Video Monitoring of College Premises Policy and Procedures

Philosophy and Scope
Definitions for the Purpose of this Policy and Procedures
Responsible Senior Leader and Responsible Office
Entities Affected by this Policy and Procedures
Responsibility and General Use
Procedures
Sanctions

I. Philosophy and Scope

Frederick Community College (“FCC” or the “College”) is committed to maintaining a safe and secure College community. A critical component of a comprehensive security plan is video monitoring. The primary purpose of video monitoring is to deter crime, and to assist the College in protecting the safety and security of the members of the College community, the College premises, and the physical assets of the College. The College does not video monitor classrooms, bathrooms, or private offices. However, classrooms and private offices may be video monitored at the request of the faculty member or
principal occupant with the approval of the Chief of Operations or as part of a law enforcement investigation.

Personnel will be designated and appropriately trained and supervised in the responsible use of video monitoring and recording equipment systems. Only designated personnel shall have access to the video monitoring and recording equipment and systems and are required to maintain confidentiality in accordance with applicable law.

This Policy and Procedures does not apply to mobile video equipment operated by law enforcement personnel, recordings required by court order or subpoena, and/or legitimate academic use of video cameras for educational purposes.

II. Definitions for the Purpose of this Policy and Procedures

“College community” refers to trustees, students, and all employees of the College as well as any independent contractors or other third parties to the extent articulated under contractual agreements.
“College premises” refers to buildings or grounds owned, leased, operated, controlled, supervised, or temporarily used by the College.
“CCTV” refers to closed circuit (non-broadcast) television video monitoring system utilizing an array of cameras and data recording servers.
“Designated Personnel” refers to the College employees authorized to view and maintain the video monitoring system or having approved access to view selected cameras and/or access to view recorded data.
“Temporary video cameras” refers to cameras that ARE not permanently installed by the College and can be temporarily deployed by designated Security personnel with appropriate authorization.
“Senior Leadership Team” refers to the President’s leadership group comprised of the President, the Provost/Executive Vice President for Academic Affairs, Continuing Education, and Workforce Development; the Vice President (VP) for Finance; the VP for Human Resources; the VP for Learning Support; the Chief of Operations; the Chief Information Officer; and the Special Assistant to the President for Institutional Effectiveness.
“Surveillance Center” refers to an area under control of the Director of College Safety, Security, and Emergency Preparedness in which live video footage/data from cameras can be monitored, and recorded video can be viewed.
“Video Media” refers to digital camera images obtained and recorded as digital files.

III. Responsible Senior Leader and Responsible Office

Chief of Operations
Operations

IV. Entities Affected by this Policy and Procedures

The College Community
All visitors, guests, and volunteers

V. Responsibility and General Use

Video monitoring will be conducted in a manner consistent with all existing College policies and procedures, including the Non-Discrimination Policy and Procedures and the Title IX Sexual Harassment Policy and Procedures. Monitoring individuals based on characteristics of race, gender, ethnicity, sexual orientation, disability, or other protected
classification is prohibited. Care and caution shall be taken by those authorized to view, monitor, or access images and information from video monitoring to ensure that the privacy rights of students, staff, and others are protected as required by the Family Educational Rights and Privacy Act (FERPA) guidelines and all local, state, and federal statutes.

All video equipment and media covered by this Policy and Procedures is considered property of FCC and is subject to this Policy and Procedures as well as policies, procedures, and standards of conduct set by FCC as well as applicable local, state, and federal laws.

The Director of College Safety, Security, and Emergency Preparedness is responsible for daily operations of the CCTV system and the Surveillance Center. Information obtained through video monitoring may be utilized for investigative, safety or security purposes, law enforcement, and compliance with College policies and procedures. Information recorded using video monitoring will only be released to non-College entities when authorized by the Chief of Operations.

The day-to-day supervision of video monitoring and the use of video recordings by College Security, Safety and Emergency Preparedness, and Testing Center personnel is delegated to the lead administrator in each area and is to be conducted in accordance with the following principles:

Signage will be posted where general video monitoring is in service;
Video monitoring of public areas at the College is limited to uses that do not violate the reasonable expectation to privacy as defined by law;
Video Media will be stored in a secure location with access by designated personnel only;
Temporary video cameras may only be used by College Security and the Director of College Safety, Security, and Emergency Preparedness to ensure the safety and security of the College community, with approval of the Chief of Operations;
The equipment used by the College will not possess the capability of recording sound at any time;
College personnel or the maintenance contractor authorized to use, access or maintain the video equipment are prohibited from copying, disseminating or using any information obtained through the video monitoring and recording equipment and systems except as delineated in this Policy and Procedures;
Approved College personnel or the maintenance contractor may not use, adjust or set the cameras to view personal activity except as is required for use in supporting suspicious activity and/or an investigation; and
Video monitoring will not be used to monitor staff performance but may be used to investigate reported violations of FCC policy as well as alleged acts of misconduct or violations of law.

VI. Procedures

Safety, Security, and Emergency Preparedness
1. The Director of College Safety, Security, and Emergency Preparedness is authorized to oversee and coordinate the daily use of video monitoring equipment for safety and security purposes at the College.
2. When directed by the President, the Director of College Safety, Security, and Emergency Preparedness is authorized to oversee and coordinate the use of video monitoring equipment for assigned investigations and in the event of an emergency.
3. The Chief of Operations is authorized to have access to the CCTV system for the purposes of monitoring or reviewing safety concerns, weather conditions, investigations, and other facility or grounds related emergencies.
4. Cameras are not constantly monitored by College Security employees except as notified to view an incident-in progress. CCTV system data is used primarily as a forensic tool of incident or criminal investigation.
5. All Security personnel involved in the video monitoring of public areas will perform their duties consistent with the policies and procedures of the College, and applicable laws.
6. Recorded video media for security purposes will be stored for a minimum period of 30 days.
7. Temporary video cameras may be placed in a specific location for a targeted concern, or upon request of the principal occupant with the approval of the Chief of Operations, in consultation with the appropriate Senior Leader.
8. Temporary video cameras will be placed in a specific location only with the knowledge and consent of the principal occupant unless the monitoring is part of an investigation and only with the approval of the President and the Chief of Operations.
Testing Center
1. The use of video monitoring in the Testing Center is to support the ability of the Testing Center staff to maintain academic integrity. Video monitoring provides support for proctoring students during exams. Video monitoring for security purposes and for proctoring of exams in the Testing Center will be conducted in a professional, ethical, and legal manner. Violations of academic integrity are addressed using the Code of Student Conduct Policy and Procedures.
2. The Director of the Testing Center is authorized to oversee and coordinate the daily use of video monitoring equipment for the Testing Center.
3. Recorded video media will be stored for a minimum period of 30 days. The use of recorded video media from the Testing Center for the purposes of College Safety, Security, and Emergency Preparedness must be approved by the Chief of Operations.
Access to CCTV Live Camera Feeds and/or Recorded Video Data
1. Requests to view live and/or recorded video data related to a specific incident by individuals other than designated employees must be made to the Director of College Safety, Security, and Emergency Preparedness and approved by the Chief of Operations.
2. Application for CCTV system access to view live camera feeds and/or recorded video data on an ongoing basis must be made to the Director of College Safety, Security, and Emergency Preparedness and approved by the Chief of Operations.
3. Access to live camera feeds or recorded video data in the Testing Center will be provided to vendors performing institutional services or functions as per contractual obligation.
4. There are limited College areas which are approved to access live video feeds at the main campus and Monroe Center. These include the bookstore, plant operations, and receiving. This is conducted in a professional and ethical manner for the protection of merchandise, to monitor weather/areas around campus, and for accessing live video feeds at the loading dock when deliveries arrive.
5. Copies of any recorded data in either motion video or still photo capture of events or persons, must be preapproved by the Chief of Operations.
6. A log of all requests for access to video media and live and/or recorded video data shall be maintained by the Director of College Safety, Security, and Emergency Preparedness.
7. Unauthorized access or disclosure of video media and live and/or recorded video data is prohibited.
8. Mobile and portable access to the College video monitoring system will be for incidental live monitoring only.
Camera Equipment Placement and Video Monitoring Software
1. Permanent placement of new cameras, or relocation of existing cameras, must be approved by the Chief of Operations, in consultation with the Senior Leadership Team.
2. Any programming modifications to the Video Monitoring software must be requested through the Director of College Safety, Security, and Emergency Preparedness and approved by the Chief of Operations.
3. Levels of administrative rights for access to the software and data storage server(s) will be assigned by the Chief of Operations.
4. The contractor may request remote access to the video software and video monitoring data server(s) from their company through the Director of College Safety, Security, and Emergency Preparedness and is subject to approval by the Chief Information Officer or their designee.

VII. Sanctions

FCC employees found in violation of this Policy and Procedures are subject to the Employee Code of Ethics and the Employee Misconduct Policy with disciplinary actions up to and including separation from employment
Contractor personnel found in violation of this policy will be reported to the company, denied access to the video monitoring system, and subject to legal action.