3-8 Campus Security Camera System

Policy Type: Administrative

Responsible Office: Virginia Commonwealth University Police Department, Division of Administration

Effective: 12/04/2015

Review Date: 08/08/2023

 

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 to the campus security camera system are responsible for knowing this policy and familiarizing themselves with its contents and provisions.

Definitions

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.

Security camera

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 viewing of security camera feeds.

Security camera recording

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

Security camera system

Any electronic service, software, or hardware that directly supports or deploys a security camera.

Contacts

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.

Procedures

1. Responsibility 

1. 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.

2. 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.

3. Technology Support Services and the VCU Police Department will assess all requests for new
   campus security camera installation(s).
4. Technology Support Services is responsible for maintaining and testing the campus security camera
   system.
5. 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.
6. Anyone who tampers with or destroys campus security camera equipment will be subject to criminal
   prosecution and/or campus judicial action.

2. Responsibility 

1. 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.
2. 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 cpcamrequest@vcu.edu.
3. 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, installation,
   storage requirements and continued maintenance. Technology Support Services will secure and
   survey network access.
4. 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.
5. Upon receipt of the assessment results, the requester must forward the results and estimate of
   required expenses to their respective assistant/associate vice president, dean or designee for final
   approval.
6. 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.
7. 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.
8. The installation of inoperable “dummy” cameras is prohibited.
9. Installers must restore the fire protection rating of any exterior wall that is penetrated during the
   campus security camera installation process.
10. 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.
11. 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.
12. Unless being used for criminal investigations, all campus security camera equipment will be visible.
13. 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

1. 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.
2. 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 cpcamrequest@vcu.edu. This form requires that
   the requester provide the justification for monitoring specific cameras and must be approved and
   signed by the respective vice president or dean.
3. The VCU Police Department will review all requests regarding the release or review of recorded
   images obtained through campus security camera monitoring.
4. 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 FOIA Officer. 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

1. 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.

2.  

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

3. 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.

4.  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

1. 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.).
2. 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.
3. All recorded video will be tracked and stored in a secure location and can only be accessed by
   authorized personnel.
4. The VCU Police Department and Technology Support Services are responsible for coordinating the
   resolution of any maintenance issues with installed cameras.

6. Exemptions

1. This policy does not apply to the following:

1. 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.
   4. Lawful individual use of cameras.

Forms

1. Camera Request Form
2. Camera Monitoring Access Request Form

 

Revision History

This policy supersedes the following archived policies:
12/04/2015                  Camera Use
10/07/2020                  Camera Use