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POLICY 08:13:11

USE AND INSTALLATION OF VIDEO SURVEILLANCE EQUIPMENT

Purpose
To enhance security and personal safety at Pellissippi State Community College, it has been determined that the use of video surveillance equipment may prevent losses and aid in the law enforcement activities of the Pellissippi State Police Department (PSPD). This policy has been written to standardize procedures for the installation of this type of equipment and the handling, viewing, retention, and destruction of recorded and digital media and to ensure the protection of individual privacy rights in accordance with the law. Appropriate measures to protect individual privacy in the course of video surveillance of non-public areas of the campus will be determined on a case-by-case basis.

Scope and Applicability

This policy applies to all individuals who install video surveillance equipment and who access, use, or manage the equipment and the media recorded by the systems.

Definitions

Video Surveillance: any video surveillance technology (video cameras, closed circuit television camera; still frame cameras; digital cameras; and time-lapse) that enables continuous or periodic viewing or monitoring of public areas.

Surveillance Media: any recordings provided by video surveillance equipment and technology. Examples include videotapes, photographs, or digital media.

Policy

Under no circumstances shall the contents of any captured video recordings be exploited for purposes of profit or commercial publication, nor shall recordings be publicly distributed except as may be required by law.

Video surveillance equipment at the college will be installed:

  1. To assist in efforts to maintain personal safety of students, faculty, staff, and other users of college premises.
  2. To assist with the application of college policies with regard to college property and the property of others.
  3. To provide a visual deterrent to crime.
  4. To increase the likelihood of identification of person(s) who may breach college policies and/or commit crimes.
  5. To assist in protecting assets on campus.

Permanently Installed Equipment
The Facilities Department in conjunction with the Network and Technical Services Department will operate and maintain the main video surveillance system for the campuses, as part of their responsibility for providing a safe and secure environment for all persons on the campus as well as protecting college and personal property.
From time to time and for various reasons, it may be appropriate to permanently install video devices in other areas of the campus (for example, for the surveillance of VPT equipment rooms, computer labs, or other areas where such devices may enhance campus security). In such cases, the following rules will apply:

  1. Individual departments, programs, or campus organizations wishing to permanently install video surveillance equipment shall submit a request to the Director of Facilities, with a statement justifying the benefit of installing surveillance equipment. The statement must include the proposed location of the surveillance device(s), location of the monitor, location of secure storage of recorded media, and the retention schedule for recorded media. The source of funding for the installation must be specifically identified as part of the request.
  2. The Director of Facilities will forward the request along with their recommendation to the Vice President of Administrative Affairs and the Vice President of Academic Affairs for their approval.
  3. Once approved, installation of the system will be coordinated through the Facilities department.
  4. The Pellissippi State Police Department will have access to all real-time and recorded images resulting from video surveillance installations. The individual department, program, or campus organization that has approved video surveillance equipment in use, will be required to allow review of the recorded media at any time by the Chief of Police (or designee).
  5. All pre-existing permanently installed video surveillance equipment on campus must conform to this policy.

Temporary Installation of Video Surveillance Equipment
From time to time and for various reasons, it may be appropriate to temporarily install video devices on campus (for example, in the course of investigations in areas of the campus where thefts or breaches of security have been noted). To ensure individual privacy rights are protected in accordance with the law during the temporary installation of surveillance equipment, the installation of the equipment will require the approval of the Director of Facilities. The same rules regarding privacy and the use of the recorded images for permanently installed systems will also apply to temporary applications of video surveillance equipment.
To the extent possible, the Facilities Department will coordinate the use of temporary video surveillance equipment with the designated users of the space involved. This policy acknowledges, however, that this may not always be possible, given the nature of investigations that may be undertaken.
No video surveillance equipment may be temporarily installed on campus unless approved by the college president or designee.

Viewing of Recorded Media
Only authorized employees may review surveillance media. The list of authorized employees will be maintained by the Chief of Police. Other individuals who may have a legitimate need to review the recorded material may be permitted to do so, but only with the prior approval of the Chief of Police. The following two special circumstances may be noted regarding recorded media:

  1. If it is determined that a crime has occurred in an area where video recording may have taken place, then the recorded media shall be reviewed by authorized members of the Pellissippi State Police Department to determine if the incident has actually been recorded. If it is determined that the media does contain evidence of a crime, then that media will be maintained and made available to responding law enforcement.
  2. If it is determined that an accident has occurred in an area subject to video surveillance, then the recorded media shall be reviewed by authorized members of the Pellissippi State Police Department to determine if it contains evidence. If it is determined to contain such evidence, then the media will be maintained according to appropriate procedures.

Retention Period for Recorded Media
The results of video surveillance activities shall be maintained for a reasonable period that will allow sufficient time for the public to report a crime or an accident (which is minimally defined herein as thirty working days).
Digital surveillance media will be stored and secured as follows:

    • Digital files will be saved in accordance with records retention policies of the Tennessee Board of Regents and applicable state and federal laws unless required for a continuing investigation, after which overwriting will occur.
    • Any information saved on physical media, such as hard drives or compact discs as per above, will be destroyed by Network and Technical Services staff or the Pellissippi State Police Department after the conclusion of any investigations and proceedings related to the recorded event or in accordance with records retention policies of the Tennessee Board of Regents and applicable state and federal laws
    • Digital servers will be located in secured areas where access is minimal and restricted to authorized staff.
    • All recorded media must be stored in a secure location, the nature of which must be identified as part of the approval process.

FERPA and the Use of Video Surveillance
For FERPA purposes, surveillance media with information about a specific student are considered education records if they are kept and maintained by the school system. If the school’s law enforcement unit controls the cameras/videos and it is doing the surveillance for safety reasons, the ensuing videos would be considered law enforcement, rather than education, records. As soon as school officials use them for discipline purposes, however, the tapes become education records and are subject to FERPA requirements.
When created and kept by the school or education agency, videotapes, media files, or photographs directly related to a specific student are considered part of that student’s education records and, therefore, subject to FERPA. For instance, if the tape captured an altercation, it would be included in the involved students’ education record, and the school must obtain consent before publishing or disclosing its contents to unauthorized individuals.
Source: National Forum on Education Statistics. (2006). Forum Guide to the Privacy of Student Information: A Resource for Schools (NFES 2006–805). U.S. Department of Education. Washington, DC: National Center for Education Statistics.

Reviewed/Recommended: President’s Staff, August 7, 2007
Approved: President Allen G. Edwards, August 7, 2007
Editorial Changes, July 2008, July 1, 2009
Reviewed/Recommended: President’s Council, March 25, 2013
Approved: President L. Anthony Wise, Jr., March 25, 2013
Reviewed/Recommended: President’s Council, May 23, 2022
Approved: President L. Anthony Wise Jr., May 23, 2022