| [Almanac, April 13, 1999]
I. Purpose
The purpose of this policy is to regulate the
use of closed circuit television (CCTV) cameras to monitor and record public
areas for the purposes of safety and security.
II. Scope
This policy applies to all personnel, schools
and centers of the University in the use of CCTV monitoring and recording.
Legitimate uses of this technology are covered by University policies governing
research with human subjects and are, therefore, excluded from this policy.
III. General Principles
A. The Division of Public Safety is committed
to enhancing the quality of life of the campus community by integrating
the best practices of public and private policing with state-of-the-art
technology. A critical component of a comprehensive security plan using
state-of-the-art technology is closed circuit television (CCTV).
B. The purpose of CCTV monitoring of public
areas by security personnel is to defer crime and to assist the Penn police
in protecting the safety and property of the University community. Any
diversion of security technologies and personnel for other purposes (e.g.,
CCTV monitoring of political or religious activities, or employee and/or
student evaluations) would undermine the acceptability of these resources
for critical safety goals and is therefore prohibited by this policy.
C. Video monitoring for security purposes will
be conducted in a professional, ethical and legal manner. Personnel involved
in video monitoring will be appropriately trained and continuously supervised
in the responsible use of this technology. Violations of the Code of Procedures
for video monitoring referenced in this policy will result in disciplinary
action consistent with the rules and regulations governing employees of
the University.
D. Information obtained through video monitoring
will be used exclusively for security and law enforcement purposes. Information
obtained through video monitoring will only be released when authorized
by the Vice President of Public Safety according to the procedures established
in this policy.
E. Video monitoring of public areas for security
purposes will be conducted in a manner consistent with all existing University
policies, including the Non-Discrimination Policy, the Sexual Harassment
Policy, Open Expression Guidelines and other relevant policies. The Code
of Practice for video monitoring prohibits monitoring based on the characteristics
and classifications contained in the Non-Discrimination Policy (e.g., race,
gender, sexual orientation, national origin, disability, etc.).
F. Video monitoring of public areas for security
purposes at the University is limited to uses that do not violate the reasonable
expectation of privacy as defined by law.
G. To maintain an informed University community,
the Division of Public Safety will periodically disseminate written materials
describing the purpose and location of CCTV monitoring and the guidelines
for its use. The location of outdoor CCTV cameras monitored by the Division
of Public Safety will be published in Almanac.
H. Information obtained in violation of this
policy may not be used in a disciplinary proceeding against a member of
the University faculty, staff or student body.
I. All existing uses of video monitoring and
recording will be brought into compliance with this policy within 12 months
of the approval of this policy.
IV. Responsibilities
A. The Division of Public Safety is the department
authorized to oversee and coordinate the use of CCTV monitoring for safety
and security purposes at the University. All University areas using CCTV
monitoring are responsible for implementing this policy in their respective
operations. Public Safety has primary responsibility for disseminating
the policy and assisting other units in implementing the policy and procedures.
B. The Vice President of Public Safety has
the responsibility to authorize all CCTV monitoring for safety and security
purposes at the University. All new installations will follow the Division
of Public Safety operating principles. All existing CCTV monitoring systems
will be evaluated for compliance with this policy.
C. The Division of Public Safety will monitor
new developments in the relevant law and in security industry practices
to endure that CCTV monitoring at the University is consistent with the
highest standards and protections.
D. A CCTV Monitoring Panel will be established
to assure that the Division of Public Safety adheres to established policy
and procedure in the use of CCTV and to review camera locations and request
for release of tapes.
1. The CCTV Monitoring Panel will consist of seven members
who will serve for a term of one year.
The chairperson of the Safety and Security Committee or his/her
designee will serve as chair
Two faculty members appointed by the Chair of the Faculty Senate
One member appointed by the President
One student member
One staff member
The University Compliance Officer
An individual may appeal an adverse decision by
the CCTV Monitoring Panel through existing University appeal mechanisms
such as the Committee on Open Expression or the University Ombudsman.
2. The CCTV Monitoring Panel will review camera locations to insure
the perimeter of view of fixed location cameras conforms to this policy.
The proposed location of permanent CCTV cameras
will be provided to the CCTV Monitoring Committee for review and published
in Almanac before installation. A list of all University owned or controlled
camera locations will be published semi-annually in Almanac and
made available by the Division of Public Safety to anyone requesting the
list.
The locations of temporary cameras to be used
for special events will be reviewed by the CCTV Monitoring Committee for
approval and published in Almanac before the event if possible.
(Note: "Temporary cameras" does not include
mobile video equipment or hidden surveillance cameras used for criminal
investigations.)
Included with the list of CCTV camera locations
will be a general description of the technology employed and the capabilities
of the cameras.
Students and staff entering certain sensitive
locations on campus may have an increased concern for privacy and confidentiality.
In order to prevent a possible chilling effect on the use of service at
these locations, concerned persons may petition the CCTV Monitoring Committee
to forgo the installation of a proposed camera or for the removal of an
existing camera. The CCTV Monitoring Committee will determine the appropriateness
of an installation weighing the concerns of the person(s) making the requests
and the safety and security of the entire community.
In recognizing students may also have an enhanced
expectation of privacy in the hallways and lounges of residence facilities,
CCTV monitoring for safety and security purposes will not be used in residential
hallways and lounges unless the Vice President of Public Safety determines
the specific safety/security risk exits.
The CCTV Monitoring Panel will review complaints
regarding camera locations and determine whether the CCTV Monitoring policy
is being followed. The panel should weigh whether the potential increment
in community security outweighs any likely infringement of individual privacy.
3. The CCTV Monitoring Panel, with the Vice President of Public Safety,
will review all requests received by the Division of Public Safety to release
recordings obtained through CCTV monitoring. No releases of CCTV recordings
will occur without authorization by the Vice President and the CCTV Monitoring
Panel. Excluded from review by the CCTV Monitoring Panel are releases of
tapes directly related to a criminal investigation, arrest or subpoena.
The CCTV Monitoring Panel may also approve release of CCTV tapes only for
legitimate purposes, such as to protect the University and its members
from lawsuits or harm. Five affirmative votes are necessary to approve
the release of tapes. Any release of tapes will be recorded on a written
log.
4. Any member of the CCTV Monitoring Panel may audit the Division
of Public Safety's CCTV monitoring operations, including videotape storage,
at any time without prior notice.
5. The Chair of the Safety and Security Committee will report
to the Safety and Security Committee at least four (4) times per year describing
all requests for camera locations and release of tapes and disposition
of those requests.
6. The CCTV Monitoring Panel will review this policy annually
and recommend revisions if needed.
V. Procedures
1. All operators and supervisors involved in video monitoring
of public areas will perform their duties in accordance with the Code of
Practice consistent with this policy developed by the Division of Public
Safety.
2. Division of Public Safety Management will assure that responsible
and proper camera monitoring practices by control operators is continuous.
3. The Division of Public Safety will post signage at appropriate locations.
Signage will state,
THIS PUBLIC AREA MONITORED BY SECURITY CAMERAS
FOR PERSONAL SAFETY AND PROPERTY PROTECTION.
4. The Division of Public Safety will limit camera positions
and views of residential housing. Any view given to the housing will be
no greater 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."
5. The Division of Public Safety Central Monitoring Center and other
central security monitoring centers will be configured to prevent camera
operators tampering with or duplicating recorded information.
6. Recorded videotapes will be stored for a period not to exceed 30
days and will then 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 Vice President of Public Safety and the CCTV Monitoring Panel.
7. Video tapes will be stored in a secure location with access by authorized
personnel only.
8. Camera control operators will conduct video observation of areas
only in plain view of others situated in the public area viewable to the
public.
9. Camera control operators will be trained in the technical, legal
and ethical parameters of appropriate camera use.
a. Camera control operators will receive a copy of this policy
and provide written acknowledgment that they have read and understood its
contents.
b. Camera control operators will receive training in cultural awareness.
10. Camera control operators will not monitor individuals based on characteristics
of race, gender, ethnicity, sexual orientation, disability, or other classifications
protected by the University's Non-Discrimination Policy. Camera control
operators will monitor based on suspicious behavior, not individual characteristics.
11. Camera control operators will not spot and continuously view people
becoming intimate in public areas.
12. Camera control operators will not view private rooms or areas through
windows.
13. Mobile video equipment may be used in criminal investigations. Mobile
video equipment will only be used in non-criminal investigations in specific
instances creating significant risk to public safety, security, and property
as authorized in writing by the President to the Division of Public Safety
and the Open Expression Committee.
Portable hidden cameras with recording equipment
will only be used for criminal investigation by the University Police Detective
Unit with the approval of the Vice President of Public Safety.
Examples of Video Monitoring and Recording of Public Areas:
Legitimate safety and security purposes include, but are not
limited to, the following:
Protection of buildings and property.
Building perimeter, entrances and exits, lobbies and corridors,
receiving docks, special storage areas, laboratories, cashier locations,
etc.
Monitoring of access control systems.
Monitor and record restricted access transactions at entrances
to buildings and other areas
Verification of security alarms.
Intrusion alarms, exit door controls, hold-up alarms, etc.
Video patrol of public areas.
Transit stops, parking lots, public (enclosed and unenclosed)
streets, shopping areas, vehicle intersections, etc.
Criminal investigation.
Robbery, burglary, and theft surveillance
Protection of pedestrians.
Monitor pedestrian and vehicle traffic and vehicles in traffic
areas at intersections
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