Franklin & Marshall College Franklin & Marshall College

Closed Circuit TV Camera Recording & Monitoring Policy

Purpose

The purpose of this policy is to regulate the use of closed circuit television (CCTV) cameras to monitor and record public areas for the purposes of safety and security.

Scope

This policy applies to all personnel of the College in the use of CCTV monitoring and recording.

Genera​l Principles

The Department of Public Safety 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 Closed Circuit Television (CCTV), which has been proven effective in reducing criminal activity.

The purpose of CCTV monitoring of public areas by public safety personnel is to deter crime and to assist the Department of Public Safety in protecting the safety and property of the college community. Any diversion of security technologies and personnel for other purposes 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. Video monitoring via the CCTV shall only be conducted by members of the Department of Public Safety or contracted security. ; Personnel involved in active video monitoring will be appropriately trained and continuously supervised in the responsible use of this technology. Violations of procedures for video monitoring referenced in this policy will result in disciplinary action consistent with the rules and regulations governing employees of the College.

Information obtained through video monitoring will be used for security and law enforcement purposes, and the Department of Public Safety will cooperate and assist local police as requested with criminal investigations. Information obtained through video monitoring will only be released when authorized by the Vice President for Administrative Services & External Affairs according to the procedures established in this policy.

Video monitoring of public areas for security purposes will be conducted in a manner consistent with all existing College policies, and other recognized policies. The code of practice for video monitoring prohibits monitoring based on the characteristics and classifications contained in the Non-Discrimination Policy (e.g., race, gender, sexual orientation, national origin, disability, etc.).

Video monitoring of public areas for security purposes at the College is limited to uses that do not violate the reasonable expectation to privacy as defined by law.

To maintain an informed college community, the Department of Public Safety will periodically disseminate written materials describing the purpose and location of active CCTV monitoring and the guidelines for its use. The location of outdoor CCTV cameras monitored by the Department of Public safety will be published in institutional publications.

Responsibilities

The Department of Public Safety is the department authorized to conduct, oversee and coordinate the use of CCTV monitoring for safety and security purposes at the College. Public Safety has primary responsibility for disseminating the policy and assisting other units in implementing the policy and procedures.

The Vice President for Administrative Services & External Affairs has the responsibility to authorize all CCTV monitoring for safety and security purposes at the College. All new installations will follow the Department of Public Safety operating principles. All existing and future actively monitored CCTV monitoring systems will be evaluated for compliance with this policy.

The Department of Public Safety will monitor new developments in the relevant laws to ensure that CCTV monitoring at the college is consistent with legal standards and protections.

CCTV Monitoring Committee, derived from members of the Public Safety Advisory Committee, will be established to assure that the Department of Public Safety adheres to established policy and procedure in the use of CCTV and to review camera locations and request for release of video information.

The CCTV Monitoring Committee will consist of at least four members.  The Chairperson of the Public Safety Advisory Committee or his/her designee will serve as chair.

  • One faculty member,
  • One staff member
  • One student member, and
  • One resident of College Neighborhood (resident may not be absentee landlord)

The CCTV Monitoring Committee will review camera locations to ensure the perimeter of view of fixed location cameras conforms to this policy.

The proposed location of permanent CCTV cameras will be provided to the CCTV Monitoring Committee for review and published in College publications prior to installation. A list of all College owned or controlled actively monitored camera locations will be published semi-annually in College publications and made available by the Department of Public Safety to anyone requesting the list.

The locations of temporary cameras to be used for special events will be reviewed by the CCTV Monitoring Committee for approval and published before the event if possible.

(Note: “Temporary cameras “ does not include mobile video equipment or hidden surveillance cameras used for criminal investigations.)

The CCTV Monitoring Committee will review complaints regarding camera locations and determine whether the CCTV Monitoring Policy is being followed. The Committee should weigh whether the potential increment in community security outweighs any likely infringement of individual privacy. The CCTV Monitoring Committee will also entertain all external community requests as above, to ensure policies are being followed.

The CCTV Monitoring Committee, with the Vice President for Administrative Services & External Affairs, will review all requests received by the Department of Public Safety to release recordings obtained through CCTV monitoring. No releases of CCTV recordings will occur without authorization by the Vice President and the CCTV Monitoring Committee. Excluded from review by the CCTV Monitoring Committee are releases of video directly related to a criminal investigation, arrest or subpoena. The CCTV Monitoring Committee may also approve release of video only for legitimate purposes. Any release of video will be recorded on a written log.

Any member of the CCTV Monitoring Committee may audit the Department of Public Safety’s CCTV monitoring operations, including videotape storage, at any time without prior notice.

Members of the community who have the possibility of being observed through the use of cameras may request to see live video of active monitoring; recorded video is not available for viewing. This request will be made to the Director of Public Safety, and when convenient to do so, should be granted. The viewing will not be permitted in the dispatch area but on the CCTV management computer within Public Safety.

The Chair of the CCTV Monitoring Committee will report to the Public Safety Advisory Committee at least two (2) times per year describing all requests for camera locations and release video and disposition of those requests.

The CCTV Monitoring Committee will review this policy annually and recommend revisions if needed.

Procedures

All operators and supervisors involved in video monitoring of public areas will perform their duties in accordance with the practices consistent with this policy developed by the Department of Public Safety.

Department of Public Safety’s management will assure that responsible and proper camera monitoring practices by control operators is continuous.

The Department of Public Safety will post signage at appropriate locations. Signage will state:

This area is subject to video monitoring by the
Franklin & Marshall College Department of Public Safety.

The Department of Public Safety will restrict views of residential housing interiors, both on and off campus. With the assistance of masking technology windows and/or doors that may allow a viewing or recording will be removed from sight. Only the Director and Associate Director of Public Safety will be authorized to make changes to the masking applied to the system, and then only when both are present to make the required changes.

The Department of Public Safety’s central monitoring area will be configured to prevent camera operators from tampering with or duplicating recorded information.

Recorded video will be stored for a period of at most 15-20 days, unless retained as part of a criminal investigation or court proceedings (criminal or civil), or other bona fide use as approved by the Vice President for Administrative Services & External Affairs and the CCTV Monitoring Committee.

Recorded video will be 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 receive training in cultural awareness.

Camera control operators will not monitor individuals based on characteristics of race, gender, ethnicity, sexual orientation, disability, or other classifications protected by the College’s Non-Discrimination Policy. Camera control operators will monitor based on suspicious behavior, not individual characteristics.

Camera control operators will not spot and continuously view people becoming intimate in public areas.

Although masking technology makes viewing restricted areas impossible, camera control operators will not view private rooms or areas through windows.

Mobile video equipment may be used in criminal 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 in writing by the Vice President for Finance and Administration to the Department of Public Safety.  Portable hidden cameras with recording equipment will only be used for criminal investigation by the College’s Department of Public Safety, with the approval of the Director of Public Safety.

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

  • Monitor and record 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, Shopping Areas and vehicle intersections, etc

Criminal Investigation

  • Robbery, burglary, and theft surveillance, etc.

Protection of Pedestrians

  • Monitoring of Pedestrian and Vehicle Traffic Activity

Policy Maintained by: Department of Public Safety, Director

Last Reviewed: 15 May 2013