44.119:  Video Surveillance Systems

To ensure the protection of individual privacy rights in accordance with the law, this policy is adopted to formalize procedures for the installation of surveillance equipment and the handling, viewing, retention, dissemination, and destruction of surveillance records.

Video surveillance will be conducted in a professional, ethical, and legal manner. Any diversion of surveillance records for other purposes (e.g., surveillance of political or religious activities, or employee or student evaluations) is prohibited. Under no circumstances shall the contents of any captured audio or video recordings be exploited for purposes of profit or commercial publication, nor shall such recordings be publicly distributed except as may be required by law. Academic uses of video surveillance technologies may be covered by the Faculty Handbook or by other policies, but are not covered by this policy. The use of mobile or hidden video equipment by Ohio University Police for criminal investigations may be covered by other policies, but is not covered by this policy.

This policy does not address the use of Webcams for general use by the University (e.g., on the Official Ohio University Website). This policy also does not apply to the use of video equipment for the recording of public performances or events, interviews, or other use for broadcast or educational purposes. Examples of such excluded activities would include videotaping of athletic events for post game review, videotaping of concerts, plays, and lectures, or videotaped interviews of persons.

I.   Participants and Responsibilities

The Ohio University Police Department (OUPD) has exclusive authority to select, coordinate, operate, manage, maintain, and monitor campus security surveillance systems pursuant to this policy.

An institutional Surveillance Oversight Committee (SOC) is established to oversee implementation of this policy.

A.   Responsibilities of the OUPD

OUPD is responsible for implementing and monitoring this policy.

OUPD is responsible for disseminating this policy on campus, for advising departments on appropriate applications of surveillance technologies, and for assisting departments in preparing proposals for the funding and installation of surveillance equipment.

OUPD shall monitor developments in the law and in security industry practices to ensure that camera surveillance is consistent with the best practices and complies with all Federal and State laws.

OUPD shall review proposals and recommendations for camera installations, and shall also review specific camera locations to ensure that the perimeter of view of fixed location cameras conforms to this policy.

The proposed location of permanent CCTV or Web cameras shall be reviewed by the Chief of Police or his or her designee for recommendation to the SOC. The locations of temporary cameras to be used for special events shall also be reviewed by the Chief of Police or his or her designee.

Students and staff entering certain sensitive locations on campus may have an increased concern for privacy or confidentiality. In order to prevent a possible chilling effect at these locations, concerned persons may petition the Chief of Police or his or her designee and if necessary the SOC to forgo the installation of a proposed camera or for the removal of an existing camera. The Chief of Police or his or her designee will determine the appropriateness of an installation, weighing the concerns of the person or persons making the requests and the safety and security of the entire community. In recognizing that students may also have an enhanced expectation of privacy in the hallways and lounges of residence facilities, CCTV or Webcam surveillance for safety and security purposes will not be used in residential hallways and lounges unless the Chief of Police or his or her designee determines that a specific safety or security risk exists.

OUPD will review complaints regarding camera locations and determine whether this CCTV or Web camera surveillance policy is being followed. The Chief of Police or his or her designee will determine whether the potential increment in community security outweighs any likely infringement of individual privacy. Appeals of a decision by the Chief of Police or his or her designee will be reviewed by the SOC which will make a recommendation to the Vice President for Finance and Administration for final disposition.

B.   Responsibilities of the SOC

The SOC will review all proposals for equipment installation recommended by the Chief of Police or his or her designee and in turn make recommendations to the Vice President for Finance and Administration for funding of new or replacement equipment.

The SOC will review appeals of decisions made by the Chief of Police or his or her designee pursuant to this policy and procedure and make recommendations to the Vice President for Finance and Administration.

The SOC shall propose to the Vice President for Finance and Administration appropriate changes to this policy and procedure.

The Vice President for Finance and Administration shall be responsible to make decisions related to: changes to this policy and procedure, funding for equipment and ongoing maintenance, and recommendations of the SOC to resolve appeals to decisions of the Chief of Police.

The General Counsel will review all requests to release recordings obtained through CCTV or Webcam surveillance. No CCTV or Webcam recordings shall be released without authorization from the General Counsel.

C.   SOC Composition

The SOC shall be composed of nine members, appointed as indicated here:

• The Ohio University Chief of Police or his or her designee, Chair of the SOC
• A designee of the Chief Information Officer
• A designee of the Vice President for Student Affairs
• A designee of the Associate Vice President for Facilities
• A designee of the Assistant Vice President for Safety and Risk Management
• A representative from Faculty Senate
• A representative from Student Senate
• A representative from Classified Senate
• A representative from Administrative Senate

II.   Procedures

A.   Installation

1. Individual colleges, departments, programs, or campus organizations wishing to install video surveillance equipment shall consult with the Chief of Police and submit a written request to their appropriate dean or vice president describing the proposed location of surveillance devices, justifying the proposed installation, providing a cost estimate, and identifying the funding source or sources for purchase and ongoing maintenance.

2. The vice president or dean will review the request and recommend it to the Chief of Police, if appropriate.

3. The Chief of Police or his or her designee will review all proposals from deans and vice presidents and forward each proposal to the SOC with his recommendation to either approve or reject.

4. OUPD shall oversee the installation of all approved surveillance equipment with the assistance of University Planning and Implementation and the Office of Information Technology.

5. The OUPD shall limit camera positions and views of residential housing. Any view of housing will be no better than what is available with unaided vision. Furthermore the view of a residential housing facility must not violate the standard of "reasonable expectation of privacy."

6. Appropriate signage will be placed in all surveilled locations. Signage will state, "This Area is Subject to Video Surveillance."

7. Signage shall also include the name and phone number of a contact person who can answer questions about the surveillance system.

8. Video surveillance monitors shall be located in controlled-access areas and shall not be viewable by unauthorized persons.

B.   Training

1. Camera control operators shall be trained in the technical, legal, and ethical parameters of appropriate camera use.

2. Camera control operators shall receive a copy of this policy and provide written acknowledgement that they have read and understood its contents.

C.   Operation

1. Video surveillance of public areas for security purposes will be conducted in a manner consistent with all existing university policies, including Policy and Procedure 40.001, "Equal Employment and Educational Opportunity,"and Policy and Procedure 03.004, "Harassment." Video surveillance of individuals must not be based on the characteristics and classifications protected in Policy 40.001 (e.g., race, gender, sexual orientation, national origin, disability, etc.).

2. Camera control operators shall monitor based on suspicious behavior, not individual characteristics.

3. Camera control operators shall not view private rooms or areas through windows.

4. All operators and supervisors involved in video surveillance will perform their duties in accordance with this policy.

D.   Recordings

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

2. Video surveillance records will be stored in a secure location with access limited to authorized personnel only.

3. Video surveillance records shall be stored for a period not less than 120 days and will then promptly be erased, 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.

4. A log shall be maintained by the OUPD of all instances of access to or use of surveillance records. The log shall include the date and identification of the person or persons to whom access was granted.

5. Camera control operators who view recorded video shall do so in the presence of a supervisor to maintain the integrity of that video footage. This does not prohibit the remote observation of a camera's current signal, in real time, for example, in response to alarm activation or calls for service for OUPD, or other exigent circumstances.

1. President

2. Executive Vice President and Provost

3. Executive Staff

4. Vice President for Finance and Administration

5. General Counsel

6. Surveillance Oversight Committee

7. Policy and Procedure Review Committee