South Plains College is committed to enhancing the quality of life of the campus community by integrating the best practices of safety and security with technology. A critical component of a comprehensive security plan is the utilization of a security and safety camera system. The surveillance of public areas is intended to deter crime and assist in protecting the safety and assets (i.e., people, equipment, and real properties) of the South Plains College community. This policy addresses the College's safety and security needs while respecting and preserving individual privacy.
To ensure the protection of individual privacy rights in accordance with the College'smission, vision, values, and state and federal laws, this policy is adopted to formalize procedures for the installation of surveillance equipment and the handling, viewing, retention, dissemination, and destruction of surveillance record. This Policy adheres to the following laws:
- U.S. Const. amend. IV
- 18 U.S.C. § 2511 - Electronic Communication Privacy Act of 1986(ECPA) *
- 5 U.S.C. § 552a - Privacy Act of 1974]
- Texas Penal Code § 16.02 - State Wiretap Act;
- Texas Penal Code § 16.04.- Stored Communications Act (SCA)
- Texas Penal. Code § 42.072. – Stalking
The purpose of this policy is to regulate the use of camera systems used to observe and record public areas for the purposes of safety and security. The existence of this policy does not imply or guarantee that cameras will be monitored in real time 24 hours a day, seven days a week.
The South Plains College Police Department (SPCPD), the Dean of Students and the Information Services Campus Security Analysist (ISCSA) jointly have the authority to select, coordinate, operate, manage, and monitor all campus security surveillance systems pursuant to this policy. All departments using camera surveillance are responsible for implementing and complying with this policy in their respective operations.
All existing uses of security camera systems will be required to comply with the policy.
Any person who tampers with or destroys video security equipment will be subject to criminal prosecution and/or College judicial action.
SPCPD, in conjunction with Dean of Students and the ISCSA is responsible for realization and assimilation of the policy.
The Dean of Students, the SPCPD, and the ISCSA are responsible for advising departments on appropriate applications of surveillance technologies and for providing technical assistance to departments preparing proposals for the purchase and installation of security camera systems.
SPCPD, the Dean of Students, and the ISCSA shall monitor developments in the law and in security industry practices and technology to ensure that camera surveillance is consistent with the best practices and complies with all federal and state laws.
SPCPD, the Dean of Students, and the ISCSA will jointly review proposals and recommendations for camera installations and review specific camera locations to determine that the perimeter of view of fixed location cameras conforms to this policy. Proposals for the installation of surveillance cameras shall be reviewed by the Chief of Police, the Dean of Students, and the ISCSA. Recommendations shall be forwarded to the Vice President for Student Affairs.
SPCPD, the Dean of Students, and the ISCSA will jointly assess new camera locations. A bi- annual evaluation of existing camera locations will be conducted. An annual review of incidents will be conducted during the federal reporting period for campus crime statistics
Maintenance and testing will be the responsibility of the SPCPD and the ISCSA.
SPCPD will review any complaints regarding the utilization of surveillance camera systems and determine whether this policy is being followed. Appeals of a decision made by the Chief of Police will be made to and reviewed by the Dean of Students who will render a decision. Any appeals to the decision should be taken to the Vice President for Student Affairs, who will act as the final arbiter.
1.1.1 Responsibilities of the Information Services Campus Security Analyst
The Campus Security Analyst (ISCSA) will be responsible for reviewing the hardware and software support required on the South Plains College network. The ISCSA will review costs of equipment, contract with vendors for installation of network cables, electricity, and purchase of cameras and supporting hardware. The ISCSA will work closely with the Dean of Students and the SPC Chief of Police during the bi-annual review of existing camera locations.
1.1.2 Responsibilities of the Dean of Students
The Dean of Students will be responsible for reviewing and approving or denying all proposals for security camera equipment recommended by the Chief of Police. The Dean of Students shall be responsible for the review and approval of any requested exceptions to this policy. The Dean of Students shall propose to the Vice President for Student Affairs appropriate changes to this policy as needed.
1.1.3 Responsibilities of the Vice President for Student Affairs
The Vice President for Student Affairs will review all external requests to release records obtained through security camera surveillance. The Vice President for Student Affairs will seek consultation and advice from College Legal Counsel related to these requests prior to the release of any records.
This policy applies to all personnel and departments of South Plains College in the use of security cameras and their video monitoring and recording systems. Security cameras may be installed in situations and places where the security and safety of either property or persons would be enhanced. Cameras will be limited to uses that do not violate the reasonable expectation of privacy as defined by law. Where appropriate, the cameras may be placed campus-wide, inside and outside buildings. Although the physical cameras may be identical, the functions of these cameras fall into three main categories:
- Property Protection: Where the main intent is to capture video and store it on a remote device so that if property is reported stolen or damaged, the video may show the perpetrator. Examples: an unstaffed computer lab, an unstaffed science lab, or a parking lot.
- Personal Safety: Where the main intent is to capture video and store it on a remote device so that if a person is assaulted, the video may show the perpetrator. Examples: a public walkway, or a parking lot.
- Extended Responsibility: Where the main intent is to have the live video stream in one area monitored by an employee in close proximity. In this case video may or may not be recorded. Example: a computer lab with multiple rooms and only one employee.
1.3 GENERAL PRINCIPLES
Information obtained from the cameras shall be used for safety and security purposes and for law and policy enforcement, including, where appropriate, student judicial functions. Information must be handled with an appropriate level of security to protect against unauthorized access, alteration, or disclosure.
All appropriate measures will be taken to protect an individual's right to privacy and hold College information securely through its creation, storage, transmission, use, and deletion.
All camera installations are subject to federal and state laws.
Departments requesting security cameras will be required to follow the procedures outlinedin area 3 – Procedures ofthis policy.
Any installed cameras that are equipped with the capacity for audio detection must be approved by the Vice President for Student Affairs. Exclusions to this regulation are audio detection for classrooms and simulation labs as approved by the Vice President for Academic Affairs.
1.3.1 Placement of Cameras
The locations where cameras are installed may be restricted access sites such as a departmental computer lab; however, these locations are not places where a person has a reasonable expectation of privacy. Cameras will be located so that personal privacy is maximized.
No audio shall be recorded except in areas where no one is routinely permitted. Requests to utilize audio surveillance that does not comply with this requirement will be evaluated on a case by case basis by the Dean of Students.
Camera positions and views of residential housing shall be limited. The view of a residential housing facility must not violate the standard of a reasonable expectation of privacy.
Unless the camera is being used for criminal investigations, monitoring by security cameras in the following interior locations are considered exclusionary zones:
- Classrooms, with exclusion of requests from faculty regarding labs such as allied health where recording of simulation clinical are required and public computer labs.
- Locker rooms
- Athletic team meeting rooms (lower Texan Dome areas)
- Faculty offices (interior of the office only)
- Health and wellness personnel offices and clinical rooms
- Personnel offices (other than those dealing directly with cash/monetary transactions)
- Dorm rooms and dorm suite common areas
The following would be considered exclusionary zones for exterior coverage:
- Cameras angled in such a way to directly view private property (e.g., residential backyards, etc.)
The installation of fake/mock/intentionally non-functioning cameras is prohibited.
Unless being used for criminal investigations, all video camera installations should be visible.
18.104.22.168 Interior Camera Coverage
Interior cameras should maximize coverage in all high traffic public areas including:
- All hallways (including hallways that lead only to faculty offices)
- Public gathering areas
- All testing labs/rooms
- Offices that deal with cash/monetary transactions (from the student/constituent and the employee line of site)
- Business office safe and storage areas
22.214.171.124 Exterior Camera Coverage
Exterior cameras should maximize coverage of exterior assets including:
- All entrances including doors and gates.
- Parking lot, maximized coverage
- Isolated/dark areas
1.3.2 Access and Monitoring
All recording or monitoring of activities of individuals or groups by College security cameras will be conducted in a manner consistent with College policies, state and federal laws, and will not be based on the subjects' personal characteristics, including age, color, disability, gender, national origin, race, religion, sexual orientation, or other protected characteristics. Furthermore, all recording or monitoring will be conducted in a professional, ethical, and legal manner. All personnel with access to College security cameras should be trained in the effective, legal, and ethical use of monitoring equipment.
College security cameras are not monitored continuously under normal operating conditions but may be monitored for legitimate safety and security purposes that include, but are not limited to, the following: high risk areas, restricted access areas/locations, in response to an alarm, special events, and specific investigations authorized by the Chief of Police or Dean of Students.
For personal safety and protection of property cameras, access to live video or recorded video from cameras shall be limited to authorized personnel of the department which installed the cameras, the Police Department and other persons authorized by the Chief of Police or the Dean of Students. The copying, duplicating and/or retransmission of live or recorded video shall be limited to persons authorized by the Chief of Police or Dean of Students.
A record log will be kept of all instances of access to, and use of, recorded material. Nothing in this section is intended to limit the authority of the South Plains College Police Department (SPCPD) in law enforcement activities.
Upon termination of employment, camera operator access privileges are withdrawn within 24 hours of last day with the College.
1.3.3 Appropriate Use and Confidentiality
Personnel are prohibited from using or disseminating information acquired from College security cameras, except for official purposes. All information and/or observations made in the use of security cameras are considered confidential and can only be used for official College and law enforcement purposes. Personnel are expected to know and follow SPC Policy HV – Data Governance Policy.
1.3.4 Use of Cameras for Criminal Investigations
The use of mobile or hidden video equipment may be used in criminal investigations by the SPCPD. Covert video equipment may also be used for non-criminal investigations of specific instances which may be a significant risk to public safety, security and property as authorized by the Chief of Police or the Dean of Students.
This policy does not apply to cameras used for academic purposes. Cameras that are used for research would be governed by other policies involving human subjects and are, therefore, excluded from this policy.
This policy does not address the use of Webcams for general use by the College (e.g., on the official South Plains College website). This policy also does not apply to the use of video equipment for the recording of public performances or events, interviews, or other use for broadcast or educational purposes. Examples of such excluded activities would include videotaping of athletic events for post-game review, videotaping of concerts, plays, and lectures, or videotaped interviews of persons. Automated teller machines (ATMs), which may utilize cameras, are exempt from this policy.
Departments requesting security cameras will be required to follow the procedures outlined in this policy.
Individual divisions, departments, programs, or campus organizations wishing to install video surveillance equipment shall submit a written request to the SPC Chief of Police describing the proposed location of surveillance devices, justifying the proposed installation, and identifying the funding source or sources for purchase and ongoing maintenance.
- The SPC Chief of Police will review the request and recommend it to the Dean of Students, as appropriate.
- The Dean of Students will review all proposals and make recommendations or forward on to the Vice President for Student Affairs with a recommendation.
- The Vice President for Student Affairs will inform the SPC Executive Council and other administrators, as appropriate. Finally recommendations and approvals will then communicated back to the SPC Chief of Police and the Dean of Students.
The Dean of Students shall oversee the installation of all approved security camera systems with the assistance of the SPCPD, the Office of Information Technology’s Campus Security Analyst and Maintenance Services, as required.
Purchasing will not accept, approve, or process any order for security camera systems without the approval of the Vice President for Student Affairs.
3.1.1 Existing Cameras
A bi-annual evaluation of cameras across all SPC properties will occur unless a property is remodeled or a new property is obtained. The evaluation will be performed by the SPC Chief of Police, the Information Services Campus Security Analyst, and the Dean of Students. The evaluation will include the following:
- Are cameras placed in strategic locations that meet the interior and exterior coverage guideline outlined in this policy?
- Are cameras operational or need to be replaced? If replacement is needed, can a newer model with greater capacity (i.e., replacing single line of vision with a 180° or 360° camera possible) be used?
- Does the camera need to be readjusted (i.e., focused, lens cleaned, repositioned, etc.)
3.1.2 New and Replacement Cameras
Based on the existing camera analysis for replacement, remodeling or new construction standards include:
- All new cameras purchased will be non-proprietary (e.g., cameras must be able to function on more than one platform).
- A variety of cameras will be used to maximize coverage while minimizing the cost to the College. Camera options may include single line of vision, 180° or 360° directional, and external night vision.
- All new cameras purchased must be reviewed by SPC-Information Services as specified in the SPC Information Services Policy 15-A – Technology Acquisition Oversight Statement.
Camera control operators shall be trained in the technical, legal, and ethical parameters of appropriate camera use.
Camera control operators shall receive a copy of this policy and provide written acknowledgement that they have read and understood its contents.
Video surveillance will be conducted in a manner consistent with all existing College policies.
Camera control operators shall monitor based on suspicious behavior, not individual characteristics.
Camera control operators shall not view private rooms or areas through windows.
All operators and supervisors involved in video surveillance will perform their duties in accordance with this policy.
3.4 STORAGE AND RETENTION OF RECORDINGS
No attempt shall be made to alter any part of any surveillance recording. Surveillance centers and monitors will be configured to prevent camera operators from tampering with or duplicating recorded information.
Surveillance records shall not be stored by individual departments. All surveillance records shall be stored in a secure College centralized location for a period of 30 days and will then promptly be erased or written over, unless retained as part of a criminal investigation or court proceedings (criminal or civil), or other bona fide use as approved by the Chief of Police or designee. Individual departments shall not store video surveillance recordings.
Software used to monitor records must require a unique username and password. A log shall be maintained within the platform that tracks all users and access rights including instances of access to or use of surveillance records. The log shall include the date and identification of the person or persons to whom access was granted. Refer to SPC Policy HV – Data Governance Policy for additional regulations regarding record security.
Approval and Revisions
- Policy approved and enacted by Executive Council – February 19, 2018