Draft of 44.119: Video Surveillance Systems

1. Purpose

   This policy regulates the installation and use of video surveillance systems for safety and security purposes in public and semi-public areas on the Athens campus of Ohio university. This policy does not imply nor guarantee that surveillance cameras will be monitored in real time.

   To ensure the protection of individual privacy rights in accordance with the law, as well as to preserve academic freedom and avoid discouraging the exercise of first amendment rights, this policy is adopted to formalize procedures for the installation of surveillance equipment and the handling, viewing, retention, dissemination, and destruction of surveillance recordings

   Video surveillance will be conducted in a professional, ethical, and legal manner. Under no circumstances will the contents of any video recordings be exploited for purposes of profit or commercial publication, except as may be required by law. The university will not normally share videos publicly without legal mandate unless in response to extenuating circumstances for which there is a compelling public interest. 

2. Scope

   1. Public and semi-public areas

      This policy applies to video surveillance in areas that are public or semi-public, in which there is not a reasonable expectation of privacy. It is important to note that just because an area may have restricted access, that alone does not create an expectation of privacy (e.g. residence hall lounges, residential hallways, computer labs, classrooms limited to students of a particular college or class, etc.)

   2. Private areas

      Areas on campus that have a reasonable expectation of privacy, including classrooms, are prohibited from being subject to video surveillance under this policy. Generally, private areas on campus include, but are not limited to, classrooms, private living quarters, restrooms, single occupancy offices, etc. Normally, video cameras in areas that could potentially capture both private areas (e.g. a window into a residence hall room) and public or semi-public areas should be installed such that the camera’s view does not include the private area. If reasonable measures cannot be taken to exclude private areas from a camera’s view, the private areas will be digitally blocked from view on both live and recorded images.

   3. Exceptions

      The following uses of video surveillance are exempt from this policy:

      1. Criminal investigations conducted by or in conjunction with the Ohio university police department;
      2. Academic instruction or feedback, as long as the video is not set to continuously record;
      3. Public web streaming video in areas that do not have a "reasonable expectation of privacy" and are not recorded (e.g., on the Ohio university website);
      4. Recording of public performance events for public entertainment (e.g., athletic events, plays, lectures, etc.).
      5. Video installations primarily intended to capture transactional data such as those installed on an ATM, vending machine, or at checkout-free smart stores.
      6. Video installations required to comply with legal standards that cannot be integrated into the enterprise solution.

      Projects believed to fall within one of these exceptions must be submitted to OUPD in advance for review and approval that the use case proposed meets an exception.

3. Procedures

   1. OUPD has the exclusive authority to administer this policy.
   2. All installations of video surveillance systems covered by this policy will use only the enterprise video surveillance solution chosen by the university.
   3. OUPD, along with the assistance of design and construction and the office of information technology will oversee the installation of approved video surveillance equipment.
   4. Video surveillance footage will only be recorded to the university's enterprise video surveillance solution.
   5. Video installations that are permissible under this policy will be placed in one of two groups for funding purposes:
      1. Cameras installed to protect the safety and security of the university community as a whole will be funded centrally.
      2. Cameras installed to meet the specific needs of a department or office, either to accommodate their operations or protect their property, will be funded by the department.
   6. Cameras falling under section 5(a) above will be subject to approval by the vice president for finance and administration based on the recommendation of OUPD.
   7. Units seeking to install cameras that fall under section 5(b) above will:
      1. Draft a written request to the chief of police, or their designee, which includes:
         1. Draft drawings which show the proposed location and direction of each camera;
         2. An employee who will be the unit's point of contact for the system; and
         3. Approval from the appropriate administrative head of the unit seeking the installation, including a funding source for one-time and on-going expenses.
      2. The chief of police, or their designee, will review the request for conformity to this policy and approve or deny the request.
      3. If disapproved, the chief of police, or their designee, will notify the proposing unit and may include recommendations to bring the proposal into alignment with the policy. The unit may elect to make those changes and resubmit the proposal to the chief of police, or their designee.
   8. The following disputes concerning the application of this policy are subject to review by a surveillance advisory group:
      1. Installations under section 5(b) that OUPD disapproves as impermissible by this policy.
      2. Installations that OUPD believes should be submitted for approval under section 5(b), but the unit believes should fall under section 5(a).
      3. Installations that are impermissible under this policy, but a unit is seeking a variance for circumstances they believe are compelling.
   9. Disputes outlined in section 8 above shall be submitted to the chief of police, or their designee, who will convene the surveillance advisory group, consisting of the following positions or their designees:
      1. Chief privacy officer
      2. General counsel
      3. Chief information officer
      4. Chief of police
   10. The surveillance advisory group shall review the dispute and submit a recommendation for disposition to the President's Executive Council for their review and approval.

4. Use of video surveillance systems

   1. Video surveillance of public and semi-public areas will be conducted in a manner consistent with all university policies. Any perceived violation of university policy shall be resolved in accordance with applicable dispute resolution processes outlined elsewhere in university policy.
   2. OUPD will oversee access to the university’s video surveillance system and to all video cameras individually. Real-time and historical video access will be restricted. At no time will access be granted to the system for the purpose of searching for unprompted evidence of wrongdoing.
   3. Real-time video access
      1. Any individual or department with a need to view video in real time will submit a completed "Request for Video Access" form to the chief of police, or their designee.
      2. The chief of police, or their designee, will review the request for a legitimate operational need and will approve or deny the request. If approved, OUPD will ensure access is granted.
   4. Historical recordings
      1. Historical recordings may be used by Ohio university officials conducting bona fide investigations. The investigating official will submit a completed “Request for Historical Video Access” form to the chief of police, or their designee.
      2. All Ohio university police officers and communications officers will have permanent access to all video surveillance systems, both in real time and historically.
   5. Any person who has been granted access to the video surveillance system will: (1) not allow their access to be used by another person; and (2) use their access only for the purpose of their job duties.

5. Disposition of records

   1. No attempt will be made to alter any part of any video recording. Access to video surveillance systems will be configured to prevent tampering with records.
   2. Ohio university police department will determine the minimum standards for video recording.
   3. Video surveillance records on the central server, when recording at minimum standards, will be stored for a period not less than thirty days and will then promptly be deleted.
   4. If an operational need arises for a camera(s) to record above the minimum standard, the unit’s point of contact or investigating official should submit a request in writing to the chief of police, or their designee, explaining the need and duration for the change. Such requests will be approved or denied by the chief of police or designee. Due to data storage limitations, video recordings for the approved camera(s) may not be available for the full thirty day retention period. The chief of police or designee will ensure that the affected cameras are restored to minimum standards as soon as practical.
   5. Public records requests for video footage may be submitted to the Ohio university police department who, in consultation with legal affairs, will review each request on a case-by-case basis and respond as required by law. 

Forms, References, and History

1. Forms

   1. Request for Video Access [PDF ADA]

2. References

   The following items are relevant to this policy:

   1. Policy 03.004, "Sexual Misconduct."
   2. Policy 40.001, "Equal Employment and Educational Opportunity."

3. History

   Draft versions of this policy that were circulated for review, their cover memos, their forms, and Reviewers' comments on them are available on the password-protected Review site.

   Prior versions of this policy was approved on:

   1. December 2, 2025 (approved for interim use in accordance with policy 01.001)
   2. September 17, 2021 (Non-substantive update. Classified Senate removed as Reviewer due to the establishment of the AFSCME 3200 Contract)
   3. August 17, 2017
   4. November 3, 2008.