Title
University of North Carolina at Chapel Hill Policy on Security Cameras
Introduction
Purpose
This policy explains where, when, why, and how the University of North Carolina at Chapel Hill (“UNC-Chapel Hill” or “University”) uses Security Cameras, also known as closed-circuit television (CCTV) cameras.
UNC-Chapel Hill recognizes the need to balance an individual’s right to be free from invasion of privacy and the University’s duty to promote a safe environment for all community members. This policy is intended to help the University balance those interests.
Scope
This Policy provides guidelines for authorization and use of Security Cameras on property, space, facilities, and grounds owned, leased, licensed, or operated by UNC-Chapel Hill.
This Policy does not apply to UNC Hospitals or other regional UNC Health Care facilities.
Policy
Policy Statement
All video monitoring must be conducted in accordance with applicable laws and regulations, and in a professional and ethical manner balancing the University’s duty to promote a safe environment with the privacy rights held by UNC-Chapel Hill faculty, staff, students, and guests.
Information obtained from security cameras is considered Tier 2 – Sensitive Data and must be handled with an appropriate level of security to protect against unauthorized access, alteration, or disclosure in accordance with the Information Classification Standard.
Unapproved or nonconforming devices in violation of this Policy are subject to removal.
All University Units using Security Cameras are responsible for implementing this policy in their respective operations.
Exceptions
This Policy does not apply to the following:
- Cameras used for legitimate instructional, research, or creative purposes;
- Cameras used for journalistic purposes;
- Cameras used for capturing public events and performances;
- Cameras used for viewing and/or recording public images in public spaces for University purposes, including video conferencing, marketing and recruitment, employee training, athletic coaching, or public observation, such as construction sites;
- Use of Security Cameras, either overtly or covertly, on a short-term basis for legitimate law enforcement purposes including, but not limited to, the gathering of evidence for a criminal investigation;
- Personally owned and operated cameras, webcams, or other recording equipment;
- Cameras in Police offices and patrol vehicles and body-worn cameras; and
- Other cameras used for non-security purposes specifically excepted from this Policy by the Security Camera Coordinator on a case-by-case basis.
The Security Camera Coordinator maintains responsibility for oversight of cameras in Police offices and patrol vehicles, and body-worn cameras. However, these cameras are subject to unique technical, administrative, and regulatory requirements addressed by state law and Police directives and are therefore not subject to this Policy.
Oversight
The Enterprise Camera Oversight Committee ("the Committee") will assess and approve requests to install, modify or decommission Security Cameras. The Committee will oversee the Policy development and strategy, including image viewing, retention, and release. It is chaired by the Vice Chancellor for Institutional Integrity and Risk Management (IIRM) and includes representatives from UNC Police, Office of Risk Management, Information Technology Services (ITS), Student Affairs, and Facilities Services - Building Services Life Safety Access Control, and is advised by the Office of University Counsel.
Why UNC-Chapel Hill Uses Security Cameras
UNC-Chapel Hill may place Security Cameras on University property where necessary and appropriate to achieve the following goals:
- Protect University faculty, staff, students, guests, and University property; and
- Detect, deter, and/or assist in the investigation of criminal activity on University owned, leased, licensed or operated property, facilities and grounds.
Security Cameras are not monitored in “real time” except in rare situations. Primary use of cameras is to aid in emergency response and post-incident investigation. Cameras may be monitored in “real-time” when safety or security concerns, event monitoring, ongoing investigations, alarms, or other situations warrant such high-level monitoring.
Allowed Uses
Security Cameras may be used for the:
- Protection of Buildings and Property – Building perimeter, entrances and exits, lobbies and corridors, receiving docks, special storage areas, laboratories and research facilities, cashier locations, etc.
- Monitoring of Access Control Systems – Monitor and record restricted access transactions at entrances to buildings and other areas.
- Monitoring of common areas and spaces on university property.
- Verification of Security Alarms – Intrusion alarms, exit door controls, hold-up alarms.
- Video Patrol of Public Areas – Transit stops, parking lots, public streets (enclosed and unenclosed), shopping areas, vehicle intersections, etc.
- Criminal Investigation – Robbery, burglary, and theft surveillance.
- Protection of Pedestrians – Monitoring of pedestrian and vehicle traffic activity.
- Parking and Traffic management – Monitoring of parking facilities; inside and outside of P2P vehicles.
- Event / Crowd management – Cameras are utilized by campus safety and emergency response personnel to support event management requirements for sporting events, large crowd events, and other high-profile events.
Prohibited Uses
Cameras generally cannot be installed in or view areas where there is a reasonable expectation of privacy, which include, but are not limited to:
- Restrooms, locker rooms, lactation rooms;
- Private offices; and
- Residential rooms or views through residential windows.
Security Cameras are prohibited from viewing bathroom entrances or other prohibited areas through windows. Any view given will be no greater than what is available with unaided vision.
The recording of audio is prohibited.
Purchasing Security Cameras
Design and procurement expenses of any Security Cameras or related infrastructure and systems will be funded by the requesting unit in coordination with Institutional Integrity and Risk Management, Building Services/Life Safety Services, ITS, and UNC Police. The requesting University Unit must get written authorization from the Security Camera Coordinator before purchasing new security camera equipment. Actual purchase of equipment and installation services must follow University Purchasing Guidelines delineated in University Finance Policy 1231 - Solicitations of Quotations, Bids and Proposals and/or University Finance Policy 1251 - Small Order Policy.
Budgets for such projects must include appropriate provisions for their integration into the University’s Enterprise Security Camera System, for the ongoing maintenance and eventual replacement of the equipment, and for the operational expenses of storing and managing the recordings.
Security Camera Placement
Placement of Security Cameras is critical to maximize the safety and protection of the University community and property and minimize the invasion of privacy. Security Cameras must be placed in coordination with the Security Camera Coordinator and the Vice Chancellor for IIRM, or their designee.
Placement Restrictions
Cameras generally cannot be installed in or view areas where there is a reasonable expectation of privacy, which include, but are not limited to:
- Restrooms, locker rooms, lactation rooms;
- Private offices; and
- Residential rooms or views through residential windows.
Security Cameras installed in a residential housing area will only be able to view exterior common areas.
Non-University Owned Property
The UNC-Chapel Hill campus includes areas of property that are not owned by the University. The Security Camera Coordinator and IIRM must coordinate with the non-University property owner to ensure seamless coverage and access through the non-University property. This may include:
- Getting authorization to place University Security Cameras on non-University property, or
- Obtaining access codes to live and archived security feeds to non-University owned Security Cameras.
Signage Requirements
Appropriate signage may be required by the Security Camera Coordinator to provide notice of the Security Cameras and enhance the crime prevention value of the Cameras. Placebo signage and/or placebo security cameras are not allowed.
Security Camera Installation and Ongoing Maintenance
All Security Cameras must connect to the University’s Enterprise Security Camera System. Security Cameras and related infrastructure and systems must follow IT policies, and specific requirements for camera configuration determined by ITS to restrict network traffic and protect from unauthorized access.
Each University Unit must provide the Security Camera Coordinator and IIRM:
- Direct access to their Security Camera’s live and archived video feeds, and
- A campus map marked with the location and viewing range of each Security Camera.
If access codes or maps are updated/changed, the University Unit must provide updated copies to the Security Camera Coordinator and IIRM within five (5) business days of the change.
University Units requesting Security Cameras covering interior or exterior spaces must provide the necessary funding for the maintenance, repair, and replacement of those cameras.
Viewing Images
Personnel with access to University Security Cameras must be trained in the effective, legal, and ethical use of monitoring equipment. Security Camera Equipment Operators are forbidden from monitoring individuals based on characteristics of race, gender, ethnicity, sexual orientation, disability, or other classifications protected by the University's Policy on Prohibited Discrimination, Harassment and Related Misconduct Including Sexual and Gender-Based Harassment, Sexual Violence, Interpersonal Violence and Stalking or the University’s Policy on Prohibited Sexual Harassment Under Title IX.
Only the following personnel or entities will be granted access to any Enterprise Security Camera System real time video or recording(s):
- Security Camera Equipment Operators from the University Unit who owns the Security Cameras for the enumerated business purposes for which the cameras were installed.
- Division of Facilities - Building Services Life Safety Access Control Services employees for the purpose of system maintenance.
- UNC Police employees for the investigation of crimes against persons or property.
- Campus safety personnel and their designees for the purpose of monitoring an on-going situation or emergency.
- University personnel who "need-to-know" for purposes of compliance with federal, state, and local laws and regulations or an administrative investigation or proceeding, as authorized in writing by the Vice Chancellor of IIRM.
Storing and Release of Recordings
All recordings will be stored in a secure manner and can only be accessed by authorized personnel.
Security Cameras and related infrastructure and systems will be configured to prevent Security Camera Equipment Operators from tampering with or duplicating recorded information. UNC Police will have the ability to duplicate recorded information only for investigative purposes.
Records of access to, and release of, Security Camera recordings must be sufficient to demonstrate compliance with this policy.
Retention
Recorded video will be stored for 30 calendar days and will then be erased or written over, unless retained as part of a criminal investigation or court proceedings (criminal or civil), or other bona fide use as approved by the University's Vice Chancellor for IIRM, the Director of Internal Audit, and/or the General Counsel.
UNC Police, or their designee, must initiate the request for recorded video data for the purposes of their investigations.
Roles and Responsibilities
Security Camera Equipment Operators must:
- Be trained in the technical, legal, and ethical use of Security Camera equipment and video.
- Use Security Camera equipment and video in accordance with University policy, including without limitation policies regarding non-discrimination.
- Refrain from recording, duplicating, or permitting unauthorized access to Security Camera video in a manner that exceeds their authorization or that is inconsistent with this Policy.
- Provide written acknowledgement that they have read and understand this Policy and the limits of their authorization.
Security Camera Coordinator will have responsibility for:
- Monitoring compliance with this Policy and applicable laws regarding Security Cameras.
- Identifying and recommending locations on campus where Security Cameras would be necessary and appropriate.
- Performing regular inspections of all Security Cameras to ensure functionality and compliance with this Policy.
- Training and authorizing Security Camera Equipment Operators.
- Ensuring Security Camera Equipment Operators have been provided with appropriate work facilities so that unauthorized individuals cannot view Security Camera video.
- Reviewing and approving Security Camera Installation Requests.
Vice Chancellors, or their designees, have responsibility under this Policy for:
- Assisting the Security Camera Coordinator by making recommendations about the level of security required on various campus locations.
- Reviewing all requests for the purchase and installation of Security Cameras for locations over which they maintain responsibility.
- Submitting requests for the authorization of Security Camera Equipment Operators to the Security Camera Coordinator. Such requests must be in writing and detail the scope and nature of the control and access proposed Security Camera Equipment Operators will have to Security Camera equipment and video.
Definitions
Enterprise Security Camera System - The security cameras, video management system software and related infrastructure components such as data storage for video recordings.
Private areas - Areas in which a person has a reasonable expectation of privacy, including, but not limited to, non-common areas of residence halls, residence hall corridors, 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 University employees or the safeguarding of their possessions, such as lounges and locker rooms, and areas dedicated to medical, physical, or mental therapy or treatment are considered private areas for the purpose of this policy.
Public 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, classrooms, lecture halls, study rooms, lobbies, theaters, libraries, dining halls, gymnasiums, recreation areas, and retail establishments. Areas of the University in which persons would not have a reasonable expectation of privacy, but to which access is restricted to certain University employees, such as storage areas, are also considered public areas for the purpose of this policy.
Security Camera - A device used to transmit images that can be viewed remotely for the purpose of protecting public safety or institutional property and to detect, deter, and/or assist in the investigation of criminal activity.
Security Camera Equipment Operators - Individuals designated by UNC-Chapel Hill as having responsibility for controlling University security camera equipment and/or viewing Security Camera video.
Security Camera Coordinator - An individual appointed by the UNC Police Chief of Police who is responsible for overall governance of the Security Camera program.
University Unit - The University division, department, or school for which the Security Camera is installed.
Related Requirements
External Regulations and Consequences
University Policies, Standards, and Procedures
Contact Information
Policy Contact
Title: Associate Vice Chancellor for Campus Safety and Risk Management
Name: Derek B. Kemp
Telephone: (919) 962-2473
Email: derek.kemp@unc.edu