SECURITY CAMERAS

Western Wyoming Community College is committed to enhancing the quality of life, safety and security 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  security of public areas is intended to deter crime and assist in protecting the safety and property of the 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’s safety policies 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 records.¹

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 presence of security cameras does not guarantee safety for persons or property at all times. Individuals and property owners are responsible for taking necessary precautions to safeguard themselves and their property while on the College campus.

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.

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 a staff member in close proximity. In this case video may or may not be recorded. Example: a testing facility with multiple rooms and only one staff.

In general, Video  Security Systems at the College are primarily for forensics value for investigative purposes and not intended for constant, real-time monitoring of activities. Once a policy violation has been committed, the systems may assist in the identification of the responsible parties. For this reason fixed-view cameras are preferred. Video  Security Systems at the College shall not be utilized to conduct personnel investigations, such as those related to, but not limited to work place attendance or work quality.  However, the College may utilize routine video  security recordings in support of disciplinary proceedings against employees and/or students, or in a civil suit or other proceeding involving person(s) whose activities are shown on the recording and relate to the proceeding.  Information obtained in violation of this policy may not be used in a disciplinary proceeding against a College student or employee. 

[1] The Clery Act requires higher education institutions to give timely warnings of crimes that represent a threat to the safety of students or employees, and to make public their campus security policies.  It also requires that crime data are collected, reported and disseminated to the campus community and are also submitted to the Education Department.  The act is intended to provide students and their families, as higher education consumers, with accurate, complete and timely information about safety on campus so that they can make informed decisions.

Adopted: March 8, 2010
Revised: January 14, 2021

Procedure 3710H

SECURITY CAMERAS

Responsibilities and Authority 

The Vice President for Administrative Services; the Protective Services Supervisor; the Director of Information Technology; and the Administration’s Safety Committee are responsible for overseeing security cameras and their associated policies, standards, and procedures.  This responsibility includes:

• Creating, maintaining, and reviewing the campus strategy for procurement, deployment, and use of security cameras;
• Authorizing placement of security cameras, in accordance with the following procedures;
• Authorizing the purchase of new security camera systems in accordance with College purchasing policies and procedures;
• Ongoing review of existing security camera systems and installations and determining required changes to ensure compliance with this procedure;
• Ensuring operators are trained in the appropriate use of security cameras in accordance with this policy.

Security Camera Placement 

Cameras will be limited to uses that do not violate the reasonable expectation of privacy as defined by law and College policy.  Cameras will be placed so that personal privacy is maximized; the College recognizes the value of privacy and will employ cameras only after examining all reasonable alternatives and fully balancing the cost, benefit and privacy implications of using video surveillance. 

No audio shall be recorded.  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. Monitoring by security cameras in the following locations is prohibited: 

• Residence halls excluding building entrances and exits and elevator entrances
• Bathrooms
• Locker rooms
• Individual Offices
• Teaching spaces
• Library
• Theatre and associated work spaces

The installation of “dummy” cameras that do not operate is prohibited. Unless being used for criminal investigations, all video camera installations should be visible. 

Security Camera Feeds and Recordings 

Only authorized persons may review and monitor security camera feeds and recordings as needed to support investigations and to enhance public safety. 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, 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 who regularly access the College security cameras must be trained in the use of security equipment in accordance with state and federal laws and within the College policy.  Law enforcement and designated College personnel may be granted limited or temporary access to the College security camera footage during an emergency situation.    

Authorized Persons 

The College President, the Vice President for Student Services, the Vice President for Administrative Services, the Dean of Students, the Protective Services Supervisor and the Protective Services staff are authorized to view real-time feeds from the College’s security cameras.  

Notification Requirements 

Signs will be posted on campus indicating that video security cameras are used to promote safety at the College.  The placement and the text of the signs will be subject to the review and approval of the Vice President for Administrative Services, in collaboration with the Student Marketing and Communications department.  

Use of Recordings 

All video security records are the sole property of the College.  Reproduction of the College’s video surveillance recordings is prohibited unless authorized by the College President or designee. Viewing of surveillance camera footage, either live video feed, recordings or images, will be conducted by authorized personnel as set forth in this policy.  Other College employees who may have a legitimate need to view recorded video data may be permitted to do so, but only at the discretion and prior approval of one of the Authorized Persons listed above.  College personnel are prohibited from using or disseminating information acquired from College security cameras, except for official purposes. 

Persons parking on College property have a reasonable expectation of privacy in their car from college surveillance; using a camera to look into a vehicle would exceed this reasonable expectation of privacy. The College will not routinely engage in surveillance of vehicle interior. 

In accordance with applicable federal and state laws, video recordings will only be released to entities off campus in response to court orders, subpoenas, or in cases of immediate threat to life or an act of physical violence. Any other release of video or images is permitted only after a written request from outside entities is received and approved by the College President or designee outlining a demonstrable and immediate need. All such disseminations of video footage shall be documented, and approval given by one of the Authorized Persons listed above.    

Video evidence relevant to a code of conduct violation will only be released at the discretion of the Dean of Students and those authorized persons listed above, in accordance with the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99).  

Retention of Security Camera Recordings 

All recordings shall be stored on a secure server in an encrypted format.  The secure server storing the recordings shall only be accessible by authorized personnel with assigned credentials and password.  The software used for the secure server shall monitor and record the identity of those accessing the server, the length of time authorized personnel access the server, and the content viewed by authorized personnel.  Security camera recordings will be kept at a minimum of 30 days and no more than 180 days and thereafter will be erased or overwritten, unless retained as part of an active police investigation, or subject to a valid court or agency preservation order, a College litigation hold, or needed for legitimate training purposes.  The 180-day maximum retention period may be extended at the request of the College’s legal counsel, the Vice President for Student Services, the Vice President for Administrative Services, the College President, or as required by law.  Prior to extending the  180-day retention period, a written statement setting forth the reasons for extending the retention period and an estimate of the extension of time must be submitted to the to the VP for Student Services, the VP for Administrative Services and the College President.  When it is no longer required to keep a recording, it shall be the responsibility of the supervising VP to ensure that the recording is permanently deleted or overwritten. 

Destruction or Tampering 

Tampering with and/or destroying cameras and/or associated equipment may be prosecuted either in the criminal court or sanctioned in accordance with College policies and procedures. 

Compliance 

The Protective Services Supervisor will ensure that records related to the use of security cameras and recordings from security cameras validate compliance with this procedure.    

At the direction of the Supervising VP, the Protective Services Supervisor and the Administration’s Safety Committee will periodically (at least once every two years) review the security camera systems and procedures for compliance with applicable law and institutional policies, and provide the supervising VP with a summary of findings and recommendations. 

Failure to meet the requirements of this procedure may result in the loss of authority to use security cameras and/or other disciplinary actions in accordance with College policy.   

Adopted: March 8, 2010
Revised: January 14, 2021