Responsible Office: VCU Police, Division of Administration
Current Approved Version: 10/07/2020
Policy Type: Administrative
Policy Statement and Purpose
The purpose of this policy is to govern the use of campus security camera system that monitor and record public areas for safety and security purposes. This policy sets forth the procedures for requesting and implementing campus security camera equipment installation, and outlines the responsibilities for authorized access, dissemination, retention and disposition of these records.
VCU 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 campus security camera system. The surveillance of public areas is intended to deter crime and assist in protecting the safety and property of the VCU community. This policy addresses the university’s safety and security needs while respecting and preserving individual privacy.
Noncompliance with this policy may result in disciplinary action up to and including termination. VCU supports an environment free from retaliation. Retaliation against any employee who brings forth a good faith concern, asks a clarifying question, or participates in an investigation is prohibited.
Who Should Know This Policy
The VCU Police department, VCU Facilities Management Department (“FMD”), and Technology Support Services, Division of Administration, and any other university members who have authorized access the campus security camera system are responsible for knowing this policy and familiarizing themselves with its contents and provisions.
Closed Circuit Television (“CCTV”)
A television system in which the video signals are transmitted from one or more cameras to a restricted set of monitors.
A camera used for monitoring or recording public areas for the purposes of enhancing public safety, monitoring restricted areas or equipment, to discourage theft and other criminal activities, and for preventing, investigating, and resolving incidents.
Security camera monitoring
The real-time review or watching of security camera feeds.
Security camera recording
A digital or analog recording of the feed from a security camera.
Security camera systems
Any electronic service, software, or hardware directly supporting or deploying a security camera.
Pursuant to the policy Creating and Maintaining Policies and Procedures, the VCU Police department, in consultation with the vice president for administration, officially interprets this policy and shall revise or eliminate any or all parts as necessary to meet the changing needs of the university through the appropriate governance structures. Please direct policy questions to the VCU Police department.
Pursuant to this policy, the VCU Police Department and Technology Support Services have the authority to select, coordinate, operate, manage and monitor all campus security camera systems. Please note: Cameras are not monitored in real time 24 hours a day.
The VCU Police Department and Technology Support Services are responsible for monitoring developments in the law and in security industry practices and technology to ensure that camera surveillance is consistent with best practices and complies with applicable federal and state laws.
Technology Support Services and the VCU Police department will assess all requests for new campus security camera installation(s).
Technology Support Services is responsible for maintaining and testing the campus security camera system.
The VCU Police Department will review any complaints received regarding the utilization of the campus security camera system to determine whether a policy violation has occurred. Appeals of a decision made by the VCU Police Department will be made to and reviewed by the vice president for administration for decision.
Anyone who tampers with or destroys campus security camera equipment will be subject to criminal prosecution and/or campus judicial action.
2. Authorization & Installation
Once an individual (the requester) has determined that the proposed camera installation is for security purposes, the requester must obtain initial approval from their respective department dean or vice president, to include: the location of the proposed campus security camera equipment; the specific security related business purpose; and identify the source(s) of funding for purchase and continued maintenance of the proposed campus security camera equipment.
After initial approval is obtained, the requesting department, program, campus organization, or campus vendor must submit a Camera Request Form for the proposed camera installation to the VCU Police Department at firstname.lastname@example.org.
The VCU Police Department will coordinate with Technology Support Services to process the assessment request, and Technology Support Services will provide the requester with the assessment results and an estimate of required expenses, including hardware, storage requirements and continued maintenance. Technology Support Services will secure and survey network access.
Campus security camera assessments will be completed by the VCU Police Department, as requested, to identify potential threats and security vulnerabilities, the probability of occurrence or impact of an event, and security risk.
Upon receipt of the assessment results, the requester must forward the results and estimate of required expenses to their respective vice president, dean or designee for final approval.
Technology Support Services is responsible for advising departments on appropriate applications of campus camera technologies and for providing technical assistance to departments that are preparing proposals for the purchase of campus security camera equipment.
All new campus security cameras must connect to the university’s centralized surveillance system, and must adhere to current university standards for equipment and equipment maintenance.
The installation of inoperable “dummy” cameras is prohibited.
Installers must restore the fire protection rating of any exterior wall that is penetrated during the campus security camera installation process.
Security cameras will not be installed in areas in which there is a reasonable expectation of privacy, including, but not limited to, restrooms, student residence hall rooms, medical patient rooms, and locker rooms.
The VCU Police Department, in coordination with Technology Support Services, will restrict camera positions and views of residential housing, and ensure that any camera views positioned proximate to VCU housing facilities will be no greater than what is observable with unaided vision.
Unless being used for criminal investigations, all campus security camera equipment will be visible.
All customer notifications regarding campus security camera installation will be maintained and disseminated, as necessary, at the discretion of Technology Support Services. The notification will include the placement of cameras, viewing capabilities and the technology utilized.
3. Access and Monitoring
Not all campus security cameras are monitored continuously, but they may be monitored by the VCU Police Department for legitimate safety and security purposes, including, but not limited to, high-risk areas or restricted access areas/locations, in response to an alarm, special events, and for specific investigations.
For campus security cameras installed for protection of property and personal safety, access to live or recorded camera footage is restricted to authorized department personnel. In order to request access to the campus security camera system, users must submit a Camera Monitoring Access Request Form to the VCU Police Department at email@example.com. This form requires that the requester provide the justification for monitoring specific cameras and must be approved and signed by the respective vice president, dean or their designee.
The VCU Police Department will review all requests regarding the release or review of recorded images obtained through campus security camera monitoring.
The release or review of recorded images in response to a Virginia Freedom of Information Act request (Va. Code § 2.2-3700 et seq.) requires prior authorization from the VCU Police Department’s records manager. The release or review of recorded images for law-enforcement purposes requires prior authorization from the VCU Police Department’s investigations division or their designee and the chief of police. The release or withholding of such records must be made in accordance with applicable law, and in consultation with University Counsel, as needed.
4. Appropriate Use and Confidentiality
All information and/or observations made in the use of campus security cameras is considered confidential. Personnel are prohibited from using or disseminating information acquired from campus security cameras, except for official university and law enforcement purposes. Camera control operators will monitor cameras based on suspicious behavior, not individual characteristics, unless individual characteristics have been reported in the context of a criminal investigation and are relevant to such investigation.
The campus security camera system may not be used to unlawfully harass, intimidate or discriminate against any individual or group.
Security camera recordings may not be used in the course of personnel investigations, such as those related to, but not limited to, work place attendance or work quality, unless approved by the associate vice president for Human Resources or their designee. The use of campus security camera recordings for any purpose not described herein is subject to review by the VCU Police Department.
5. Storage, Retention, Disposal of Recordings and Maintenance
All recorded video will be stored, retained and disposed in accordance with the Virginia Public Records Act (see Va. Code § 42.1-76 et seq.).
All recorded video will be stored for a minimum of seven (7) days, unless retained as part of a criminal investigation or court proceedings (criminal or civil), or other bona fide use, as approved by the chief of police or their designee.
All recorded video will be tracked and stored in a secure location and can only be accessed by authorized personnel.
The VCU Police Department and Technology Support Services are responsible for coordinating the resolution of any maintenance issues with installed cameras.
a. This policy does not apply to the following:
1. Security cameras installed by authorized financial institutions to monitor bank branch locations and ATM machines.
2. Recordings from cameras whose primary function is not security related, such as public performances or events, interviews, research, or for broadcast or educational purposes. Examples of such excluded activities include: videotaping of classroom lecture(s), athletic events for post-game review, videotaping of concerts, plays and experiments, or videotaped interviews
3. Webcams used for general use by the university.