Business Policies and Procedures Manual
Chapter 50: Safety and Security
Video Security Systems–WSU Pullman
BPPM 50.35
For more information contact:
Public Safety
police@wsu.edu / 509-335-8548
Forms:
Contents
1.0 Policy and Purpose
When used appropriately and in combination with other crime prevention and community policing initiatives, judicious use of video security systems in public spaces may serve as a potential deterrent to criminal behavior and also assist law enforcement with protecting persons and property.
The purpose of this policy is to regulate and standardize the use of all video security systems at the Washington State University (WSU) Pullman campus, with the goal of enhancing security while also respecting and protecting individual privacy, academic freedom, and constitutional rights. The policy also formalizes the installation, management, security, access, monitoring, retention, dissemination, and destruction procedures associated with such systems in order to meet technical and privacy best practices.
The WSU Pullman Office of Public Safety/Police Department, with support from Finance and Administrative Information Services (FAIS), is exclusively authorized to select, coordinate, operate, manage, and monitor all video security systems pursuant to this policy.
This policy authorizes a Video Security Oversight Committee (VSOC) established by the WSU Pullman Chancellor to oversee its execution and review. (See Subsection 3.9 regarding the VSOC.)
2.0 Applicability
This policy applies to the use of the video security systems at the WSU Pullman campus, and to all personnel, departments, units, and colleges of the Pullman campus. (See Subsection 3.6 for a definition of a video security system.) The policy applies retroactively to all previously installed and activated video security systems at the WSU Pullman campus.
This policy does not apply to video security equipment or content produced and used for:
- Institutional Review Board (IRB) or Institutional Animal Care and Use Committee (IACUC) approved research with human subjects or animals
- Police body cameras.
3.0 Definitions
The following definitions apply to this policy (BPPM 50.35).
3.1 Monitoring
The use of cameras, display monitors, or other video equipment for real-time observation of images.
3.2 Permanent Installation
The installation of any device or system that is intended to remain in place for an indefinite time, and to be removed or modified only for change of circumstances, upon approval of the VSOC.
3.3 Private Area
An area where an individual might change clothing (e.g., residence, bathroom, shower area, locker and/or changing room).
The term “private area” also typically includes private office spaces. However, exceptions are appropriate in those areas where monetary transactions occur or where the use of CCTV is needed to safeguard money or supplies from theft, destruction, or tampering.
3.4 Public Area
An area open for public use where there is no reasonable expectation of privacy or an area that could normally be openly observed (e.g., campus grounds and parking lots, an academic hallway, a classroom, a library, or a study room).
3.5 Temporary Installation
The installation of any video security device or system that is intended to:
- Remain in place for a defined, temporary period; or
- Remain in place for only as long as required for a specific investigation, trial period, or other short-term need; and
- Be removed when the specified need or period has expired.
3.6 Video Security System
A system consisting of electronic devices such as cameras and recording systems designed or used for the purpose of safety of persons and security of property. The data from the system is transmitted and/or controlled remotely through a direct or network connection.
It includes the use of any video device or equipment with the capacity to capture, record, and/or transmit images of places, things, and activities occurring in University-owned or controlled spaces for security purposes. It does not include videoconferencing for communication or instructional purposes.
The cameras communicate with monitors and/or video recorders across private coaxial and/or Ethernet wire cable runs or wireless communication links. For this reason, the cameras are designated as “closed-circuit” to indicate that access to the content is restricted by design only to those able to see it. Modern closed-circuit television (CCTV) displays may include the following features:
- Color, high-resolution displays
- Ability to zoom in on an image
- Ability to track items or individuals
Video security systems subject to this policy (BPPM 50.35) do not include the use of devices or equipment by persons who are not acting within the scope of their authority from the University, or under its direction or control.
3.7 Video Security System Data
Digital video data captured by recording devices that may be monitored, transmitted, stored, retrieved, or modified in conjunction with the use of a video security system.
3.8 Video Security System Device
Any camera or video recording device that captures and stores images as data; and any electronic equipment that, as part of a video security system, provides the capability to retrieve, transmit, or reproduce the video data files.
3.9 Video Security Oversight Committee (VSOC)
The Video Security Oversight Committee (VSOC monitors the execution of this policy (BPPM 50.35) at the direction of the WSU Pullman Chancellor. The VSOC is comprised of representation appointed by the Chancellor from campus organizations, which may include:
- Office of Public Safety/Police Department
- Finance and Administrative Information Services (FAIS)
- Attorney General’s Office
- WSU Pullman Facilities Services
- WSU Pullman Student Affairs
- Office of Risk Management Services
- Faculty Senate
The WSU Pullman Chancellor may select additional members from other campus organizations to serve on the VSOC. Meetings occur at least annually and as needed.
4.0 Requirements
4.1 Permitted Uses
Video security systems may be used for official University and law enforcement purposes only. This includes:
- Enhancement of personal safety
- Enhancement of property protection
- Surveillance of criminal or suspected criminal activity
- Substantiation of civil complaints
- Other uses upon prior written approval of the VSOC
4.2 Placement
Security cameras should only be used in public areas where there is no reasonable expectation of privacy.
Public area camera applications where the camera view includes the outside of any residential facility or private offices must not:
- Offer an enhancement of view of private areas that is better than what is available with unaided vision; and
- Violate a reasonable expectation of privacy.
4.3 Signage
Signage is not required for video security system installations in public areas; however, signage notifying the public of the presence of video security is recommended, particularly where it may not be clear whether the area is considered public or private. Requested signage must be approved by the VSOC and paid for by the requesting department.
4.4 Prohibited Uses
The use of video security system equipment is limited to professional, ethical, and legal uses that do not violate a reasonable expectation of privacy.
A video security system may not be used:
- To harass, intimidate, or discriminate against any individual or group, including protected groups
- For prurient, immoral, or entertainment purposes, or to view intimate activity
- To record sound or speech in violation of RCW (Revised Code of Washington) 9.73.030, with or without video
- For inoperative or placebo “for looks only” applications unless approved by the VSOC.
4.5 Confidentiality
Personnel are prohibited from viewing or disseminating data or information derived from video security systems except pursuant to official and authorized purposes or as required by law. All information and/or observations made through the use of security cameras are considered confidential and may be used for official University and law enforcement purposes only.
Unofficial and/or unauthorized viewing or dissemination of confidential data or information is subject to appropriate administrative and/or disciplinary action, as well as possible criminal charges.
4.6 Destruction or Tampering
Any person who tampers with or destroys a video security camera or any part of the video security system is subject to appropriate administrative and/or disciplinary action, as well as possible criminal charges.
4.7 Content Access, Monitoring, Ownership, and Uses
Video security systems may monitor continuously in real time under normal operating conditions. Typical uses of the system data are for forensic examination.
4.7.a Access
Access to live or recorded video security system data is limited to personnel authorized by the Director of Public Safety/Police Chief. All access and use are subject to the confidentiality and authorized use restrictions in Subsection 4.5.
Typically, personnel with administrative or functional responsibilities where video security systems are used are granted authorization to access the data for their specific areas.
Also, all of the following personnel are granted authorization by the Director of Public Safety/Police Chief to access the data when needed for an authorized purpose in accordance with Subsection 4.5, unless doing so compromises an investigation:
- Police department personnel
- FAIS personnel
- Public Records Office personnel
- Human Resource Services (HRS) investigative personnel
- Internal Audit investigative personnel
- Senior University administrators (vice president, dean, and above)
The Director of Public Safety/Police Chief may grant exceptions to the access guidelines listed above on a case-by-case basis. WSU Pullman departments must submit a Video Security Camera System Access Request to the Office of Public Safety/Police Department to request access for personnel not listed above.
4.7.b Copying, Duplicating, and/or Retransmisson
Copying, duplicating, and/or retransmission of live or recorded video is limited to persons authorized by the Director of Public Safety/Police Chief or designee, or as required by state law.
4.7.c Ownership
All video security system content is owned by the University and is the responsibility of the Director of Public Safety/Police Chief.
4.7.d Training
All personnel involved in the supervision, application, and use or monitoring of video security systems must be trained with respect to this policy (BPPM 50.35). The training must be approved by the Director of Public Safety/Police Chief.
5.0 General Procedures
5.1 Security Camera Installations
All security camera installations must:
- Be subject to an annual recharge fee through Public Safety, the established University service center, to support the cost of installation, maintenance, and replacement;
- Be formally submitted to the Director of Public Safety for approval using the Security Camera System Installation Request form;
- Be completed by FAIS or designee/contractor in consultation with the area technology officer (ATO);
- Comply with applicable building codes; and
- Comply with AMP Netconnect/Commscope Standards.
5.1.a Security Camera Installations Requiring New Cabling
All new security camera installations must comply with the requirements and procedures in BPPM 80.56. Facilities Services must complete new cabling pathway/building penetrations for any security camera installations, unless such installations are part of a capital project.
FAIS is allowed to install new cabling through existing pathways, as needed, for all new security camera installations. All security camera side terminations must be completed by FAIS.
5.1.b Network Activations/Terminations
Information Technology Services (ITS) is responsible for all network terminations/ activations in telecommunications closets and other facilities.
5.2 Storage, Retention, and Access to Recorded Data
All recorded video security system data and information is subject to requirements regarding confidentiality and limitations on use in Subsection 4.5.
5.2.a Location
All recorded video security system data must be stored in a secure University centralized location. Individual departments may not store recorded video security system data except as part of an investigative report.
Contact the Director of Public Safety/Police Chief for further information, instructions, and/or authorizations.
5.2.b Retention Requirements
University records retention requirements apply to video security records.
See the All-University Records Retention Schedule–Security Records table regarding applicable University records retention requirements for general security monitoring records. Note: Retention requirements for police records are covered under a unique departmental records retention schedule assigned to the WSUPD.
5.2.c Access
Access to stored video security system data is strictly limited to University employees who have a legitimate business need, or others as approved by the Director of Public Safety/Police Chief.
5.2.c.i Access Log
An automatic electronic access log of security camera use is created by each video security system. The log must include dates and times that security cameras are accessed by individuals and the dates and times recordings are reviewed and/or exported.
All logs must be retained for a period of one year as required by federal CJIS (Criminal Justice Information Services) standards and the University’s records retention schedule. See the All-University Records Retention Schedule–Security Records table.
5.3 Release of Information
Persons involved with monitoring, maintenance, or installation must not release any information obtained from University video security systems unless required by law or at the direction of the Executive Vice President for Finance and Administration or designee.
5.4 Commercial Use
Commercial use of captured video content must be approved by the WSU Pullman Chancellor or designee.
5.5 Public Records Requests
All public records requests, including requests for the release of video security records, must follow the University’s public records request policy. See WAC 504-45-030 and BPPM 90.05.
The Office of Public Safety/Police Department is responsible for providing any video security system records covered by this policy (BPPM 50.35) that are requested through the Public Records Office.
5.6 Complaints
Complaints concerning the placement or use of the video security systems should be made to the chair of the VSOC through the Office of Public Safety for investigation and adjudication by the committee; e-mail police@wsu.edu; telephone 509-335-8548.
An appeal may be addressed to the WSU Pullman Chancellor within 30 days after the VSOC issues a decision regarding the specific complaint.
6.0 References
The following references apply to this policy (BPPM 50.35):
- EP8: WSU System Data Policies
- EP15: Policy Prohibiting Discrimination, Sexual Harassment and Sexual Misconduct
- EP37: WSU Information Security Policy
- RCW 9.73.030: Intercepting, recording, or divulging private communication – Consent required – Exceptions
- WAC 504-45-030: Availability of public records
- BPPM 90.05: Release of Public Records
- BPPM 30.61: Payment Card Data Security Compliance
- AMP Netconnect/Commscope Standards
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Revisions: Sept. 2023 (Rev. 614); Nov. 2020 – new policy (Rev. 558)