3-8 Campus Security Camera System
Policy Type: Local
Responsible Office: Chief John Venuti, Virginia Commonwealth University Police Department
Review Date: 3/1/2017
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 an on-campus security and safety closed circuit television (CCTV) camera system. The surveillance of public areas is intended to deter crime and assist in protecting the safety and property of the VCU community. Given the volume of quality images being generated by the camera system, VCUPD has established protocols for sharing images with the public when doing so could be helpful to an investigation.
Most of the cases involving high-quality images have been solved without needing to enlist outside help, but should the situation arise under which the sharing of images can assist in solving a case, this policy will address VCU’s safety and security needs while respecting and preserving individual privacy. The purpose of this policy is to regulate the use of CCTV cameras to monitor and record public areas for the purposes of safety and security. This policy applies to all personnel, schools and centers of the University in the use of CCTV monitoring and recording.
All employees are expected to fully comply with the guidelines and timelines set forth in this written directive. Failure to comply will result in appropriate corrective action. Responsibility rests with the division commander to ensure that any violations of policy are investigated and appropriate training, counseling and/or disciplinary action is initiated.
- The VCUPD is committed to enhancing the quality of life of the campus community by integrating the best practices of public and private policing with state-of-the-art technology. A critical component of a comprehensive security plan using state-of-the-art technology is CCTV.
- The purpose of CCTV monitoring of public areas by public safety personnel is to deter crime and to assist the VCUPD in providing safety and protecting the property of the University community. Any diversion of security technologies and personnel for other purposes (i.e., CCTV monitoring of political or religious activities, or employee and/or student evaluations) would undermine the acceptability of these resources for critical safety goals and is therefore prohibited by this policy.
- Video monitoring for security purposes will be conducted in a professional, ethical and legal manner. Personnel involved in video monitoring will be appropriately trained and continuously supervised in the responsible use of this technology. Violations of the procedures for video monitoring referenced in this policy will result in disciplinary action consistent with the rules and regulations governing employees of the University.
- Information obtained through video monitoring will be used exclusively for safety, security and law enforcement purposes. Information obtained through video monitoring will only be released when authorized by the VCUPD according to the procedures established in this policy.
- Video monitoring of public areas for safety and security purposes will be conducted in a manner consistent with all existing University policies. The code of practice for video monitoring prohibits monitoring based on the characteristics and classifications of race, religion, gender, age, sexual orientation, national origin, disability, etc.
- Video monitoring of public areas for security purposes at the University is limited to uses that do not violate the reasonable expectation to privacy as defined by law.
- VCUPD is solely authorized to oversee and coordinate the use of CCTV monitoring for safety and security purposes at the University. All University areas using CCTV monitoring are responsible for implementing the following procedures in their respective operations. VCUPD will assist other units in implementing the policy and procedures.
- The Chief of Police has the responsibility to authorize all CCTV monitoring for safety and security purposes at the University. All CCTV installations will follow VCUPD operating principles.
- VCUPD will monitor new developments in the relevant law and in security industry practices to ensure that CCTV monitoring at the University is consistent with the highest standards and protections.
- The VCUPD Security Sergeant shall perform a documented monthly test of each CCTV camera to ensure that they are working properly. The following will be tested for each camera:
- Functionality in general
- Focus of picture
- Operation during the dark/night hours
- Operation during the light/day hours
- The Investigations Division will review all requests regarding the release or review of recorded video images obtained through CCTV monitoring. No release or review of recorded video images will occur without authorization by the Investigations Division or designee along with the Chief of Police. The VCUPD may also approve the release or review of recorded video images for legitimate purposes, such as to protect the University and its members from harm or liability. However, recorded video images directly related to criminal investigations, arrests or subpoenas may be exceptions to this standard.
- All VCUPD personnel involved in video monitoring of public areas will perform their duties consistent with this policy.
- The Investigations Division will assure that responsible and proper camera monitoring practices by control operators is continuous.
- VCUPD will limit camera positions and views of residential housing. Any view given to the housing will be no greater than what is available with unaided vision. Furthermore the view of a residential housing facility must not violate the legal standard of “reasonable expectation of privacy.”
- The VCUPD Emergency Communications Center and other monitoring centers will be configured to prevent camera operators from tampering with recorded video information.
- Recorded video will be stored for a period of no less than 7 days prior to an automatic purge within the system, 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. Because of the various types of CCTV technology, storage times will vary.
- Video recorded images will be tracked and stored in a secure location with access by authorized personnel only.
- Camera control operators will conduct video observation of areas only in plain view of others situated in the public area viewable to the public.
- Camera control operators will be trained in the technical, legal and ethical parameters of appropriate camera use. Camera control operators will receive a copy of this policy and provide written acknowledgement that they have read and understood its contents.
- Camera control operators will NOT monitor individuals based on characteristics of race, religion, gender, age, sexual orientation, national origin, disability or other classifications protected by policy. Camera control operators will monitor based on suspicious behavior, not individual characteristics.
- Camera control operators will NOT view private rooms or areas through windows where there is an expectation of privacy.
- Mobile video equipment and hidden surveillance cameras may be used in criminal and administrative investigations. Mobile video equipment will only be used in non-criminal investigations in specific instances creating significant risk to public safety, security, and property as authorized by the Chief of Police.
Examples of Video Monitoring and Recording of Public Areas
Legitimate safety and security purposes include, but are not limited to the following:
- Protection of buildings and property - Building perimeter, entrances and exits, lobbies and corridors, receiving docks, special storage areas, laboratories, cashier locations, etc.
- Monitoring of Access Control Systems - Restricted access transactions at entrances to buildings and other areas.
- Verification of security alarms - Intrusion alarms, exit door controls, hold-up alarms.
- Video Patrol of Public Areas - Transit stops, parking lots, public streets (enclosed and unenclosed), shopping areas and vehicle intersections, public gathering areas, campus functions, etc.
- Criminal Investigation - Robbery, burglary, and theft surveillance.
- Protection of pedestrians - Monitoring of pedestrian and vehicle traffic activity.
Dissemination of Images
- VCUPD has the authority to select, coordinate, operate, manage, and monitor all campus security surveillance systems pursuant to this policy.
- Information obtained from the cameras shall be used for safety, security and training purposes for law and policy enforcement. Information must be handled with an appropriate level of security to protect against unauthorized access, alteration, or disclosure.
- All appropriate measures will be taken to protect an individual’s right to privacy and hold University information securely through its creation, storage, transmission, use and deletion.
- In the event that the transmission of images is determined to be helpful in solving a crime, VCUPD shall employ a 4-tiered system of escalating intensity for transmitting images.
- Personnel interested in requesting images shall contact the Investigations Division sergeant. Under no circumstances shall VCUPD or University personnel transmit their own images or recordings without the approval of the Investigations Division sergeant, even if they have the capability to do so.
- NOTE: If an image or video can be utilized on scene to assist the responding officer in handling an incident, supervisors may authorize their use.
- Each situation will be evaluated on a case-by-case basis with input from the Investigations Division sergeant, Public Relations Specialist, Assistant Chief and/or Chief of Police.
- Images selected for transmission will be disseminated according to the following tiers:
- TIER 1 – Images distributed to law enforcement only, particularly VCU and Richmond Police Departments
- TIER 2 – Images related to minor offenses, transmitted to all VCUPD officers, Residential and Academic Security, and security/front desk staff in individual facilities (i.e. front desk staff at libraries or gyms)
- TIER 3 – Images related to serious offenses, as defined by emerging patterns, high value items, injury, brazenness or other factors, transmitted to personnel as described above as well as posted to the VCUPD website in a central location, VCUPD social media sites in an organized way, and screens in the gyms. If an arrest is made, the VCUPD website and social media sites will be updated to reflect the arrest and the notices will be removed from the screens.
- TIER 4 – Images related to felonies or other very serious crimes, transmitted to personnel as described above as well as the local media. This will be used only in the most serious of circumstances and with consultation with the director/assistant director of University Public Affairs.
- In the event that images are requested by members of the media, attorneys, private citizens, etc., requests shall be handled according to the Freedom of Information Act (FOIA) procedures set forth in Written Directive 2-8 Media and Public Information Requests.
- Personnel are prohibited from using or disseminating information acquired from security cameras except for official purposes. All information and/or observations made in the use of security camera are considered confidential and can be used only for official University and law enforcement purposes.