Any diversion of security technologies for purposes other than specified herein would undermine the acceptability of these resources for critical safety goals and is, therefore, strictly prohibited.

The procedures herein provide guidelines for using video surveillance on College Premises to enhance security while respecting the reasonable expectation of privacy among the College Community.

Further, these procedures provide guidelines for installing, monitoring, storing, releasing, and destroying surveillance records.

Surveillance cameras may be installed in situations and places where the security of either people or property would be enhanced. The existence of this Procedure and any related cameras or equipment installed does not imply or guarantee that cameras will be monitored in real-time 24 hours a day, seven (7) days a week.

PRIVACY

All information obtained by or stored because of the system's use is considered confidential to the extent permitted by law. The College does not intend to monitor Employees' routine activities but to balance the rights of privacy with the need to provide a safe and secure environment.

Security cameras will not be used in locations with a reasonable expectation of privacy as defined in the law.

SCOPE

The provisions of this Procedure do not govern the following uses of video technology:

• Academic Use: This Procedure does not apply to legitimate academic use of video cameras for educational purposes.

• Law Enforcement Surveillance: This Procedure does not apply to cameras placed by or used in any way by any law enforcement agency for criminal surveillance.

Unrelated to Surveillance: This Procedure does not apply to video cameras or webcams established for reasons unrelated to surveillance activity, including remote monitoring of facilities construction to ascertain project progress, campus public relations initiatives, or videotaping of College Sanctioned Events for use in marketing.

VIDEO SURVEILLANCE INSTALLATION AND CAMERA PLACEMENT

The Director of Campus Safety, Security, and Risk Management shall oversee the placement of video surveillance technology and ensure that the perimeter of view of fixed-location cameras conforms to this Procedure.

In carrying out this responsibility, the Director of Campus Safety, Security, and Risk Management will also consider input and recommendations from the College Community on suggested camera locations.

The Director of Campus Safety, Security, and Risk Management shall be guided by the following rules governing the placement of video surveillance technology. Any exceptions to these rules must be approved by the Vice President of Finance and College Operations/CFO.

• Public Areas: Video surveillance shall be restricted to public areas and areas commonly used by the College Community.

• Private Areas: Video monitoring is limited to areas where individuals would not reasonably expect privacy.

• Posting of Notice: Signs shall be displayed prominently in public areas where video surveillance is being conducted, informing the public of the usage of video surveillance on College Premises.

  • Exterior Cameras: For exterior cameras, these signs will be posted in a conspicuous place near the video surveillance camera.

  • Interior Cameras: For interior cameras, video surveillance warning signs shall be placed at or near each entrance to the places that are being monitored.

• Placebo Cameras: The College will not ordinarily utilize inoperative, perfunctory, placebo, or “for looks-only” video surveillance equipment.

• Changes in Law or Security Practices: The Director of Campus Safety, Security, and Risk Management shall monitor developments in the law and security industry practices to ensure that camera placement and surveillance are consistent with the best practices and comply with all applicable Federal and State laws. The Director of Campus Safety, Security, and Risk Management shall review this Procedure periodically.

• Installation: Information Technology Services shall work with Campus Safety and Security to ensure proper installation and configuration of all approved surveillance equipment. The Office of Campus Safety and Security shall maintain and operate surveillance software and hardware, such as cameras.

• Objections to Camera Placement: Where complaints are made about the location of video surveillance cameras at the College, the following process shall be followed:

  • The Vice President of Finance and College Operations/CFO will review complaints regarding camera locations and determine whether this video surveillance policy is being followed.

  • Considering this determination, the Vice President of Finance and College Operations/CFO will recommend the President regarding the disposition of the complaint.

• Once a final decision regarding the complaint is reached, the complainant will be notified in writing.

• While not always possible, every attempt should be made to finalize decisions regarding complaints about video surveillance locations within 15 working days of receipt of the complaint.

MONITORING

Employees involved in video monitoring of public areas will perform their duties according to the practices outlined in this Procedure. Specifically, the following guidelines shall apply to the monitoring of video surveillance cameras at the College:

• Generally: Video surveillance monitoring of campus areas for security purposes will be conducted in a manner that is professional, ethical, legal, and consistent with all existing college policies.

• Unauthorized Access: The College will take reasonable security precautions to prevent unauthorized access to, use, or disclosure of data monitored or recorded by any college surveillance systems.

• Viewing Access: Access to video surveillance monitors will be limited. Specifically, the following guidelines shall apply in granting access to monitor the video surveillance cameras:

  • Authorized access to the “live view” of security cameras is limited to:

    • President/District Director

    • Vice President of Finance and College Operations/CFO

    • Director of Campus Safety, Security, and Risk Management

    • Evening Administrator and Security Supervisor

    • Security Officers with the approval of the Director of Campus Safety, Security, and Risk Management or the Evening Administrator/Security Supervisor

    • Designated Employees (e.g., Welcome Center – select cameras only)

    • Center Coordinators for their respective facility only

    • Facilities Director

    • System Administrators: Media Services Technicians

  • Authorized access to the “recorded view” of cameras is limited to:

    • President/District Director

    • Vice President of Finance and College Operations/CFO

    • Executive Director of Human Resources/CHRO

    • Executive Director of Student Services/CSSO

    • Director of Campus Safety, Security, and Risk Management

    • Evening Administrators and Security Supervisors

    • Security Officers with the approval of the Director of Campus Safety, Security, and Risk Management or the Evening Administrator/Security Supervisor

    • System Administrators: CIO/IT Supervisor/Media Services Technicians

  • Authorized access to the Server and system-wide settings:

    • System Administrators: Media Services, Network, and Server Technicians

• Requests for recorded information will be submitted in writing to the Director of Campus Safety, Security, and Risk Management. Requests must include the following information:

  • • Reason for review.

    • Date of occurrence.

    • Approximate time of occurrence.

    • Proximate location.

    • Name of individual/s (if known).

    • Other pertinent information that will assist in acquiring requested information/incident report.

    • Requestor’s contact information.

    • Signature of the requestor and printed name and title.

Requests must be made promptly to ensure footage retention. The Director of Campus Safety, Security, and Risk Management or designee will respond to the requestor within five (5) business days. If the request is approved, the video images will be provided digitally.

• Requests for exceptions to the guidelines listed above shall be made in writing to the Director of Campus Safety, Security, and Risk Management. The request shall identify the individual for whom access is sought, the area to be monitored, and the rationale for granting access. If the request is denied, an appeal can be made to the Vice President of Finance and College Operations/CFO.

• Training. All Employees involved in the supervision, application, use, or monitoring of video surveillance technology at the College will meet the following requirements:

• Be trained in the technical, legal, and ethical parameters of appropriate surveillance use.

• Receive a copy of the policy and provide written acknowledgment that they have read and understood its contents.

STORAGE

Digital recordings or other media will be stored, handled, and transported in a manner that preserves security. Further, recorded images unrelated to or used for an investigation shall be kept confidential and destroyed regularly. Accordingly, the following guidelines regarding the storage of video surveillance records shall be strictly adhered to:

• Location: Video surveillance records shall be stored in a secure location with limited access to authorized Employees.

• Timeframe: Generally, video surveillance records shall be stored for not less than 15 days and not more than 60 days unless retained as a part of a criminal investigation, court proceedings (criminal and civil), or other bona fide use, as approved by the Director of Campus Safety, Security, and Risk Management. Records will be maintained consistent with Wisconsin Public Records law requirements and the Family Educational Rights and Privacy Act. Records that are the subject of a request for release shall not be destroyed.

• Alterations: No attempt shall be made to alter any part of any surveillance recording. Surveillance centers will be configured to prevent tampering with or duplicating recorded information.

• Access Log: The Office of Campus Safety and Security shall maintain an access log for all access to or use of surveillance records. This log shall include the date, time, and identification of the person or persons to whom access was granted.

RELEASE OF INFORMATION

Information obtained through video monitoring will only be released when authorized by the Director of Campus Safety, Security, and Risk Management, according to these procedures,

and in compliance with the law. The following guidelines will govern the release of recordings obtained using video surveillance technology:

• Law Enforcement Purposes: Information obtained through video monitoring may be used for security and law enforcement purposes, and the College will cooperate and assist law enforcement as requested with criminal investigations. This includes but is not limited to providing copies of any recordings within the College’s possession.

• Commercial Use: Under no circumstances shall the contents of any captured video recordings be used for profit or commercial publication, nor shall such recordings be publicly distributed except as required by law.

• Recordings Involving Possible Crimes: Unless outlined in the paragraph above, recordings directly related to a criminal investigation, arrest, or subpoena will not be released to any party. Where requests for recordings are subpoenas or other legal documents, appropriate contact with the College’s legal counsel for guidance is required.

• Confidentiality Statement: The College’s authorized camera monitors shall take reasonable steps to protect the confidentiality of recorded information and to prevent the unauthorized release of recorded information.

DESTRUCTION OR TAMPERING WITH VIDEO SURVEILLANCE TECHNOLOGY

Any person who tampers with or destroys a video surveillance camera or any part of the video surveillance system will be subject to appropriate administrative or disciplinary action and possible referral to law enforcement for criminal charges.

DISCLAIMER

The College is not responsible for losing recorded video information due to system failure, error, power failure, IT Network failure, or any other causes.

DEFINITIONS

Video Surveillance – A technology that monitors remotely and records activity across College Premises.

Public Area – An area open for public use where the expectation of privacy is not violated by what could generally be openly observed, such as the campus grounds, an academic hallway, a classroom, a library, testing areas, or study rooms.

Private Area – Areas where an individual might change clothing, such as bathrooms, shower areas, lockers, and changing rooms. This would also typically include private office spaces; however, exceptions are appropriate in those areas where monetary transactions occur or where video surveillance is needed to safeguard money or supplies from theft, destruction, or tampering.

Video Surveillance Technology – Any item, system, camera, technology device, communications device, or process used alone or in conjunction with a network for gathering, monitoring, recording, or storing an image or images of College Premises and the College Community. Images captured by video surveillance technology may be real-time or preserved for review later. Video technology used by the College shall not be used to record sound.

Camera Monitors – Any Employee authorized to have live access to college-owned video surveillance cameras.