Policy: 4.19 Video and Closed-Circuit Television (CCTV) Monitoring

Business and Operating Policies and Procedures

Adoption Date: June 23, 2021 Revised

The purpose of this policy is to regulate the use of video recording and Closed-Circuit Television (CCTV) security systems so that safety and security is enhanced while respecting the privacy rights of the College community and the public and maintaining compliance with all applicable laws and policies. This policy applies to all personnel with respect to the installation and use of video security and CCTV cameras, except as noted below, in facilities owned or controlled by the College.

All references to video security and CCTV systems throughout this policy are for those systems which were designed and installed with the intent and ability to record video and/or be monitored for purposes of enhancing campus safety and physical facility security.

Exclusions

This policy does not apply to:

Use of video recording and CCTV technology for video conferencing.
Use of class lecture recordings and/or archiving for the purpose of content sharing.

A. GENERAL PRINCIPLES

1. Howard College and Campus Security are committed to enhancing the quality of life of the campus community by integrating the best practices of campus safety with state-of-the-art technology. A critical component of a comprehensive security program is the use of video recording and CCTV.

2. Any interception, duplication, transmission, or other diversion of video and CCTV technologies for purposes other than safety and security contemplated by this policy is generally prohibited. Safety and security purposes include, but are not limited to:

Protection of individuals, including students, faculty, staff, and visitors.
Protection of college owned and/or property and buildings, including building perimeters, entrances and exits, lobbies and corridors, receiving docks, special storage areas, laboratories, and cashier locations.
Monitoring of common areas and areas accessible to the public, including parking lots, public streets, and pedestrian walks.
Investigation of criminal activity, and/or employee/student conduct.
Protection against an act of terrorism or related criminal activity.
Protection of Critical Infrastructure as defined under the Texas Homeland Security Act, the USA Patriot Act, or the United States Department of Homeland Security.

3. Information obtained via video and CCTV monitoring will be used for safety/security, and law enforcement purposes, however, it may also be used for student/employee investigations when there is reasonable cause to do so.

4. Video and CCTV monitoring of public areas for security purposes will be conducted in a professional, ethical, and legal manner consistent with existing College policies.

5. Monitoring shall be limited to uses that do not violate a reasonable expectation to privacy.

6. Monitoring individuals based on characteristics of race, gender, ethnicity, sexual orientation, disability, or other protected classifications is prohibited.

7. Monitoring will be based on suspicious behavior, not individual characteristics.

8. Video and CCTV monitoring of public areas is limited to uses that do not violate the reasonable expectation of privacy as defined by law.

9. Images and any related data collected by video recording or CCTV are the property of Howard College.

B. RESPONSIBILITIES

1. The Chief Operations and Safety Security Officer and the President of the College are authorized to access all video/CCTV monitoring to enhance and maintain safety and security at Howard College.

2. The four user roles listed below identify those authorized to the video/CCTV security system and the system functions each role is provided.

Administrative User: President of the College, Chief Operations and Safety Security Officer, Chief Technology Systems/Data Security Officer, and College Information Technology Department Directors. Full system access, to include access of all district cameras, ability to make system changes and create new user accounts.
Power User: Howard College Campus Security. Able to access live footage, recordings, adjust camera view settings, to include access of all district cameras, and provide recorded video to law enforcement in consultation with Chief Operations and Safety Security Officer.
Restricted User: Contract Security, Judicial Officers, Coordinators of Residence Education, Assistant Coordinators of Residence Education, Director of Childcare Center, Assistant to Childcare Director, and Executive Dean of the Lamesa Campus. Able to access live footage, recordings, but no access to system settings. Includes camera access to respective campus, building, or department.
Standard User: Camera Monitors, Lamesa Dual Credit Advisor/Lamesa Site Assistant, Lamesa Site Assistant, Coordinators of Testing. Able to access live footage only, and no access to system settings. Includes camera access to respective campus, building, or department.

3. Camera users will be trained by the Chief Operations and Safety Security Officer and/or the Chief Technology Systems/Data Security Officer in the technical, legal, and ethical parameters of the appropriate camera use. Camera users will receive a copy of this policy and provide written acknowledgment that they have read and understood its contents. The Chief Technology Systems/Data Security Officer will be notified by the Chief Operations and Safety Security officer when each individual camera user has completed such training to develop a user account and grant access to the video/CCTV security system.

4. Campus Security will monitor new developments in the law and industry standards and protections.

C. PROCEDURES

1. The Chief Operations and Safety Security Officer is authorized to oversee and coordinate the use of video and CCTV monitoring equipment at Howard College.

2. All approved individuals involved in video and CCTV monitoring will perform their duties consistent with policies developed by Howard College.

3. Approved individuals involved in video and CCTV monitoring shall not share their user account information nor

4. Howard College may post signage as appropriate indicating that CCTV equipment is in use.

5. CCTV camera positions and views of residential housing may be limited, however, the use of video and CCTV systems in those areas are a necessity for the preservation and protection of college-owned property and assets. Any view given of housing areas will be similar to what is available with unaided vision. Furthermore, any CCTV view must not violate the standard of “a reasonable expectation of privacy.”

6. The CCTV monitoring locations will be configured so as to prevent the tampering with or unauthorized duplication of information.

7. Recorded video images will be stored for as long as storage capacity will allow or as allowed by law, unless retained as part of a criminal investigation or court proceedings (internal, civil and criminal), or other bona fide use as approved by the Chief Operations and Safety Security Officer or the President of the College, in which case it will be retained as appropriate and as needed. Recorded images will be stored in a secure location with access by authorized personnel only. Those recorded devices which are no longer needed for criminal justice or administrative purposes will be destroyed or electronically erased.

8. Video Media will be stored on a secure server with access only by authorized personnel.

9. Individuals authorized to access video/CCTV images while on campus may also access this data with portable smart devices as approved by the Chief Operations and Safety Security Officer or the President of the College.

10. Departmental video/CCTV systems must be approved by the Chief Operations and Safety Security Officer, in consultation with the President of the College. Approved departmental video/CCTV systems will be governed by this policy.

D. Requests for Information Obtained from Monitoring Systems

1. Information relating to ongoing criminal investigations and anti-terrorism must only be released when approved by the Chief Operations and Safety Security Officer, in consultation with the President of the College.

2. Open Records Requests for recorded video must be forwarded to the Chief Operations and Safety Security Officer.

3. Lawful requests (e.g., subpoenas, search warrants) for recorded video must be forwarded to the Chief Operations and Safety Security Officer, then be in consultation with the President of the College.

4. Internal requests for copies and/or information of video recording must be forwarded by a Cabinet Member to the Chief Operations and Safety Security Officer by official memo or other official documentation. Records of this documentation will be maintained by the Chief Operations and Safety Security Officer.

5. The President of the College may delegate certain authorities as needed.

E. Documentation from Camera Users

1. Any incident that is supported or initiated by video/CCTV will be documented.

2. In the record of the incident, the operator will enter:

That CCTV was used on the incident.
The specific camera/s used.
Any pertinent information gathered by CCTV