BACKGROUND The purpose of this policy is to regulate the use of closed circuit television (CCTV) systems that monitor and record public areas on campus to enhance safety, security, and emergency management.
SCOPE This policy applies to all employees, students, and visitors as well as academic and administrative units at the University of Alabama at Birmingham (UAB) and all facilities and grounds owned or leased by UAB.
This policy does not address the use of general-purpose web cameras for special interest applications or University promotion purposes, but it should be noted that such cameras must not be used as a substitute for a video surveillance or other security system. Legitimate use of video/audio capture, transmission, or recording related to teaching/testing, approved animal or human subject research, or patient care areas may be covered by other UAB policies and is therefore excluded from this policy.
DEFINITIONS CCTV: CCTV is a generic term used to describe a variety of video surveillance technologies. More specifically, CCTV refers to a system in which one or more video cameras are connected in a closed circuit or loop, with the images produced being sent to a central television monitor or recorded. As used in this policy, the term CCTV applies only to video recordings, not the electronic interception and/or recording of audio.
PUBLIC AREAS: Video surveillance is normally restricted to areas of general public access; it is not to be used to view or record workstations, including private offices, desks, or cubicles; classrooms or rooms not generally open to the public where students and/or faculty commonly work, study, or hold discussions; living areas; or other areas where a reasonable expectation of privacy exists. Exceptions may include areas where cashiering services are performed or money is stored/exchanged, as well as other areas containing valuable equipment or objects such as art collections and laboratories.
VIDEO SURVEILLANCE: Video surveillance is the use of image capture, processing, transmission, and storage equipment for authorized monitoring of public areas. This includes full-motion and still images, use of network transmission capacity, and digital storage and retrieval software.
POLICY STATEMENT UAB is committed to enhancing the quality of life on its campus by integrating the best practices of public and private policing, safety, and emergency management with state-of-the-art technology. A critical component of UAB’s approach to public safety is the use of CCTV.
General Principles The purpose of CCTV monitoring of public areas by police, security, emergency management teams, and other authorized employees is to deter crime, respond to emergencies, and assist in protecting the safety of persons and property within the University community. Examples include monitoring perimeters, entrances and exits, lobbies and corridors, receiving docks, reception areas, etc.; confirming security alarms; investigating crimes, such as robbery, burglary, theft, etc.; and protecting pedestrians and facilitating traffic plans.
Any diversion of security technologies and personnel for other purposes not related to safety, security, or emergency management is prohibited. Any person who tampers with or destroys a camera or any part of an electronic CCTV system may be prosecuted in the criminal justice system as well as subject to internal disciplinary processes.
Any video surveillance system or monitoring system not connected to the University’s main CCTV system is prohibited. Any system of this nature, when found, will be removed immediately, and the responsible party may be subject to disciplinary action. This does not include use of temporary CCTV equipment, such as mobile video equipment or covert surveillance cameras, by UAB Police for criminal investigations or under specific court order.
CCTV must be used in a professional, ethical, and legal manner that does not violate individuals' reasonable expectation of privacy as defined by law and consistent with all existing University policies, including, for example, the Equal Opportunity and Discriminatory Harassment Policy and Title IX Sexual Assault and Sexual Misconduct Policy. Fake or "dummy" cameras and/or signage falsely indicating CCTV coverage are also prohibited. Employees with access to CCTV equipment, systems and/or records must be aware of applicable laws, regulations, and/or policies and trained in the responsible use of CCTV.
Information obtained through CCTV is intended to be used for law enforcement, physical security, emergency management, as part of an official UAB investigation and/or in support of disciplinary proceedings against faculty, staff, or student(s), or in a risk management claim or civil suit whose activities are shown on the recording and are relevant to the suit. No release of recorded images will occur without authorization. Additionally, copying of video or interception of signals and/or images is prohibited.
Video monitoring of public areas for security and emergency purposes is conducted in a manner consistent with all existing University policies, including, for example, the Equal Opportunity and Non-Discrimination Policy and Title IX Sexual Assault and Sexual Misconduct Policy.
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.
Division of UAB Police and Public Safety The Division of UAB Police and Public Safety is responsible for overseeing and coordinating the use of CCTV at UAB. The division maintains a master inventory and associated documentation of all existing and approved CCTV, equipment, and access authorizations.
The Associate Vice President of UAB Police and Public Safety authorizes all CCTV monitoring for safety, security, and emergency management purposes at UAB. All new and existing installations must follow the Division of UAB Police and Public Safety operating procedures.
The Division of UAB Police and Public Safety must store CCTV records in a secure location and configured in a manner to prevent unauthorized access, modification, duplication, or destruction. CCTV records will be kept for no longer than thirty (30) days unless requested in writing by the Office of Counsel, Risk Management, Human Resources, or Compliance & Risk Assurance, and they shall be erased or destroyed in a secure manner as soon as the retention period expires, unless retained as part of a criminal investigation, court proceedings (criminal or civil), or other bona fide use as approved by the Associate Vice President for Police and Public Safety and the CCTV Oversight Committee. The division shall receive, document, and store the written preservation request and ensure the preservation occurs in an efficient and effective manner.
To maintain an informed University community, the Division of UAB Police and Public Safety makes information on the purpose of CCTV monitoring and operating procedures available through the safety page (uab.edu/safety-resources) on the UAB Police and Public Safety website (uab.edu/police).
The Division of UAB Police and Public Safety monitors new developments in the relevant law and in security industry practices to ensure that CCTV monitoring at UAB is consistent with the highest standards and protections.
CCTV Oversight Committee The CCTV Oversight Committee (The Committee) is comprised of:
· Associate Vice President of UAB Police and Public Safety
· Deputy Chief of UAB Police and Public Safety
· Director of Emergency Management
· Emergency Management Coordinator
· Director of Physical Security
· Assistant Vice President for Public Relations
· Senior Director of Insurance and Risk Finance
The Committee reviews camera locations to ensure the perimeter view of cameras conforms to this policy. Individuals entering certain sensitive locations on campus may have an increased concern for privacy or confidentiality. Concerned persons may petition the Committee to forgo the installation of a proposed camera or to remove an existing camera. The 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 certain areas of residence halls, such as common lounge areas, the Committee will determine if there is a specific safety or security risk and the appropriateness of CCTV monitoring.
The Committee reviews this policy annually and recommends revisions, if needed.
UAB Academic and Administrative Units
All units using CCTV monitoring are responsible for implementing this policy in their respective facilities. The CCTV Oversight Committee works with employees within academic and administrative units who have responsibility for facilities management, building administration, and/or technology support to ensure overall safety, security, and emergency management goals for CCTV systems within those facilities are met.
Employees and students without facilities management, building administration, and/or technology support responsibilities must not have access to recorded videos unless specifically authorized.
NONCOMPLIANCE Unauthorized access to, inadequate protection of, and inappropriate use, disclosure, and/or disposal of CCTV systems or records must be reported immediately to the Associate Vice President for Police and Public Safety. Confirmed violations of this policy are subject to commensurate consequences, up to and including termination, dismissal, or severance of relationships with UAB.
IMPLEMENTATION The Associate Vice President/Chief of Police and Public Safety is responsible for procedures to implement this policy.