be the responsibility of the Director of Campus Safety to see that records related to the use of security cameras and recordings from security cameras are sufficient to demonstrate compliance with this policy. No department should obtain security camera systems without approval from the Director of Campus Safety.
   The Vice President of Student Affairs or their designee, in conjunction with the Director of Campus Safety, or their designee, may review the deployment and utilization of security cameras at the University, whenever and as frequently as they deem necessary. A finding that a department or individual has failed to comply with the requirements of this policy may result in the loss of its privilege to support, maintain, or deploy security cameras and may result in other remedial action.
8. Exceptions - Uses of security cameras beyond those described in this security camera policy shall be governed by applicable University policies and procedures. Persons having questions about the use of monitoring cameras not subject to this policy should direct those questions to the Director of Campus Safety or the General Counsel.