Security Cameras Procedure - 70.01.03
College Policy Number/Title:
The mission of Howard Community College’s (HCC) department of public safety is to provide a safe and secure environment for students, employees, and visitors. Technology is a necessary component of a best practices approach to public safety and security cameras assist in crime prevention and are a tool in the college’s efforts to increase campus security and safety. Campus security cameras are used in a professional and ethical manner in accordance with college policy and federal, state, and local laws and regulations. It should be noted that the presence of security cameras does not guarantee safety for persons or property at all times.
This procedure regulates the use of security cameras on campus. Objectives of this procedure are to:
- enhance the safety and well-being of the college population and protect college property;
- respect the privacy of members of the campus community and guests;
- support the mission of the department of public safety; and
- provide transparency in the use of video camera technology in achieving a safe and secure campus environment.
Security camera systems include any electronic service, software, or hardware directly supporting or deploying a security camera. Security camera monitoring is the occasional, real-time review or watching of security camera feeds. Security camera surveillance is the digital or analog recording of the feed from a security camera.
Responsibilities and Authority
The director of public safety is responsible for overseeing security cameras and 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;
- 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;
- creating and approving the procedures for security cameras and their use; and
- ensuring operators are trained in the appropriate use of security cameras, in compliance with training on legal and ethical standards provided to public safety officers.
Security Camera Placement
The department of public safety may establish temporary or permanent security cameras in public areas of the campus.
Pursuant to Maryland law, security cameras may not be used in private areas of the campus unless advance notification is given to any individual entering the private area. Private areas include bathrooms, shower areas, locker and changing rooms, areas where a person might reasonably change clothes, private offices, and rooms for medical, physical, or mental therapy or treatment. When security cameras are permitted in private areas, the camera will be used narrowly to protect money, real or personal property, documents, supplies, equipment, or pharmaceuticals from theft, destruction, or tampering.
To the maximum extent possible, security cameras will not be used to get close-up video through the windows of any private residential space or commercial space located off campus. If needed, electronic shielding will be placed in the security camera so that the security camera cannot be used to look into or through windows. Additionally, security cameras will not be directed at the windows of any private building not on college property.
Audio recordings are prohibited.
Security Camera Feeds and Recordings
The department of public safety may review and monitor security camera feeds and recordings as needed to support investigations and to enhance public safety. The director of public safety may assign staff to review and monitor security camera feeds and recordings. Monitoring or surveillance of individuals based on characteristics of race, gender, ethnicity, sexual orientation, disability, or other protected classifications is prohibited.
Signs will be posted on campus indicating that video surveillance is used to promote safety at the college. The placement of and the text on the signs will be subject to the review and approval of the director of public safety, in collaboration with the public relations and marketing office.
Use of Recordings
All video surveillance records are the sole property of HCC. Reproduction of HCC’s video surveillance recordings is prohibited unless authorized by the director of public safety or the vice president of administration and finance. Viewing of surveillance camera footage, either live video feed or recordings, will be conducted by authorized public safety personnel. Other individuals who may have a legitimate need to view recorded video data may be permitted to do so, but only at the discretion and with prior approval of the director of public safety or a designee.
In accordance with applicable federal and state laws, video recordings will be released in response to court orders or subpoenas and to law enforcement personnel as part of ongoing investigations relating to college incidents and personnel. Recorded data may also be shared interdepartmentally for legitimate access needs, such as disciplinary proceedings against students or employees. All such disseminations of video footage shall be documented in the public safety video request log.
It is public safety department policy that video surveillance records related to open or active investigations will not be released to either involved or third parties under the authority of the General Provisions Article of the Annotated Code of Maryland §4-351. However, there may be occasions when, upon the advice of legal counsel, the college may permit a third party to view a recording while not receiving a copy. Video evidence relevant to a code of conduct violation will only be released at the discretion of the director of student conduct or a designee, in accordance with the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99). A person denied video recording access has the right to appeal that denial under the provisions of Title 4 of the General Provisions, Maryland Public Information Act (MPIA).
Access to Video Surveillance Records under the Maryland Public Information Act
The following steps must be followed to access video surveillance records under the Maryland Public Information Act:
- MPIA requests to view security video surveillance records may be addressed to the director of public safety (DPS) at Howard Community College. MPIA requests made to the DPS will follow the steps outlined in college procedure, 61.04.02-Maryland Public Information Act Requests.
- When an MPIA request for a surveillance record is submitted to the DPS, the DPS will inform the president’s office for record keeping purposes. The department of public safety will have the requester prepare a public information act request form, available in the public safety office, to facilitate the submission of requests and prompt review by the DPS or designee. A copy of the completed form and a written explanation of the video shown or provided to the requester by the DPS or designee, including the viewing or release date, must be sent to the office of the president by the DPS.
- After review of the MPIA request, the DPS or designee may permit the requester to view a video surveillance record, particularly if time and other factors create circumstances that require prompt inspection of a surveillance record.
- If a video surveillance record becomes information or evidence in an investigation or becomes information in a matter relating to student or employee discipline, the DPS may deny the request for a copy of the video surveillance record. The requester will then be required to obtain a court subpoena or court order to receive a copy of the requested surveillance record.
Some requests for public information may incur costs. Details related to costs are outlined in college procedure, 61.04.02-Maryland Public Information Act (MPIA) Requests.
Records covered under the MPIA include only those which are in existence at the time of the request. Unless retained separately as part of the department’s internal investigative process, video recordings are only available within a limited timeframe, normally 14 days, after which the recordings are overwritten by the system.
Retention of Security Camera Recordings
As noted above, security camera recordings are normally retained for a period of 14 days. Recordings transferred to CDs or other drives for investigative purposes will be retained for a period of three years and indexed to the original incident report number. This retention period may be extended at the request of the college’s legal counsel, the director of public safety, or the senior director of athletics and student conduct, or as required by law.
The director of public safety will ensure that records related to the use of security cameras and recordings from security cameras validate compliance with this procedure. Staff who maintain or support security camera technology must also maintain records and systems to ensure compliance with this procedure.
At the direction of the vice president of administration and finance, the director of public safety will periodically review the security camera systems and procedures for compliance with applicable law and institutional policies, and provide the vice president of administration and finance 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, as determined by the college president.Effective Date: 09/10/21
President's Office Use: VPAF/PRES