University Policy 101

Installation and Use of Video Cameras for Non-Academic Purposes

Approved by Executive Council: 5/12/08
Posted: May 12, 2009
Revised & Posted: October 30, 2017
Policy Topic: Business Administration & Auxiliary Services
Administering Office: Administration and Finance


I. POLICY STATEMENT

It is the intent of this policy is to set requirements for the purchase and installation of video cameras for non-academic purposes; blue-light phones; panic buttons; and other such public safety technology.  WCU is committed to implementing and maintaining a security plan that incorporates the use of these technologies to enhance community safety through crime and crisis prevention, detection, and reporting activities.

II. DEFINITIONS

1.     Non-Academic Video Cameras

Video cameras installed, affixed or located, permanently or temporarily, for the purpose of monitoring or observing activity over time.  Non-Academic Video Cameras may be installed during either the course of capital construction or as an independent project.  This definition does not include legitimate uses of video cameras for instructional or research purposes. This definition does not apply to the legitimate use of non-affixed, portable video cameras used for newsgathering, creative, or promotional purposes.

2.     Emergency Notification (Blue Light) Phones

Emergency notification phones are located throughout campus.  Their purpose is to allow for direct emergency dialing to the University Emergency Communications Center (ECC).  These devices may have landline, cellular, or radio notification capabilities.  This includes Emergency Notification Phones that are installed during either the course of capital construction or as an independent project.

3.     Panic Buttons / Silent Alarms

Buttons used for automatic notification of emergency personnel (police, EMS, or fire) when used.  This includes panic buttons that are installed during either the course of capital construction or as an independent project.

4.     Emerging Technologies

Any technological communications and/or video device not listed above that could be installed for the purposes of campus safety and security.  The only exceptions to this are devices, alarms, panels, hydrants, and pull stations related to fire detection and suppression.

 5.     Campus Camera System

The network of Non-Academic Video Cameras and digital video recorders, to include all associated components that are used to continuously monitor non-academic areas on and around campus.  The campus camera system does not include any academic video cameras or recording equipment.  Additionally, the camera systems are not installed in nor used for viewing of private areas.

6.     Two-Way Radios

Two-way radios are used by University departments to communicate business-related information amongst staff members.  These entities are both public safety as well as non-public safety departments. These two-way radios used, in some circumstances to communicate with non-University agencies in cases where mutual aid may be used.  Radio traffic on these devices is regulated by the Federal Communications Commission (FCC).

III. AUTHORIZED ROLE AND PURPOSE OF PUBLIC SAFETY TECHNOLOGIES

A.    Video Cameras for Non-Academic Use

1.     Video Cameras for General Safety and Security

Non-Academic Video Cameras, with or without video recording capability, may be used overtly on campus to enhance safety and security. Non-Academic Video Cameras shall not be monitored continuously in real time and are not intended to serve as a reliable way to request or attract police assistance.  

University Departments that have purchased Non-Academic Video Cameras may be granted access to view cameras that they have purchased and had installed. University Police and University Emergency Services are the only authorized personnel permitted to record or copy images or video from the Campus Camera Systems.

2.     Video Cameras for Targeted Criminal Investigative Purposes

University Police may use video cameras, overtly or covertly, on a short-term basis for law enforcement purposes including, but not limited to, evidence gathering during a criminal investigation. Such use must comply with the law and any standards or procedures adopted by the University Police. Other than paragraph IV.D. below.  The remainder of this policy is not applicable to cameras used for investigative purposes.

3.     Video Cameras for Marketing, Training, or Public Observation

Video cameras (including web cams) may also be used overtly for viewing and/or recording images in public spaces for university purposes, including marketing and recruitment, employee training, athletic coaching, or public observation. Images of activities in public spaces may be distributed electronically without notice to participants.

B.    Emergency Notification (Blue Light) Phones

Emergency Notification (Blue Light) Phones shall be used in fixed locations including, but not limited to, parking lots, adjacent to sidewalks, and near buildings.  These emergency notification phones are to be used by students, staff, faculty, and visitors that need emergency assistance from police, fire, or Emergency Medical Service personnel.  These emergency notification phones are for crisis communications only, and once activated dial directly to the WCU Emergency Communications Center.

C.    Panic Buttons

Panic Buttons shall be installed, upon approval by the Department of Emergency Services and the University Police Department (as outlined in paragraph IV.C), in locations where financial transactions occur; and in locations where sensitive personnel and student issues may be handled; any other location as determined by University Police and the University Department of Emergency Services.   Panic buttons shall be considered a last resort of communications, and only used when alternative means of communications will not work or are not justifiable.

 D.    Emerging Technologies  

New Public Safety technologies are developed on a consistent basis.  Before the implementation of any technology relating to public safety at Western Carolina University, the Department of Emergency Services and the University Police Department, as outlined in paragraph IV.C, must review the technology to determine consistency with campus standards and viability to overall campus safety and security.

E.    Two-Way Radios

These devices include single and multi-channel two-way radios, along with any associated accessories to include shoulder microphones, batteries, chargers, and earpieces.  This is to ensure consistency with the WCU radio communications systems.  Any radio purchase by a WCU department shall be approved through the Department of Emergency Services and University Police (as outlined in paragraph IV.C) to ensure consistency with campus standards.  Additionally, the Department of Emergency Services will authorize and facilitate the addition of channels on each radio per campus standards.

IV. RESPONSIBILITIES AND AUTHORITIES

A.    General

It is the responsibility of all administrators and department heads, including University Police, to make recommendations about the level of security required on campus. Decisions to install public safety technologies listed under paragraphs III.A - D. above will be made through consultation and deliberation as described below.

B.    Role of Requesting Office/Department

An office/department wanting to install any public safety technology, as listed in paragraphs III.A-D, is required to consult with the WCU Department of Emergency Services first.  The following information must be provided by the requestor:

Purpose, location, and areas to be covered by each piece of technology

Budget available for purchase, operation, maintenance and repair, installation and removal of the requested public safety technology device(s);

Description of how the proposed installation of technology fits into WCU campus security needs, as well as the requesting department’s needs and operations. 

In the case of cameras, any plans for use of cameras, to include use of any captured images by the camera or recording device, shall be defined by the requesting office / department.

  In case of camera installation request, the retention period for images captured and recorded, if any, by each camera

All equipment must be consistent with standards set forth by Western Carolina University.

The authorized user is responsible for all costs associated with the camera including the purchase, operation, maintenance/repair, installation and removal costs.

Upon approval by the Department of Emergency Services, the Department responsible for purchase will develop a Purchase Order in order to procure the approved equipment.  No equipment listed under this policy shall be purchased through a P-Card or other means.  This includes accessories associated with the equipment described in this policy.

C.    Review of Public Safety Technology Requests

The Department of Emergency Services and the University Police Department will jointly review and approve any requests for new or replacement public safety technology as outlined in paragraph III.A-D above.  The Department of Emergency Services and the University Police Chief will ensure that the requests, at minimum, conform to the information requested in paragraph IV.B and the following additional information:

Compatibility with existing university equipment and standards set by the Department of Emergency Services, the University Police Department, and Information Technology.   

Assurance of compliance with applicable privacy laws

Upon approval, the Department of Emergency Services will coordinate with the requesting department, Information Technologies, and Facilities Management to ensure there are no conflicts with proposed purchase and installation.

D.    Role of the University Emergency Services and Police Department

The Department of Emergency Services will receive requests for any public safety technologies outlined in paragraphs III.A-D.  Upon receipt of the request, the Department of Emergency Services will provide initial review of the request and consult with University Police to ensure that the project is necessary, all standards are met, and concerns are met.

The Department of Emergency Services and University Police may operate all public safety technologies, to include Non-Academic Video Cameras, or provide direct supervision of the use of such equipment by authorized users, as necessary.

The Department of Emergency Services and the University Police will store, retain and otherwise control all images in whatever format captured by Non-Academic Video Cameras and recording devices operated for law enforcement purposes pursuant to Paragraph III. A. above. These materials shall be available only to duly authorized officials of WCU with a legitimate educational or business interest and/or appropriate law enforcement agencies in connection with criminal investigations or criminal proceedings. University offices conducting investigations into violations of law, policy, or regulations, including, but not limited to, the Student Code of Conduct, have legitimate educational or business purposes to review the records. Materials will also be made available to authorized agencies or persons upon receipt by the Police Department of a duly issued subpoena or other court order.

The Department of Emergency Services will issue an annual report to the campus disclosing the location of all Non-Academic Video Cameras and recording devices except for those being used for on-going criminal investigations under paragraph III.A. above.

The Department of Emergency Services and the University Police Department will conduct an annual assessment of the need for adding new public safety technologies in order to enhance campus security.

E.    Role of Information Technology (IT)

IT is responsible for assisting with the coordination of IT infrastructure associated with Public Safety Technology outlines in paragraphs III.A-D. 

IT is responsible for developing and maintaining software and equipment standards and protocols for the online distribution of video (live or pre-recorded) for university purposes. Video images and presentations distributed live online may or may not be monitored, recorded and archived by the university.

IT is responsible for coordinating planned outages or reporting discovered interruptions of public safety technologies to the Department of Emergency Services.

 F.    Role of Facilities Management

Facilities Management shall be consulted before any public safety technology is installed. Any public safety device that is attached to a building will be approved by Facilities Management.  Authorized users are responsible for the cost, if any, of installation and removal of any public safety device by Facilities Management.

G.   Camera Video Retention Guidelines for Units other than University Police

There is no obligation that Non-Academic Video Cameras make a record of matters observed. Should a record be made it is recommended that a minimum 30-day retention period, if allowed by the capacity of the recording equipment, be implemented.

Any image captured in any format by a non-academic video recording device shall be transferred upon request to the University Police or to any other university unit with a legitimate educational or business need for the record pursuant to this policy. The receiving unit is responsible for retention of the images in accordance with State policy.

Recorded video may only be retrieved for criminal investigation or disciplinary proceedings.  Any exceptions to this will be reviewed on a case by case basis by the Department of Emergency Services and University Police.

V. SANCTIONS

Unauthorized use of Non-Academic Video Cameras may subject an employee or student to disciplinary action up to and including dismissal. Unauthorized use will be reviewed on a case-by-case basis in light of the surrounding circumstance.

VI. POLICY REVIEW

The Vice Chancellor for Administration and Finance is responsible for the review of this operating policy every two (2) years or as needed.

 

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