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Policies & Procedures Table of Contents

Miscellaneous

Campus Safety and Security Video Surveillance and Monitoring Policy - 6F3

I. INDEX

  1. Purpose
  2. Scope
  3. Use of Video Surveillance Equipment
  4. Approval Process
  5. Advisory Committee
  6. Notification of Employees and Bargaining Units
  7. Monitoring and Recording Evidence
  8. Training
  9. Collection and Storage of Information
  10. Compliance with Laws
  11. Violations and Sanctions
  12. Acknowledgements

II. GENERAL POLICY

  1. Purpose

    In combination with other crime prevention and community policing initiatives, widespread public awareness of the presence of video surveillance cameras in campus public spaces may serve as a potential deterrent to some criminal behavior. Therefore, the University has established a public safety strategy that incorporates the judicious use of video surveillance technology in public spaces. Such technologies will be used to meet the University's desire to protect persons and property, while avoiding unnecessary intrusions upon academic freedom or individual civil liberties including privacy, freedom of expression and freedom of assembly.

    Video surveillance devices are not a guarantee for a person's individual safety or protection. However, video surveillance does serve as a useful and timely investigative aid in regard to criminal acts or omissions. Relevant and useful evidence may be obtained in order to investigate and solve a crime.

    This policy establishes guidelines for Southern Illinois University Edwardsville (University) in regard to the installation and operation of video surveillance systems.
  2. Scope

    This policy applies to all property that is under the ownership or control of the University and regulates the actions of University personnel who are responsible for installing, recording or monitoring video surveillance equipment and systems. This includes video surveillance technology installed during either the course of capital construction or as an independent project.

    This policy does not apply to video recording devices that are used for educational purposes by faculty, staff or students in accordance with an academic course, research or training program, such as video recording devices used for mass communication classes or secure testing activities specifically equipped for such a purpose. This policy is not intended to prohibit the use of video recording devices used to record campus life activities such as sporting events, campus club events, or other University-sponsored events.

    Audio recordings are not authorized under this policy.
  3. Use of Video Surveillance Equipment

    1. In the interest of safety and security, the University may monitor areas under the ownership or control of the University through the use of video surveillance equipment in order to promote, maintain and enhance the safety and security of its faculty, staff, students, visitors and property. This may include the installation of video surveillance devices or other video recording equipment upon any property owned or controlled by the University, the monitoring of information obtained or collected from such devices (either in real time or recorded), and the recording of such information.
    2. Video monitoring for security purposes will be consistent with all existing University policies, including but not limited to the SIUE Non-Discrimination Policy, the SIUE Sexual Harassment Policy, the SIUE Police Department policies and general orders, the SIUE Emergency Management Plan, and other applicable state or federal laws, regulations or judicial orders.
    3. Video monitoring will not be used in the evaluation of employee performance, to monitor employment-related duties or functions or as evidence for reprimand, discipline or arbitration purposes. However, if video surveillance reveals a criminal act or criminal offense committed by an employee, such information may be used for law-enforcement or disciplinary purposes.
    4. SIUE respects the privacy of University community members. Any video surveillance or monitoring conducted upon University property pursuant to this policy shall occur in public areas. Public areas include, but are not limited to, parking lots, bus stops, sidewalks, bike paths, building entrances and lobbies, staircases and stairwells, hallways and corridors, ATMs and point of sale/monetary transaction areas. Private areas such as the following shall not be subject to video surveillance: residence hall rooms, bathrooms, shower areas, lockers and changing rooms, areas where a reasonable person might change clothes, and private offices such as faculty offices. Additionally, rooms for medical, physical, or mental therapy or treatment are private.

      Where video cameras are permitted in other non-public areas, they will to the maximum extent possible be used narrowly to protect money, real or personal property, documents, supplies, equipment, or pharmaceuticals from theft, destruction, or tampering.

      At all times, the University shall adhere to all applicable state or federal privacy laws.
    5. Signs shall be conspicuously displayed in all areas under video surveillance. The minimum text for these signs must state, "This area is subject to video surveillance and may or may not be monitored."
  4. Approval Process

    1. Units wishing to install new, temporary or replacement video surveillance systems must obtain prior approval.
    2. The Chancellor hereby delegates to each respective vice chancellor or vice chancellor's designee the responsibility of authorizing the use of video surveillance in his/her respective unit, and with assigning appropriate personnel to record and review the information obtained from video surveillance as required by the operational needs and security of the unit.
    3. The Vice Chancellor for Administration will be responsible for the oversight of the security devices and associated policies including:

      1. Authorizing placement of all cameras and associated signage;
      2. Authorizing the purchase of any new camera systems and associated signage;
      3. Reviewing existing security camera systems and installations and associated signage;
      4. Insuring that all security installations are in compliance with this policy; and
      5. Creating and approving the procedures for use of security cameras.
    4. If the appropriate vice chancellor determines that video surveillance is necessary and appropriate in a particular area, such vice chancellor or their designee shall consult with the Vice Chancellor for Administration regarding the specific placement, installation and maintenance of video surveillance equipment on University property.
    5. Prior to the submission of an official request for surveillance, the requestor shall consult with the Information Technology Services to determine if the proposed system or equipment is compatible with other University systems and/or technologies.
    6. Written requests for surveillance shall include:

      1. Name of designated campus authority and review/approval date;
      2. Name and contact information of the person requesting installation;
      3. List of operators (name or position) who will have access to the surveillance system and its images;
      4. Purpose and justification for the surveillance system consistent with the permitted uses under this policy;
      5. Explanation of how the surveillance images may be reviewed and/or used;
      6. Measures that have been taken to minimize the impact on personal privacy;
      7. Assertion that the planned installation and operation of the surveillance system shall comply with applicable laws and this policy;
      8. Nature of the physical space in which surveillance will occur and other activities likely to be captured by the system;
      9. Implementation details including physical location, field of view, capabilities of the camera, where and how long the images will be stored and retained;
      10. Cost of purchase, installation and maintenance as well as source of the funding;
      11. Manner in which affected units will be notified of the surveillance; and
      12. The locations and/or areas in which the signs will be posted.
    7. In addition, for requests to install video surveillance equipment in faculty workstations in Lovejoy Library or any classroom space at the University, such requests must be approved by the Chair (if applicable), Dean (if applicable) of the relevant academic unit, and the Provost and Vice Chancellor for Academic Affairs.
    8. Exceptions to the prior review and written approval requirements may be made in the event of an emergency or other situation reasonably appearing to pose an imminent threat to the safety and security of the University community and only in accordance with the procedures outlined in this policy. In such circumstances the Vice Chancellor for Administration or their designee, or campus Chief of Police or their designee, shall make all reasonable efforts to obtain verbal approval from the designated campus authority prior to deployment of the surveillance system, and obtain written approval within 5 working days.
  5. Advisory Committee

    1. An Advisory Committee will assist the Vice Chancellor for Administration in balancing the concerns related to the use of surveillance technology and the resulting recorded material to improve security on campus with the community members' interests in privacy, assembly and free speech.
    2. The Advisory Committee shall be comprised of the following:

      1. Vice Chancellor for Administration;
      2. Chief of Police or their designee;
      3. Chief Information Officer or their designee;
      4. Faculty Senate appointee;
      5. Staff Senate appointee;
      6. Student Government appointee; and
      7. Director of Facilities or their designee.
    3. The Advisory Committee shall meet at least annually to review surveillance installations for appropriateness, verify consistent application of surveillance controls and review objection decisions.

      If the Advisory Committee finds that a surveillance installation (or some part thereof) is not in compliance with this policy, the Advisory Committee shall advise the Vice Chancellor for Administration of the need to correct the compliance issue.
    4. The Advisory Committee shall issue an annual report to each constituent group regarding the use of video surveillance monitoring.
  6. Notification of Employees and Bargaining Units

    1. The University, or specific unit where surveillance is proposed (if applicable), will notify the affected members of the campus community and applicable collective bargaining units, in writing, of the University's intent to install video surveillance equipment at a particular location and/or area upon University property no less than thirty (30) days prior to its operation, unless such intent is in response to criminal activity on campus or by state or federal directive.
    2. If required by state law, contract or judicial order, the University will negotiate the installation, use and monitoring of the video surveillance equipment that directly affects members of a particular bargaining unit recognized by a labor agreement. If lawfully required, the University shall post notices in designated locations to alert the campus community that the particular location is monitored by video surveillance.
    3. Conspicuous public signage must be displayed at all video surveillance locations, except at emergency or investigative locations. Surveillance installations may or may not be monitored continuously. Therefore units with active installations shall post signage stating, "This area is subject to video surveillance and may or may not be monitored."
    4. Individuals who want to object to the placement of surveillance equipment or believe the presence of surveillance equipment is in violation of this policy may file an objection with the Vice Chancellor for Administration. The Vice Chancellor for Administration shall rule on the objection within 20 working days. The decision of the Vice Chancellor for Administration on objections is final.
  7. Monitoring and Recording Evidence

    1. Any information collected through the use of video surveillance equipment is considered University property and/or records. The appropriate vice chancellor or their designee in each unit will be responsible for determining the specific personnel in the unit who will have access to video surveillance equipment and recordings.
    2. Upon notification of potential criminal or unauthorized activity in a particular location, the SIUE Police Department may review information obtained from the video surveillance equipment in conjunction with its investigation of such activity.
    3. Disclosure of information obtained from video surveillance to non-University officials or personnel will be subject to review by the SIUE Police Department and the SIU Office of General Counsel, and will be handled in accordance with any applicable state or federal laws or regulations.
    4. The SIUE Police Department may conduct and/or monitor temporary or permanent video surveillance upon any area that is open and accessible to the campus community with the approval of the Vice Chancellor for Administration and in accordance with state and federal privacy laws.
    5. This policy does not apply to covert surveillance utilized by the SIUE Police Department or other authorized law enforcement agency for criminal surveillance as governed by Illinois law.
    6. The University will take reasonable security precautions to prevent unauthorized access to, use or disclosure of data recorded by video surveillance systems.
    7. It is the responsibility of the applicable unit to remove any system access given to an individual at the time of separation from the University.
    8. The applicable unit is responsible for all costs associated with video surveillance.
  8. Training

    1. Operators must receive a copy of the standards of appropriate use, and must sign that they have read and understood its contents. Such standards prohibit the targeting of individuals based upon perceived individual characteristics or classifications such as race, gender, ethnicity, sexual orientation or disability.
    2. Surveillance equipment operators will:

      1. Receive training on technical, legal and ethical use of such equipment;
      2. Provide written acknowledgement that they have read and understand this policy;
      3. Perform their duties in accordance with this policy; and
      4. Access images only to the extent permitted by this policy.
    3. Operators are prohibited from:

      1. Monitoring individuals based on inappropriate characteristics such as race, gender, ethnicity, sexual orientation, or disability;
      2. Viewing the interior of residential rooms through windows, doors or other means;
      3. Duplicating images or permitting access to others of surveillance images except as specifically permitted by this policy; and
      4. Viewing, recording, accessing or otherwise using a surveillance system or surveillance images in any manner that is inconsistent with this policy and/or outside the scope of the usage approved by the designated campus authority.
  9. Collection and Storage of Information

    1. Video surveillance equipment has the ability to record, collect and store information, which then may be preserved as an official record or kept temporarily.
    2. Information not requested or utilized by the SIUE Police Department shall only be stored temporarily, as determined by the capabilities of the specific surveillance equipment purchased by the respective unit, and shall not be considered documents "maintained" by the University.
    3. Security camera recordings will be retained for a minimum period of 10 days. This retention period may be extended at the request of University legal counsel, the Chief of Police, or as required by law.
    4. Recordings from surveillance equipment may be preserved and retained longer than 10 days under specific circumstances. This retention may only occur:

      1. Upon receiving credible notification of a University or law enforcement investigation for alleged illegal activity;
      2. Upon receiving notice from the Office of General Counsel that such copying and storage is otherwise needed to comply with legal obligations to retain materials;
      3. Upon receiving authorization from the Chancellor or Vice Chancellor for Administration indicating that such retention reasonably appears necessary to protect University operations;
      4. Where there is a reasonable belief that the surveillance information may be related to illegal activity that has occurred, is occurring or is imminently about to occur; or
      5. Where the surveillance information has historical significance.
    5. Video surveillance recordings must be destroyed in a secure manner as soon as they are no longer needed for the purpose for which they were retained.
  10. Compliance with Laws

    The Vice Chancellor for Administration, or their designee, in consultation with in the University Police Department and the Office of General Counsel, will monitor new developments in the relevant law and in security industry practices to ensure that the manner in which the University utilizes video surveillance is consistent and compliant with the highest standards and protections, and any applicable laws.
  11. Violations and Sanctions

    Violations of any aspect of this policy may subject the violator to employment, civil or criminal action, as permitted by University policy, applicable collective bargaining agreement(s), and/or any applicable laws.
  12. Acknowledgements

    The following resources and agencies were utilized in the development of this policy: Cornell University Responsible Use of Video Surveillance Systems; Indiana University PS 02.1 Procedures: Administrative Electronic Surveillance; Oakland University Surveillance and Monitoring Technology; Owens Community College Safety and Security Department Video Monitoring Procedure; St. Francis Xavier University Video Surveillance Policy; SUNY College of Environmental Science and Forestry Video Surveillance Policy; University of Illinois Security Camera Policy; Western Carolina University Policy 101, Policy for Installation and Use of Video Camera for Non Academic Purposes.

 

Approved by Chancellor effective 4/19/23
This policy was issued on April 20, 2023, replacing the May 23, 2013 version.
Document Reference: 6F3
Origin: OC 4/24/13; OC 4/19/23

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