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Closed Circuit TV [CCTV]

Guilford College is committed to enhancing the safety and security of the campus community by integrating public safety best practices with state-of-the-art technology. A critical component of a comprehensive security plan using progressive technology is Closed Circuit Television (CCTV), which has been proven effective in reducing criminal activity. 

To ensure the protection of individual privacy rights in accordance with the College’s values and state and federal laws, CCTV recording of public areas for security purposes at Guilford College is limited to uses that do not violate the reasonable expectation of privacy as defined by the law and will be conducted in a professional, ethical and legal manner by members of the Department of Public Safety. CCTV recording is used in public and common areas exclusively for safety and security purposes -- i.e., to deter crime and to assist in protecting the college’s community and property. Signage indicating the location of CCTV recording of a public area will be posted to enhance the crime prevention value of the CCTV system.

Purpose/Reason for Policy: This policy is adopted to formalize procedures for the installation of CCTV equipment and the handling, viewing, retention, dissemination, and destruction of CCTV records.

Scope/Covered Persons:  This policy applies to all members of the Guilford College community and College owned and/or operated property and buildings.

Definitions:  

Closed Circuit Television (CCTV): A video camera used for recording public areas for the purposes of enhancing public safety, discouraging theft and other criminal activities, and investigating incidents. The College’s CCTV system does not use facial recognition technology of any kind. 

Public/common areas: areas made available for use by the public, including, but not limited to, campus grounds, parking areas, building exteriors, loading docks, areas of ingress and egress, residence hall corridors and common areas, study rooms, lobbies, theaters, libraries, dining halls, gymnasiums, recreation areas, and retail establishments.  Areas of the College in which persons would not have a reasonable expectation of privacy, but to which access is restricted to certain College employees, such as storage areas, shall also be considered public areas for the purpose of this policy. Public Safety will limit camera positions and views of residential housing to common areas. Furthermore, any view must not violate the standard of “a reasonable expectation of privacy.”

Private areas: areas in which a person has a reasonable expectation of privacy, including, but not limited to, private faculty and staff offices, non-common areas of residence halls, bathrooms, shower areas, locker and changing rooms and other areas where a reasonable person might change clothes.  Additionally, areas designed for the personal comfort of employees or the safeguarding of their possessions, such as lounges and locker rooms, and areas dedicated to medical, physical, or mental health therapy or treatment shall be considered private areas for the purpose of this policy.

Given Guilford's deep commitment to academic freedom and to protecting the privacy of discussions that take place in college courses, classrooms, studios, laboratories (with the exception of chemical storage areas) and lecture halls shall also be considered private areas for the purposes of this policy.

The Policy:  

CCTV recording of public areas for security purposes will be conducted in a manner consistent with existing College policies, including the Notice of Non-Discrimination, the Title IX Policy and other relevant policies. CCTV cameras will be used to record activity around building perimeters, entrances and exits, lobbies and corridors, receiving docks, special storage areas, cashier locations and other areas that, in the discretion of the Director of Public Safety, in consultation with the Chief of Staff, are warranted depending on the circumstances.

Images and any related data collected by CCTV are the property of Guilford College and will be used exclusively for safety and security  purposes. Recorded images will be stored in a secure location with access by authorized Public Safety staff only.

CCTV records will not be released to the public, students, employees (other than those tasked with related job duties), parents or law enforcement agency without a summons, subpoena, search warrant or other court order. The content of the video is a College record subject to administrative regulations regarding confidential records, and potentially to FERPA, under specific conditions. 

Tampering with video equipment or CCTV recordings is prohibited. 

The presence of CCTV does not insure complete protection against a criminal act nor does it mean that every CCTV location is in operation at all times.

Recording video media will be stored for a period not to exceed 75 days and will then be erased or written over unless retained as part of a criminal investigation or court proceedings (civil or criminal), or other bona fide use as approved by the Director of Public Safety and Chief of Staff.  Video Media will be stored in a secure location with access by authorized personnel only. Individual departments shall not store video CCTV recordings. 

A log shall be maintained of all instances of access to or use of CCTV records. The log shall include the date and identification of the person or persons to whom access was granted.

Exceptions 

  • Academic Use:  This policy does not apply to cameras used for academic purposes. Cameras that are used for research, communications, or class projects would be governed by other policies involving human subjects and are, therefore, excluded from this policy. 
  • Student/employee personal cameras: This policy does not address the use of webcams, live streaming for general use by the College, or video recording of events.
  • 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 video recording of athletic events for post-game review, video recording of concerts, plays, and lectures, live stream activity or video recorded interviews of persons. Automated teller machines (ATMs), which sometimes utilize cameras, are also exempt from this policy. 

Roles and Responsibilities: 

The Director of Public Safety is responsible for authorizing, overseeing and coordinating all CCTV recording for safety and security purposes in consultation with the Chief of Staff. No staff other than Public Safety staff trained in the use of the CCTV system will have access to the video footage. However, the College reserves the right to authorize other individuals to view video footage if that is a necessary action as part of an investigation of a crime, violation of College policy, or significant campus safety concern. 

The Director of IT&S is responsible for the installation and maintenance of the video recording equipment and technology but is not authorized to view the footage unless authorized by the Director of Public Safety.

The Chief of Staff  will review all requests received by the Department of Public Safety to release recordings obtained through CCTV recording as soon as practicable. No releases of CCTV recordings will occur without authorization by the Chief of Staff who will seek consultation and advice from legal counsel as needed. 

Compliance: 

Violations of this policy, depending on the severity of the violation, may be cause for corrective action in accordance with established procedures for staff and faculty.

Other related Policies, Regulations, Statutes and Documents: 

Approval Authority:  The Guilford College President

Responsible Office: Jermaine Thomas, Director of Public Safety, Bauman L010C, 336-316-2907, thomasja2@guilford.edu

Revision History: New Policy approved by President’s Cabinet 3-4-2020