UPPS 05.04.05 - Video Documentation and Surveillance Systems
Video Documentation and Surveillance Systems
UPPS No. 05.04.05
Issue No. 3
Effective Date: 2/21/2020
Next Review Date: 7/01/2022 (E2Y)
Sr. Reviewer: Director, Network Operations and Director, University Police Department
The purpose of this policy is to regulate the installation and use of video documentation and surveillance (VDS) systems designed to allow observation and recording from cameras installed on Texas State University property. This policy does not imply or guarantee that the university will monitor cameras 24 hours a day, seven days a week. Cameras are not a guarantee of safety, but are tools that assist the university in overall security, serve as a deterrent against crimes and inappropriate or unlawful activity, as well as provide information to assist with incident investigations.
This policy applies to all students, faculty, staff, departments, schools, colleges, and divisions in the use of VDS systems. This policy applies to all forms of VDS, regardless of the technology employed, including closed circuit television (CCTV), internet-based (web) camera systems, and cameras used for academic, business, or informational purposes. The viewing, recording, reviewing, and releasing of any data will be in compliance with all federal and state laws governing the release of information in compliance with the Texas Public Information Act.
Technology Resources operates and maintains a centralized VDS system on behalf of University Police Department (UPD) for the purpose of recording cameras that UPD determines are relevant to the security of persons or property on campus.
The sole purpose of academic cameras is viewing and recording academic activities, and they are not attached to the centralized VDS system. The sole purpose of business cameras is viewing and recording business activities, and attachment to the centralized VDS system is required. Cameras not deemed by UPD to be essential to overall university security will be the financial responsibility of the requesting department.
Application of this policy to cameras used for legitimate academic purposes will comply with UPPS No. 02.02.03, Protection of Human Research Subjects. Camera systems installed expressly and specifically to enable teleconferencing among willing and fully informed participants are exempt from this policy.
VDS operations will be conducted in a professional, ethical, and legal manner following appropriate training and with supervision in the responsible use of this technology. Violations of the VDS Code of Procedures (as defined in Section 05.) may result in disciplinary action consistent with the rules and regulations that govern the behavior of the involved parties.
Video Documentation and Surveillance (VDS) Systems – the continuous or periodic observation or recording of campus activity to detect, deter, or obtain evidence of criminal or otherwise prohibited behavior. The university may also use VDS to observe and record academic, business, or informational activities if this function and use is consistent with this policy.
Covert Video – VDS conducted in secret with no visible evidence or warning of monitoring or recording activities. All video cameras are subject to covert use as described in Section 05.07 of this policy.
Video Surveillance Operator – any individual approved by the director of UPD to view or control a VDS camera, or to view or control the data captured by a VDS system.
Academic Activities – those teaching, learning, and assessment functions involved in the expansion or transfer of knowledge between or among students and faculty.
Business Activities – direct interactions between the university and its students, faculty, staff, alumni, and other constituencies, exclusive of academic activities.
Informational Video – video taken for the purpose of providing information to the campus community (e.g., livestreams of public locations or to monitor available parking locations).
Texas State is committed to enhancing the campus quality of life by integrating the best practices of public and private policing with state-of-the-art technology. VDS systems are a critical component of a comprehensive security plan using state-of-the-art technology.
The primary purpose of an integrated centralized VDS system is to deter crime and to assist the police in protecting the property of the university community and access to facilities and services.
The university will only release information obtained through VDS systems when authorized by the director of UPD following steps established in this policy.
Existing university policies, including policies related to non-discrimination, will govern VDS of public areas. The VDS Code of Procedures prohibits documentation based on the characteristics and classifications contained in these policies.
VDS of public areas will not violate the reasonable expectation to privacy as defined by law.
The university will only use VDS to observe or record activities in campus areas as necessary to protect significant university interests as stated in UPPS No. 07.04.05, Assembly Activities Involving Amplified Sound, Exhibits, and Erecting Symbolic Structures.
VDS of academic activities requires prior review by UPD and prior approval by the provost and vice president for Academic Affairs (VPAA) and the vice president for Finance and Support Services (VPFSS).
UPD is authorized to oversee and coordinate all university VDS uses. All university organizations that utilize VDS are responsible for implementing this policy in their respective operations. UPD has primary responsibility for disseminating the policy and assisting other units in implementing policy and procedures.
The director of UPD is responsible for authorizing all VDS at the university. All new installations and changes to existing camera systems must adhere to this policy and the university’s network, hardware, or software requirements for VDS systems.
UPD will monitor new developments in the relevant law and in security industry practices to ensure that the university’s policies and practices relating to VDS systems are consistent with the highest standards, protections, and requirements of all federal, state, and local laws, The Texas State University System (TSUS) Rules and Regulations, and campus policies.
Network Operations must receive new requests for installations and changes to existing cameras connected to the centralized VDS using the Request for Video Surveillance Devices form prior to equipment purchase and installation. UPD will classify the proposed VDS camera location according to the criteria outlined in VDS Camera Installation Criteria. The proposed location of all VDS cameras must be consistent with the criteria outlined in VDS Camera Installation Criteria. The requesting department’s chair, the provost and VPAA, and the VPFSS must also approve academic activity cameras utilizing the centralized VDS system.
Consistent with UPPS No. 05.02.06, Acquisition of Information Technology Products and Services, and UPPS No. 04.01.05, Network Use Policy, the procurement and implementation of VDS systems shall be registered and assessed by the Information Security Office to ensure compliance with state and university standards and best practices.
UPD will perform reviews of proposed permanent surveillance camera installations to ensure they conform to the university’s established policies, practices, and implementation criteria. The director of UPD will submit recommendations to the VPFSS for their consideration in determining the appropriateness of the proposed installations.
UPD will maintain a list as provided by Network Operations, of all VDS camera locations, including a general description of the technology employed and the capabilities of the camera at each location. Information pertaining to camera location, camera view, camera models, visual capabilities, camera network infrastructure, planned tactical use, and camera and software configuration is confidential. This information is controlled, handled, transmitted, distributed, and disposed of according to the university’s information management and disclosure policies, and the director of UPD must approve release to the public or other personnel who do not have a valid “need to know.”
Students and staff entering certain sensitive locations on campus may have an increased concern for privacy or confidentiality. Persons having concerns related to these issues may petition the director of UPD to review installation of a proposed camera or for the removal of an existing camera. The director of UPD will consider the requesting person’s concerns, the provisions of the established criteria (see VDS Camera Installation Criteria), and the need for documentation at that location when reviewing a complaint.
The director of UPD, or designee, will evaluate the camera location’s circumstances and history to determine whether the benefit to and enhancement of community security outweighs the complaint. The VPFSS will review any appeals to the director of UPD’s, or designee’s, decision. The VPFSS’s decision is final.
The permanent removal of a centralized VDS camera requires approval by the vice president over the department served by the camera and the VPFSS.
The director of UPD, or designee, will review all requests to release VDS systems recordings. No releases will occur without the authorization of the director of UPD, or designee, as provided for in this policy.
VIDEO DOCUMENTATION AND SURVEILLANCE (VDS) CODE OF PROCEDURES
All persons involved in VDS will perform their duties in accordance with this policy.
The university will configure documentation systems to prevent camera operators from tampering with or duplicating recorded information.
The university will store recorded video for 30 days and then erase it, unless retained as part of a criminal investigation or court proceedings (criminal or civil), or other bona fide uses as approved by the director of UPD.
The university will store video media in a secure location with access by authorized personnel only.
Video surveillance operators who are granted access to archived recorded video must access footage in a manner to maintain the integrity of that video footage.
Video surveillance operators will monitor individuals solely based on suspicious activities or behavior, not individual characteristics protected by the university’s non-discrimination policies (race, color, national origin, age, sex, religion, disability, veterans’ status, sexual orientation, gender identity, or gender expression).
UPD will only use covert VDS for criminal investigation with the director of UPD’s approval. The VPFSS will receive notification of all covert VDS operations prior to or as soon as possible after deployment.
VDS is limited to uses that do not violate the reasonable expectation to privacy as defined by law.
PROCEDURES FOR ACCESS TO LIVE OR RECORDED VIDEO FOOTAGE OR IMAGES BY UNIVERSITY FACULTY AND STAFF
The director of UPD, or designee, may grant permission to UPD personnel to view or control a video camera, or to view the data captured by a VDS system. All other persons must request permission in writing from the director of UPD stating the reason for and intended use of the requested data.
If access is granted to recorded footage by the director of UPD, the director, or designee, will coordinate with the requestor to allow the requestor to view the requested footage or images.
Video footage from VDS systems shall not be released, transferred, converted to alternate media, or otherwise provided to any person without the prior written permission of the director of UPD. VDS footage containing images of all or part of any campus expression area shall not be released, transferred, converted to alternate media, or otherwise provided to any person without prior written permission from the VPFSS and the vice chancellor and general counsel of the TSUS.
Consistent with other provisions of this policy, the director of UPD may authorize extended access to the live or recorded images of academic activities, business activities, or for informational purposes to persons having oversight responsibility for those activities. This use of the extended access to live or recorded images is limited to academic, business, or informational purposes.
PROCEDURE FOR RELEASE OF RECORDED VIDEO FOOTAGE OUTSIDE THE UNIVERSITY
- Any release of recorded video footage outside the university must have the prior approval of the director of UPD.
UPD will manage transferred recordings from the VDS in accordance with state and federal laws pertaining to evidence handling and storage.
Access to recordings maintained for evidence purposes as described in this policy will only be allowed as provided by applicable law, including the Texas Public Information Act.
The director of UPD, or designee, may release VDS footage and images to law enforcement agencies sharing jurisdiction with UPD.
REVIEWERS OF THIS UPPS
Reviewers of this UPPS include the following:
Position Date Director, University Police Department July 1 E2Y Director of Network Operations July 1 E2Y Associate Vice President, Facilities July 1 E2Y
This UPPS has been approved by the following individuals in their official capacities and represents Texas State policy and procedure from the date of this document until superseded.
Director, University Police; co-senior reviewer of this UPPS
Director, Network Operations; co-senior reviewer of this UPPS
Associate Vice President for Technology Resources
Vice President for Information Technology
Vice President for Finance and Support Services