D.1.18 Use of Video Security Monitoring Systems

Marine Biological Laboratory
Policy Number D.1.18

Initiated by: Deputy Director of Operations
Approved by: MBL Director
Date: September 23, 2014
Revision:
Distribution:

1.0 Introduction
The MBL is committed to ensuring the safety and security of those who work, study, live, and visit the campus. The MBL also values and respects the personal privacy of all members of the community.

In support of these objectives, the MBL has developed the following policy to establish the responsibilities, conditions, and procedures for the placement and use of video security monitoring systems in public spaces to enhance safety and security on the MBL campus.

For the purposes of this policy, the term public spaces shall mean areas of the MBL campus where a reasonable individual would not expect personal privacy. Examples of non-public spaces include areas such as residence rooms, bathrooms, shower areas, locker and changing rooms, private offices, and other confidential locations.

The phrase video security monitoring shall refer to equipment such as security cameras, video recording devices and data, monitors, and associated network infrastructure. It shall not include audio monitoring or recording, or other devices used for video conferencing, teaching, and research.

2.0 Purpose and Scope
The objectives for the application of video security monitoring systems are to:

  1. Enhance community safety while respecting personal privacy,
  2. Prevent criminal activity and,
  3. If a crime has occurred, assist law enforcement personnel with investigation.

This policy applies to all staff, faculty, students, visitors, vendors, and contractors and their activities on MBL property.

3.0 Principles

  • Information obtained through the use of video security monitoring systems shall be used exclusively to improve campus safety and law enforcement purposes.
  • All video security monitoring shall be conducted in compliance with the Massachusetts Privacy Act, MGL c. 214, sec. 1B.
  • Video security monitoring shall be conducted in a manner consistent with all other MBL policies, including those related to non-discrimination and harassment (e.g., race, gender, sexual orientation, national origin, disability, etc.).
  • Images obtained through MBL video security monitoring systems shall be maintained securely and with restricted access only by authorized personnel.
  • Unless involved in an active criminal investigation, recordings from video security monitoring shall be permanently deleted after a specific limited period of time.

4.0 Responsibilities
The Director of the MBL (or his/her designee) shall be responsible for approving the placement of all of video security monitoring systems and for authorizing the release of any recordings obtained from such equipment.

The Director of Facilities and Services shall be responsible for the installation, maintenance, and oversight of all video security monitoring systems. Such oversight shall include the proper training and supervision of all personnel involved in security operations, and ensuring that all monitoring activities are conducted within the scope of this policy and other related MBL policies.

The Director of Facilities and Services and the Director of Human Resources, with assistance and advice from the University of Chicago Department of Safety and Security, will monitor developments in relevant law and in security industry practices to ensure that camera placement, training, monitoring, recording, and data management are consistent with the highest professional standards.

5.0 Placement of Video Security Monitoring Equipment
Video security monitoring cameras shall be placed in, and with views limited to, public spaces, with the sole exception being authorized investigations conducted for law enforcement purposes. Areas regularly subject to video security monitoring shall be posted with visible signage.

In all cases, access to cameras, recording equipment, and image data shall be physically and electronically secure, and restricted to authorized personnel.

6.0 Access and Monitoring
All personnel involved in operating video security monitoring equipment shall be appropriately trained and follow approved written procedures for all activities. Violations of such procedures or the principles established by this policy will be grounds for disciplinary action, including termination of employment.

Recorded images will be stored for at least 30 days and generally not more than 60 days before being erased, unless retained as part of a criminal investigation, court procedure, or other specific use approved by the Director of the MBL (or his/her designee). Images may be stored as part of an integrated system, as part of a centrally-managed system on MBL servers, or at a remote location.

Under no circumstances will the MBL use security camera technology to monitor the work behavior of staff, faculty, students, vendors, contractors or visitors, unless there is a legitimate investigation pertaining to conduct contrary to the law or MBL policy. Any such monitoring or review must be conducted under the auspices of the MBL Human Resources Department and preceded by a documented complaint, report, memo, email or other formal correspondence as to the nature, scope and level of action to be taken.