University Security Camera System

Adopted Policy 6.3

Policy Purpose

The University at Albany sets forth principles for the installation and appropriate use of the University Security Camera System.

Responsible Office

University Police Department, Division of Finance and Administration

Responsible Executive

Chief of University Police

Policy History

Date of Permanent Approval: August 29, 2019

Policy Statement

The University at Albany respects the privacy of the University Community and strives to balance that privacy against the safety needs of the University Community. The University employs a University Security Camera System to deter crime; to identify potential criminal activity; to investigate criminal activity and violations of applicable policies, procedures, rules, regulations, and other oversight requirements applicable to the University; and to enhance the safety, security and quality of life for the University Community.

Persons Affected

Students, Faculty, Staff, Third Parties

Definitions

Campus or Campuses is any University owned, leased, licensed or operated space, facility, property, grounds, equipment, motor vehicle or building.

Employee is any faculty member of the University at Albany or staff employed by the University at Albany or a University-related Organization and its subcontractors who are issued University at Albany identification cards.

Private Areas are identified as areas including residence hall rooms, bathrooms, shower areas, locker and changing rooms, and areas where a reasonable person might change clothing. Additionally, rooms used for medical, physical, or mental therapy or treatment, and their entrances and exits, are defined as Private Areas.

Public Areas are all areas not specifically defined as Private Areas by this policy.

Reasonable Expectation of Privacy is an expectation of privacy generally recognized by society and perhaps protected by law.

Security Camera Footage is the recording produced by the cameras and retained by the software and hardware within the University Security Camera System.

University is the University at Albany, State University of New York.

University Community is the University students and faculty, University and University-related Organization staff, vendors, visitors, and guests who regularly or periodically occupy and/or utilize the Campuses of the University.

University-related Organization(s) is one or all of the following entities associated with the University: University at Albany Foundation, Research Foundation for State University of New York, University Auxiliary Services at Albany, Inc., University at Albany Bioscience Development Corporation, Alumni Association of the State University of New York at Albany, Empire Commons Student Housing, Inc., Student Association State University of New York at Albany, Inc., and University at Albany Graduate Student Association.

University Security Camera System is the collection of cameras owned by the University used to advance the safety and security of the campus community, along with the related infrastructure and software needed to store and access the images recorded by the cameras.

Policy

The University at Albany will utilize the University Security Camera System in Public Areas of the Campuses to enhance safety, security, and quality of life for the University Community in a manner consistent with pertinent federal and New York State laws.

Intended use
1. Investigations – To assist in the investigation of potential criminal acts and violations and enforcement of federal, state, State University of New York and University laws, policies, procedures, rules, regulations, and other applicable oversight requirements.
2. Critical incident response – To assist responders in the event of a critical incident to deploy resources in a safe and effective manner.
3. Alarm verification – To assist responders in determining the nature of intrusion alarms, exit door controls, hold-up and panic alarms.
4. Crowd management – To assist in determining crowd activity and volume during events or in areas of high pedestrian or vehicle traffic. These areas can include: Campus grounds, parking lots, roadways, bus stops, and recreational areas.
5. Verification of building access – To assist in verifying the condition of building access as well as identification of individuals gaining access to secure locations.
6. Property protection – To verify the security of building perimeters, entrances, lobbies, corridors, receiving docks, special storage areas, laboratories, cashier locations, ATM/CVC machines, and emergency telephones.
7. Real time monitoring of cameras within the University Security Camera System is neither implied nor guaranteed.
Prohibited use
1. Profiling - The practice of targeting individuals based on characteristics including, but not limited to, race, gender, ethnicity, sexual orientation, disability, religion or other protected classifications is prohibited.
2. Personal interest – The University Security Camera System shall not be used to serve private interests, nor to satisfy personal curiosity.
3. Privacy – The University Security Camera System shall not be used to interfere with an individual’s Reasonable Expectation of Privacy without legitimate cause and appropriate authorization as required by law.
4. Audio – The University Security Camera System shall not be used to capture audio whether live or as a recording. Any audio functions of cameras within the System will not be utilized under this policy.
Video cameras exempted from this policy
1. The following are not part of the University Security Camera System and are therefore not governed by this policy.
  1. The police use of in-car video, on-body video, or University police building recording systems.
  2. Cameras used covertly by University police or other law enforcement agencies for criminal surveillance as governed by New York State law.
  3. Academic use of video cameras for educational purposes, video cameras used for journalism, or private video cameras owned and operated by individual members of the University community.
  4. Video cameras or webcams established temporarily or permanently by the University for reasons unrelated to surveillance activity, such as remote monitoring of facility construction to ascertain project progress, campus marketing or public relations initiatives, or fundraising activities.
  5. Surveillance cameras that are owned by vendors or contractors of the University or its University-related Organizations that are installed within their equipment.
Installation and placement of cameras
1. The University reserves the right to place video cameras on its Campuses in Public Areas where necessary and appropriate for the purposes identified above.
2. All video cameras on Campus, other than those specifically exempted in Section C of this policy, may only be installed with written authorization of the Responsible University Official for this policy and must be installed as part of the University Security Camera System.
3. The process and guidelines for decisions regarding placement of new video cameras in the University Security Camera System is included in procedures promulgated under this policy.
4. Prior to the approval of any plan for new construction or renovation, the Responsible University Official shall review the project and determine if cameras are required employing the process and guidelines referenced in Section D.3.
5. University schools, colleges, and departments presently utilizing security cameras that are not integrated into the University Security Camera System shall promptly advise the University Police Department, which will review the location and utilization of the cameras to determine whether or not they are in compliance with this policy. The Police Department will inform the operators of actions needed to bring the cameras into conformance with this policy. These actions may include the removal of the camera(s) and destruction of stored footage.
Notification of the University Community
1. This policy shall be made available to all students, faculty, staff, and visitors and be printed in appropriate publications to inform the University Community that cameras may be utilized on Campus.
2. Signage shall be conspicuously posted in recorded areas to inform the University Community of the presence of cameras.
Camera system access
1. All members of the University Police Department and other Employees who have been approved by the Responsible University Official for this policy for access as part of their job duties shall have access to the University Security Camera System for use consistent with Section A of this policy.
Security Camera Footage
1. The Security Camera Footage produced by the University Security Camera System are records of the University Police Department.
2. The Responsible University Official or their designee will authorize use, duplication, or release of these records for University officials. Any use, duplication, or release of these records to external users requires authorization by the Responsible University Official or their designee in consultation with the Office of General Counsel.
3. The Responsible University Official or their designee shall oversee the storage and maintenance of all Security Camera Footage, making all reasonable effort to ensure the integrity of the footage obtained through the University Security Camera System.
4. Any activity observed by a person reviewing Security Camera Footage that is, or may reasonably be, criminal in nature must be promptly reported to the University Police Department.
5. Manner and length of storage of Security Camera Footage will occur in accordance with the procedures promulgated in support of this policy.
6. No alterations of any footage recorded by the University Security Camera System shall be made, with the exception of those permitted in the procedures promulgated under this policy.
This Policy shall go into effect immediately upon approval.

Procedures

Requesting camera services
1. All requests for the placement of a camera subject to this policy must be made in writing to the Responsible University Official or their designee.
  1. All requests shall include information on specific security concerns at the requested location.
  2. Requests for camera services will result in a security review conducted by the University Policy Department to determine the security needs of that location and a recommended remediation strategy if necessary.
  3. The Office of Facilities Management shall request a security review during the planning stage of all new construction and major renovation projects for the purpose of including camera placement in these facilities if necessary such that such placement can be integrated with the construction stage.
2. In assessing requests, the Responsible University Official or their designee shall consult additional pertinent offices as necessary including, but not limited to, the Office of Residential Life, the Office of Facilities Management, the Office of Information Technology Services, the Office of Enterprise Risk Management and Compliance, and the Office of General Counsel.
3. The Responsible University Official or their designee will respond in writing to all requests for the placement of a camera within thirty (30) days of receipt of such request.
4. Appeals of a decision regarding the possible placement of a camera under this policy shall be made in writing to the Vice President for Finance and Administration.
  1. All appeals need to include the original written request as well as the written response by the Responsible University Official or their designee in addition to an additional justification for the placement request.
5. If camera placement is a component of a recommended remediation strategy, the Responsible University Official or their designee will evaluate and determine the exact placement of such camera or cameras in accordance with the following guidelines:
  1. Cameras will be installed in locations which contribute to the safety and security of the University Community.
  2. Cameras may not be installed in Private Areas of the Campus. The only exceptions are cameras which would not capture images of patients or clients installed in Private Areas containing sensitive items.
  3. University Security Camera System cameras shall not be purposely directed in a manner to infringe on an individual’s Reasonable Expectation of Privacy.
    1. If a camera is mistakenly directed in such a manner, a request shall be made by the affected party or a University official to the Responsible University Official or their designee to review and correct the camera placement.
    2. If any person reviewing Security Camera Footage observes the fact that a camera placement is infringing on the Reasonable Expectation of Privacy of any member of the University Community, such infringement shall be immediately brought to the attention of the Responsible University Official or their designee such that the camera placement can be reviewed and corrected.
  4. Empty, dummy, or placebo cameras are not to be used.
Requesting user access to the University Security Camera System
1. All requests to receive user access to the University Security Camera System must be made in writing to the Responsible University Official or their designee.
2. The Responsible University Official or their designee shall assess requests for user access to the University Security Camera System based on section A. Intended Use of University at Albany policy 6.3 University Security Camera System.
3. The Responsible University Official or their designee shall respond to all requests for user access within thirty (30) days of receiving the written request.
4. Appeals of a decision regarding user access can be made in writing to the Vice President for Finance and Administration.
  1. All appeals need to include the original written request as well as the written response by the Responsible University Official or their designee.
5. The Responsible University Official or their designee shall ensure that all persons who receive user access to the University Security Camera System review University at Albany policy 6.3 and receive training in the effective, legal and ethical use of the University Security Camera System before accessing the System the first time.
6. Each person granted user access to the University Security Camera System shall sign a University Security Camera System Access and Compliance Agreement as attached to these procedures. Such agreement shall be maintained on file by the Responsible University Official or their designee and be in effect and enforceable throughout such person’s employment by or relationship with the University.
7. The Responsible University Official or their designee shall maintain a log of all persons approved to have user access to the University Security Camera System, including the date of approval, exact level of approved user access, date of training, date of signed University Security Camera System Access and Compliance Agreement, the reason for approving user access, and, if applicable, date of termination of user access.
Video or other storage media of Security Camera Footage
1. To protect the integrity of Security Camera Footage derived from the University Security Camera System, alterations require approval by the Responsible University Official and are limited to those intended to protect the privacy of nonparticipants in an incident, or to produce a still image for a lawful purpose.
2. The University Security Camera System Footage shall be maintained and stored by the University Information Technology Services (ITS).
3. ITS shall create a written documentable chain of custody plan for all University Security Camera Footage and obtain written approval of such plan by the Chief Information Officer and the Responsible University Official. The Responsible University Official shall retain the signed, approved copy of the plan. The Chief Information Officer shall be responsible for ensuring its implementation.
4. Security Camera Footage derived from the University Security Camera System shall be stored by ITS for a period no less than 14 days and not to exceed 30 days unless retained as part of a criminal investigation, court proceeding, other University investigation, or other bona fide use as approved by the University Police Department in consultation with the University Office of General Counsel.
5. ITS shall apply standard University information technology protocols to ensure availability, integrity and confidentiality of the Security Camera Footage.
6. The Chief Information Officer shall determine UAlbany ITS employee access to the University Security Camera System and review access at regular intervals according to standard ITS protocols to determine if employee access to the University Security Camera System is still warranted.
Maintenance and testing of cameras and equipment
1. The Responsible University Official shall ensure that the equipment necessary to effectively operate the University Security Camera System is maintained in good working order.
2. All maintenance and repair to be performed by technicians with a demonstrated expertise in video surveillance systems.
3. University ITS shall monitor the network, video processing service, and storage solution to identify malfunctions. Malfunctions that cannot be immediately corrected shall be promptly reported to the Responsible University Official or their designee.
4. The Responsible University Official shall ensure that tests of all cameras are conducted weekly, with malfunctions promptly submitted for repair.
5. The Responsible University Official or their designee shall maintain a log of all tests, malfunctions, maintenance, and repairs of the University Security Camera System.