Video Monitoring and Surveillance Policy

I. PURPOSE

The purpose of this policy is to regulate the use of video cameras owned and operated by Juniata College to monitor and record college premises.

II. SCOPE

This policy applies to all college Public Safety personnel in the use of video monitoring and recording equipment systems, to administrators and technology partners in determination of camera placement and access to and use of records, and to all individuals captured by camera recordings.

III. GENERAL INFORMATION

A. Juniata College Public Safety is committed to enhancing the safety and quality of life of the campus community by integrating the best practices of public and private security with state-of-the-art technology. A critical component of a comprehensive security plan using state-of-the-art technology is video surveillance.

B. The primary purpose of video technology is to deter crime and to assist JCPS officers in protecting the safety and property of the college community.

C. Video monitoring for security purposes will be conducted in a professional, ethical and legal manner. Personnel involved in the use of video equipment will be appropriately trained and supervised in the responsible use of this technology.

D. Information obtained through video recording and/or monitoring will be used for safety, security and law enforcement purposes and for compliance with college policies. Information obtained through video recording/monitoring will only be released when authorized by the Director of Public Safety.

E. Video monitoring for security purposes will be conducted in a manner consistent with all existing college policies including Non-Discrimination Policy, the Title IX Policy on Sexual Harassment, and other relevant policies. The college prohibits video monitoring based on the characteristics and classifications contained in the Non-Discrimination Policy (e.g. race, gender, sexual orientation, national origin, gender identity, disability, etc.)

F. Video monitoring of areas for security purposes at the college is limited to locations that do not violate the reasonable expectations of privacy as defined by law.

G. Except as provided in policies relating to covert surveillance, all video camera installations will be visible.

H. Audio recording is not a capability of this system, and recording of conversations or audio transmissions without express authorization of all parties is a violation of Federal law and the laws of the Commonwealth of Pennsylvania.

IV. RESPONSIBILITIES

A. Juniata College Public Safety (JCPS) is authorized to oversee and coordinate the use of video equipment for public safety purposes at the college.

B. The Director of Public Safety, in coordination and consultation with the Chief Student Affairs Officer (CSAO) and Chief Human Resources Officer (CHRO), has the responsibility to authorize the use of video equipment for public safety purposes at the college. All new installations will follow JCPS operating principles.

C. JCPS will monitor new developments in the relevant law and in security industry practices to ensure that video monitoring at the college is consistent with the highest standards and protections.

D. All members of JCPS shall be considered to be video surveillance system operators and shall receive training with regard to the system and are required to maintain a working knowledge of the monitoring functions of the system.

E. All JCPS personnel shall be guided by the information outlined in this procedure relative to the monitoring of video surveillance cameras.

F. The JCPS Supervisor/Officer on duty shall be immediately notified whenever any suspicious, criminal, or life-threatening activity is observed through the monitoring of video surveillance cameras. Incident reports will include relevant narrative observations of significant camera-related recording or activity. In instances as determined by JCPS, recordings will be preserved as a part of the report record.

V. MANAGEMENT

A. Security of digital recordings:

1. Access to digital recording equipment is limited to: The Director of Public Safety, designated JCPS supervisors and administrative staff; the CSAO; the CHRO; members of the Information Technology Services when supervised or directed by the Director of Public Safety or his/her designee and others as may be designated by the Director of Public Safety.

B. Limiting access to digital recordings or video surveillance equipment:

1. The Director of Public Safety has the authority to limit access to digital recordings and video surveillance equipment by matching position need or use case to access tools and restrictions in the interface or through implementation of rules and regulations, such as this procedure.

2. Under no circumstances will anyone other than members of the Public Safety Department, Dean of Students Office or Human Resources be permitted access to the video surveillance system and shall not be permitted to monitor video surveillance cameras or digital recordings, without prior knowledge and permission from the Director of Public Safety.

C. Review and dissemination of information:

1. Only the Director of Public Safety or his/her designee is permitted to review, copy, or remove digital recordings from the video surveillance system.

2. The Director of Public Safety or his/her designee should assist other members of JCPS with any needs related to digital recordings.

3. Concerned citizens, victims, news media, and other non-security employees will not be allowed access to digital recordings unless approved by the Director of Public Safety.

4. JCPS Officers investigating crimes or other incidents are encouraged to seek the Director’s assistance in reviewing digital recordings for suspect or other valuable information.

5. If necessary, the Director of Public Safety or his/her designee can export a digital record for evidence purposes. This digital material will be handled as evidence and disseminated to proper authorities as required by law or subpoena.

VI. PROCEDURES

A. The use of video surveillance cameras shall be limited to campus Public Safety purposes, including but not limited to:

1. People, property and building protection, enhancing public safety, crime prevention and deterrence, reducing or removing the fear of crime, alarm verification, video patrol of public areas, criminal investigation, identifying suspects, gathering evidence and monitoring of access control systems.

B. Video surveillance cameras shall not be used for: Profiling, random targeting of individuals, peering into buildings, private office or living spaces, restroom facilities, locker rooms, or other areas where the is an expectation of privacy, except for legitimate campus Public Safety purposes, such as criminal investigation and only after approved by the Director of Public Safety, CSAO and CHRO.

C. All officers and supervisors involved with the use of video equipment and systems will perform their duties in accordance with Department and College Rules and Regulations.

D. Juniata College Public Safety Officers are prohibited from using and/or disseminating any information acquired from the video equipment. All information and/or observations made in the use of the CCTV equipment are considered CONFIDENTIAL and can only be used for official college and law enforcement business upon the approval of the Director of Public Safety.

E. Camera locations are discussed with the CSAO and CHRO, and or their designee, before installation takes place.

F. JCPS will post and maintain legally required signage at appropriate campus entrances, buildings, areas, and/or spaces where video surveillance systems are being utilized (unless those systems are installed for covert monitoring as authorized and approved by the Director of Public Safety, CSAO and CHRO). Signage will state: THIS AREA IS SUBJECT TO VIDEO SURVEILANCE.

G. Recorded events are stored temporarily on local devices and then securely in the cloud unless retained as part of a criminal investigation, court proceedings (criminal or civil), college judicial proceedings, or other Bona Fide use as approved.

H. The system will store data for up to 30 days before the images are overwritten. The system replaces the oldest images with newer images (FIFO).

I. Cameras are NOT continuously monitored under normal operating conditions but may be monitored periodically for legitimate Public Safety purposes that include, but are not limited to, the following: high risk areas, restricted access areas/locations, in response to an alarm, at times and locations that have previously experienced violations, special events and specific investigations upon reasonable suspicion.

J. Should monitoring reveal activity that violates laws, an investigation will be initiated. Violations of law or incidents that jeopardize student, employee or community safety will be responded to immediately and documented as per protocol. Violations of college policy that do not jeopardize the safety of students or community members and is not considered urgent or an emergency will not be responded to immediately. Such activities will be documented and addressed directly by the Director of Public Safety or his/her designee.

K. Periodically the college experiences patterns of criminal activity, both to persons and property. Much of the problem has been confined to acts of vandalism or theft of property or equipment. In an effort to combat these problems, either by deterring the activity of apprehending violators, the college may use video equipment for covert surveillance purposes. As previously noted, the cameras will not be

installed in any area that would violate the reasonable expectations of privacy as defined by law. No further announcement will be made prior to the actual placement of video equipment.

L. The Public Safety Department with the approval of the CSAO and CHRO (or the individual’s proxy/designee in instances of absence or leave) will only use covert cameras and equipment for legitimate Public Safety purposes, such as criminal investigation. The following procedures will be followed:

1. The Director of Public Safety shall notify the CSAO and CHRO of the installation and activation of a covert camera, including: the knowledge and/or allegation leading to the recommendation for the purpose of the cameras. Additionally, the justification shall include the specific location of the camera, anticipated date(s) of operation, and installation and protocol for reporting the video evidence.

2. The Director of Public Safety or his/her designee shall review the video periodically, at least once a day. A report of activity on the video will be shared with the relevant CSAO/CHRO(s.)

3. If the camera has been installed and activated as a result of a specific investigation, it shall be the responsibility of the Director of Public Safety or his/her designee to ensure that the device is removed promptly at the end of the investigation.

4. It shall be the responsibility of the Director of Public Safety and the relevant CSAO/CHRO(s) to determine if any other college personnel should be made aware of the installation and activation of the covert camera.

VII. MAINTENANCE OF EQUIPMENT

A. Under no circumstances shall anyone, except designated or contracted technicians attempt to service, repair, or tamper with any of the video surveillance equipment.

B. If any video surveillance system equipment fails, the Director of Public Safety or his/her designee should be notified as soon as possible. The Director of Public Safety or his/her designee will be responsible for notifying the factory representative for repairs and for shutting down the affected equipment during failure.

VIII. EXAMPLES OF VIDEO MONITORING AND RECORDING OF PUBLIC AREAS

A. Legitimate Public Safety purposes include, but are not limited to the following:

1. Protection of People – Awareness and understanding of movements and interactions between individuals on and adjacent to campus.

2. Protection of Buildings and Assets – Building perimeter, entrances and exits, lobbies and corridors, receiving docks, special storage areas, laboratories, cashier locations, etc.

3. Monitoring of Access Control Systems – Monitor and record restricted access transactions at entrances to buildings and other areas.

4. Verification of Security Alarms – Intrusion alarms, exit door controls, hold-up alarms.

5. Video Patrol of Public Areas –Parking lots, public streets, and vehicle intersections, etc.

6. Criminal Investigation – Robbery, burglary, and theft surveillance, etc.

7. Protection of Pedestrians – Monitoring of pedestrian and vehicle traffic activity.