Policy Title: Security Camera and Recording Retention Policy Responsible Executive: Executive Vice President Responsible Office: Department of Public Safety Contact: Department of Public Safety 609-258-1000 Effective Date: December 25, 2022 Last Update: December 25, 2022 I. Purpose The purpose of this policy is to create a governance and usage framework that will apply to all security cameras used to monitor or record indoor and outdoor spaces owned, occupied, or controlled by Princeton University. The guiding principle of the policy is to identify specific locations and situations where security cameras can be placed if a risk-based evaluation of the operational need indicates camera placement is justified. The primary purpose of utilizing security cameras is to enhance the safety and security of members of the University community and University property while preserving individual privacy and freedom of expression. The Life Safety and Security Committee and executive sponsors of capital projects, who are responsible for approving camera placements, may impose placement restrictions that go beyond the scope of this policy where it is believed that the presence of cameras would be inconsistent with community values, the preservation of an environment that encourages free academic and intellectual inquiry, or other important values. The framework created within this policy seeks to ensure that security cameras used by the campus community are operated in a manner that is consistent with University principles and in compliance with all applicable policy and legal requirements. The existence of this policy does not imply or guarantee that security cameras will be monitored in real time continuously or otherwise. Additionally, while the University makes reasonable efforts to ensure its security cameras are functional/operational, this policy is no guarantee of this. Any violation of this policy may result in disciplinary action and/or potential penalties, including without limitation termination of employment or engagement. II. Scope This policy applies to all academic and administrative units and all faculty, staff, and contractors employed by the University. This policy shall not apply to use of cameras for reasons unrelated to security surveillance activity. Furthermore, this policy does not apply to video technologies that are used by devices such as laptop computers, small, unmanned aircraft systems, smart phones or similar devices, unless such devices are used primarily to view or record video images for more than a short-duration or incidental basis. This policy also does not apply to cameras used by law enforcement in carrying out law enforcement functions. Automated Teller Machines (ATMs), which may utilize video, are also exempt from this policy. III. Definitions As used within and for the purposes of this policy, the following terms are defined as follows. Security camera: a camera used for the safety and security purposes described in Section V below, which are enabled only to make visual recordings (i.e., no audio recordings). Security camera recording: a digital or analog recording of the feed from a security camera, or an image derived from such recording. Security camera system: any electronic service, software, or hardware directly supporting or deploying a security camera. Security camera system owner: University staff member who is responsible for overseeing a security camera system including camera placement, operation, and/or management of the security camera system and all images taken with such system. IV. Roles and Responsibilities Department of Public Safety (DPS): Department authorized to oversee and coordinate the use of security camera monitoring for safety and security purposes at the University. Life Safety and Security Steering Committee (LSSC): Committee authorized to review all requests for security camera installation and make final recommendations regarding camera placement. Executive Sponsor: For capital construction projects, the Executive Sponsor of the project or their designee may review security camera placement requests and grant final approval. Assistant Vice President for Public Safety (DPS AVP): Member of LSSC and head of DPS. V. Security Camera Placement Guidelines Cameras can be placed in selected areas for the legitimate safety and security purposes of deterring of crime, providing the University with information that will enhance the safety and security of persons, and protecting the property of the University according to the guidelines outlined in this section. The installation of security cameras will be based upon evidence of a need to mitigate an identified risk or vulnerability. Such needs include: Safeguarding of human life; Protection of buildings owned, occupied, or controlled by the University; Protection of University property and assets; Monitoring of access to University controlled buildings; Verification of security alarms; Monitor storage, pick up, and drop off of hazardous materials; Rapid response to emergency events or incidents; Protection of high security spaces (i.e., Art Museum, Library Rare books collections); and Management of safety risks at large events (typically events with 1,000 or more attendees) on campus, including Reunions, Commencement, and large Athletics events. Cameras will be limited to uses that do not violate the reasonable expectation of privacy as defined by law or the University. Security camera systems generally cannot be installed to monitor areas where there is a reasonable expectation of privacy. VI. Security Camera Placement Approval Processes Where the security camera request relates to placement of security cameras at or around completed capital construction or renovation sites (i.e., at or around newly constructed/renovated buildings), the Office of Capital Projects and associated design teams will consult with the Department of Public Safety to determine recommended camera placements. The camera placement plan will then be reviewed by the Life Safety and Security Committee (LSSC) for approval. If the LSSC approves the camera placement plan, and the capital construction project has an executive sponsor, it will then go to the Executive Sponsor for the capital construction project for final approval. If the Executive Sponsor disagrees with LSSC approval of a camera placement plan, the Executive Sponsor will meet with the LSSC Steering Committee to discuss. If the LSSC approves the camera placement plan and there is no Executive Sponsor for the capital construction project, LSSC’s approval is considered final. When the security camera request does not relate to the placement of security cameras at completed capital construction or renovation sites, the requestors should consult with the Department of Public Safety to determine recommended camera placements. The camera placement plan will then be reviewed by LSSC, which will make the final decision regarding security camera placement in a manner consistent with this policy. After final approval of the camera placement, whether or not in relation to capital construction or renovation projects, the camera placement plan will be documented by the project manager in the form attached to this policy in Appendix A and forwarded to DPS and Facilities Site Protection for record keeping purposes. The LSSC may recommend placement of additional cameras or impose location restrictions that go beyond the scope of this policy where it is believed that the presence of cameras would be inconsistent with community values, the preservation of an environment that encourages free academic and intellectual inquiry, or other important values. Signage or other forms of notice, specific or general, stating the presence of security cameras will be placed as required by law. The appearance and placement of any required signage needs to be approved by the Office of the University Architect. Camouflage or other deliberate concealment of cameras is not permitted unless specifically requested by DPS consistent with its use of concealed cameras. DPS may place temporary concealed security cameras for use in criminal investigations or in exigent situations involving credible threats to the safety of the campus, to the life, health or safety of any person, or of theft or destruction of property, where, in each case, making the camera visible would undermine the University’s response to the situation. Such camera placements must be authorized in writing by the DPS AVP or delegated authority for each discrete incident and reported to the Executive Vice President or their designee for approval prior to the start of the surveillance. Should external law enforcement request the University to install a security camera on property owned, occupied or controlled by the University on an ad hoc basis (in a concealed or unconcealed location), that request will be presented to the Executive Vice President for consideration. Security cameras should not enable audio recording. Placement of non-operable, or “dummy” video cameras is prohibited. VII. Security Camera Operation Once security camera placement has been approved, all security camera system owners must comply with University training, reporting, and management requirements to ensure compliance with this policy. VIII. Monitoring Guidelines All video recording and/or monitoring of activities of individuals or groups must be conducted in a manner consistent with University policies and applicable legal requirements. Neither the installation of security cameras nor this policy constitutes an undertaking by the University to provide continuous live monitoring of all locations visible through such cameras. Cameras may be monitored in “real time” when safety or security concerns, event monitoring, ongoing investigations, alarms or other situations warrant such monitoring. IX. System Oversight Responsibility Camera field of view, operational parameters and configurations for camera security systems are determined by the Department of Public Safety or its designee. Facilities and the Office of Information Technology are responsible for the operation and maintenance of the network applications and the physical system hardware that support security camera systems. X. Access to and Retention of Recordings Access to or distribution of any security camera recording requires express written permission of the Executive Vice President or designee. The Executive Vice President or designee will make determinations in a manner consistent with this policy and in consultation with the appropriate University officials, including representatives of the Office of the Vice President for Campus Life, the Graduate School, the Dean of the Faculty, the Office of Human Resources and the Office of the General Counsel, as necessary. Requests should be submitted to the DPS AVP in writing. All security camera recordings must be stored in a secure location established by the operating unit, accessible only to authorized and trained staff members, and configured to prevent unauthorized modification, duplication or destruction, and they will be retained in accordance with University guidelines. Security camera recordings will generally be retained for a period of time between 30-90 days, depending on the operational needs of the particular units. The security camera system owner is responsible for ensuring that recordings are erased or recorded over as required in this paragraph. Requests to preserve a security camera recording from deletion should be submitted in writing to the DPS AVP, and should include the reason for the preservation request. XI. Existing Security Camera Systems Security camera systems that predate the effective date of this policy shall be brought into compliance with this policy within six (6) months of the effective date of this policy. Unapproved or nonconforming security camera systems may be removed. Related Policies: Access to Accounts and Information Policy
