Original Date: 8/4/2020 * Last Revision Effective: 8/4/2020
Policy Contact: Vice President, Administrative Services
Purpose
The following procedures are established to meet the requirements for implementing policy # 6380 – Security Camera Use.
Procedures
Bellevue College Information Technology Services (ITS) will coordinate with the security camera team under the direction of the vice president of administrative services (VP AS) to:
- ensure the quality and integrity of systems,
- identify appropriate camera placement,
- take measures to ensure privacy, and
- appropriately manage the monitoring and retention of recordings.
ITS will
- assess hardware and software for quality and interoperability,
- advise on the feasibility of camera placement, and
- manage recording storage logistics.
Security Camera Team
The BC Security Camera Team is convened by the VP AS and will include the following members:
- Director of public safety or designee
- Member(s) from ITS
- Director of campus operations or designee
- Human resources representative
- Representative(s) of the installation area or building, selected by the administrator with operational control of the area, in consultation with the VP AS
- Faculty representative
- Student representative
The security camera team will meet on an as needed basis to consider and make recommendations about potential camera installations. Team recommendations will be based on input from all applicable stakeholders such as Title IX, student affairs, the diversity, equity, and inclusion office, and employees in affected areas. The team will coordinate with the VP AS to ensure that appropriate measures are taken to protect individual rights to privacy and the security of information created, stored, transmitted, used or deleted.
Camera Placement
Cameras will be located to prioritize personal privacy. No audio will be recorded. Camera placement must not violate the standard of a reasonable expectation of privacy. All installed cameras should be visible. Facilities with cameras will be marked with signage. The exact location, number, and function of all cameras will be considered confidential and not be released to the general public, guests, or employees.
The VP AS has approval authority on camera placement based on ITS and security camera team recommendations.
Access and Monitoring for Official Business
Cameras are not actively monitored. Video recordings are viewed upon report of a possible crime or college policy violation. Information obtained from the cameras will be used exclusively for the investigation of alleged criminal matters and college policy violations. Public safety staff and other authorized personnel, as determined by the VP AS, will handle information with an appropriate level of security to protect against unauthorized access, alteration, or disclosure. All personnel with access to college security cameras will be trained in the effective, legal, and ethical use of monitoring equipment.
Cabinet-level administrators may request live feed access to camera for staff members to monitor locations in their functional area (e.g., athletics may be allowed to have live feed access to cameras). The VP AS must approve all requests for access. Any equipment used to view the live access feed must be placed in a location that maintains privacy.
For the purposes of an investigation, the director of public safety may authorize the viewing or release of camera images in response to an alleged violation of college policy or criminal statute that has been reported to a college investigative office (e.g., Title IX, HR, student conduct, public safety). In cases where the alleged violation may implicate a college employee, the director of public safety will first obtain the approval of the vice president of human resources.
Public safety will maintain a log of all instances of, access to, and use of, recorded material. The log will include the name of the person(s) to whom access was provided and the date. This log will be discarded in accordance with the State Government General Record Retention Schedule.
Requests for Records
Requests for records associated with security cameras, including but not limited to requests for camera footage, will be processed in accordance with applicable state and federal laws and college policy.
Storage and Retention of Recordings
No attempt shall be made to alter any part of any video recording. Areas where security camera recordings are viewed and all camera hardware will be configured, to the extent possible, to prevent camera operators from tampering with or duplicating recorded information. All records related to security camera operations will be stored in a secure location, either on campus or through a cloud-based solution. Access to the storage location should be limited to those who have access to security camera feeds or employees authorized to perform infrastructure maintenance.
BC will maintain all security camera records in accordance with the Washington State Government General Records Retention Schedule and the Community and Technical College Records Retention Schedule.
Limitations
Access, monitoring, storage, and retention of records related to security camera use will be governed by:
- Family and Educational Rights and Privacy Act (FERPA) regulations,
- BC Policy 1440, Discrimination, Harassment and Retaliation, which prohibits discrimination based on membership in a protected class,
- Professional, ethical, and legal considerations.
Training
All public safety personnel or other college employees having access to the camera system will be trained in the technical, legal, and ethical parameters of appropriate camera use. Personnel will receive a copy of this policy and associated procedures and provide written acknowledgment that they have read and understood its contents.
Relevant Laws and Other Resources
Washington State Government General Records Retention Schedule
Revised Code of Washington 42.56.420 Security
Revised Code of Washington 42.56.050 Invasion of privacy, when
Revision History
Original 8/4/2020
Approved By
President’s Cabinet
Last Updated August 10, 2020