Video Surveillance

Policy 14.9
Approved by:	President
Responsible Officer:	CHIEF INFORMATION OFFICER
Responsible Office:	INFORMATION TECHNOLOGY SERVICES
Originally Issued:	06/30/2025
Last Revision:	NEW
Category:	TECHNOLOGY
Related Policy
SD BOR 7.1 Acceptable Use of Information Technology Systems

1. Reason for Policy

   This policy establishes guidelines for the use of security cameras on University premises, to provide a safe and secure environment for the University community in support of the University’s mission, enhancing security while aiding law enforcement and preserving the privacy of the University Community. Video Surveillance Cameras are used as a means of detecting and assisting in the investigation of criminal activity and breaches of relevant University Policies and behavioral codes of conduct, while promoting the safety of individuals and the security of assets and property. The policy ensures compliance with federal, state, and local privacy laws, SDBOR Policy 7.1, and formalizes procedures for camera system installation, use, and data handling.

   This policy applies to all facilities within the purview of DSU, extending to off-campus or affiliate sites where the University exercises control over space within the premises. This policy applies to all employees, students, guests, and contractors of DSU, including any individual or entity permitted to use or have access to the Video Surveillance System, in the use and installation of video recording and surveillance technology.

2. Definitions

   1. Administrator. A user authorized within the video surveillance system with permissions to install, configure, modify, or delete cameras, as well as manage user permissions within the system.
   2. CIO (Chief Information Officer). Campus Chief Information Officer/Vice President of Technology is the department head for the DSU (Dakota State University) technology department.
   3. Covert Cameras. Concealed surveillance devices designed to capture video discreetly without the subject's knowledge, typically used for security, investigative, or observational purposes in a covert manner.
   4. Empty/Dummy/Placebo Cameras. Non-functional camera units resembling real surveillance cameras, lacking recording or monitoring capabilities, are often used as a deterrent to illicit activities without actual surveillance functionality.
   5. ITS. Information Technology Services. The official technology department for Dakota State University and subsumed departments.
   6. A user authorized within the video surveillance system with privileges to observe live video feeds and retrieve stored video footage from selected cameras within their access rights.
   7. Public Areas. Spaces that are open to public use, such as classrooms, lecture halls, study rooms, lobbies, library, parking lots, building entrances and exits, recreational facilities, dining, and retail venues.
   8. Reasonable Expectation of Privacy. The legal and ethical principle that individuals have a right to privacy in areas where they can reasonably expect not to be observed or recorded. On a campus, this typically includes private spaces such as restrooms, locker rooms, private offices, classrooms without technology, residence hall rooms, and other locations designated for personal use. Video surveillance must not be conducted in these areas. Surveillance is generally limited to public or semi-public spaces—such as hallways, entrances, computer labs, commerce areas, and outdoor areas—where there is no reasonable expectation of privacy and where security or safety concerns justify monitoring.
   9. Security Camera. A camera deployed to surveil or record public spaces with the aim of bolstering public safety, deterring theft and criminal behavior, and probing incidents.
   10. University/Campus Community. The university students, faculty, staff, vendors, visitors and guests who regularly or periodically occupy and/or utilize the campus of the University.
   11. Video Surveillance Recording. A capture of security camera footage.
   12. Video Surveillance System. DSU’s array of university-owned cameras deployed to enhance the safety and security of the campus community, alongside the corresponding infrastructure and software essential for storing and retrieving the captured images.
   13. Viewer.  A user authorized within the video surveillance system with privileges to observe live video feeds from selected cameras within their access rights.  Viewers do not have access to stored video.

3. Statement of Policy

   1. The CIO, or designee, shall be responsible for establishing and disseminating policies and procedures regarding video surveillance and assuring compliance with those policies and procedures.
   2. Installation
      
      1. All security cameras shall be installed only after the approval of the CIO, and their purchases shall be made through ITS.
      2. The CIO, or their designee shall assess all new camera surveillance requests and grant approval. During this evaluation, the CIO, or designee shall consider the reasonable privacy expectations of individuals in the area under consideration, alongside the space's characteristics and potential safety and security concerns.
      3. In installing cameras, the University will prioritize the privacy of the campus community while also striving to balance this with its safety requirements.
      4. The University may not install cameras in areas with reasonable expectation of privacy.
      5. The University shall place appropriate signage to ensure that employees, students, visitors, and members of the community are aware that video surveillance is in use in the form of “THIS AREA IS SUBJECT TO VIDEO SURVEILLANCE AND RECORDING FOR SECURITY PURPOSES,” to comply with all relevant federal and state laws.
      6. The use of empty, dummy, or placebo cameras, which lack actual recording or surveillance capabilities, is strictly prohibited.
      7. The installation of covert cameras is prohibited.
      8. Cameras may be installed for one or more of the following purposes:
         1. Property Protection: The capability to capture and store video remotely to document potential property theft or damage, with the goal of identifying and apprehending the perpetrator, for instance, in unstaffed computer labs, dining & common areas, and some parking lots.
         2. Personal Safety: The ability to capture and store video remotely to document crimes against individuals, aimed at identifying and capturing the perpetrator, such as incidents occurring in common areas and some parking lots.
         3. Retail and Cash Handling. To monitor activity in retail or other cash handling zones to minimize losses and aid in investigations.
         4. High-Risk Areas. To monitor high risk areas or restricted access areas and locations.
         5. Special Circumstances. In reaction to alarms, during special events, and in designated investigations authorized by law enforcement and approved by the University or SDBOR General Counsel.
         6. Other Reasons. Any other reason not listed above which is approved by the Chief Information Officer, or designee.
   3. Recording and Monitoring
      
      1. Physical video surveillance does not imply that activity is actively recorded or monitored unless an individual’s or a group’s behavior may warrant specific monitoring with community safety in mind.
      2. Video cameras may be equipped to record video images and audio. Generally, audio recording will not occur unless signage is posted indicating that sounds may be recorded. However, audio may be recorded without signage in areas where access is restricted and as part of an approved investigation, with written consent from the CIO or their designee, and approval from the University Executive Committee or SDBOR General Counsel. In urgent situations, audio may be used without prior approval.
      3. Under typical operation, University camera systems are not under continuous monitoring. Access to view live or recorded video from cameras for property protection and personal safety will only be granted to individuals authorized by the Chief Information Officer or designee. For remote monitoring and authorized local viewing, the live video stream may be monitored by designated staff authorized by the CIO, surveillance administrator or designee.
      4. Operator access to recorded footage shall be controlled and limited to as few authorized individuals as necessary.
      5. Video monitoring and recording shall be conducted in a professional, ethical, and legal manner by Video Surveillance personnel and will be appropriately trained in the lawful and responsible use of Video Surveillance Technology and have a signed Dakota State University Confidentiality Agreement.
   4. Retention.  The CIO, or designee, shall be responsible for the following:
      1. Maintain video surveillance recordings in a secure environment and at no time shall attempts be made to alter any part of the footage.
      2. Retain recordings for a period of at least 30 days or as storage allows.
      3. Retain recordings exported for any purpose for a minimum period of one year from completion of use.
      4. Where the recording forms part of the evidence in court or tribunal proceedings, recordings shall be kept for at least one year following final disposition of the matter including any court reviews and appeals.
      5. Auditable logs of all access, uses and disclosures of video footage shall be kept for future references and in compliance with all relevant federal and state laws and regulations.
   5. Disclosure and Dissemination
      1. Any video recorded, collected, or preserved in any manner shall be the property of DSU and shall not be released to external entities without the prior approval process established hereunder.
      2. The University shall ensure that a disclosure record is maintained, and it includes a description of circumstances justifying the disclosure, the timeframe of footage, the name, title, and agency to whom the footage is being disclosed, the legal authority for the disclosure, the means used to disclose the footage and whether the footage will be returned or securely destroyed after use.
   6. The CIO or designee shall regularly test the University camera installations, data storage, and backups to ensure that they are working properly as intended.
   7. The CIO, or designee, is responsible for monitoring latest developments in the law and security industry practices to ensure that video surveillance usage is consistent with best practices and complies with all federal and state laws.
   8. Non-Compliance: Non-compliance with this policy may result in disciplinary actions, in accordance with established protocols for students, faculty, and staff as outlined in relevant policies such as the student regulations, faculty handbook, or staff handbook. Consequences may include suspension of access privileges, and/ or legal proceedings, depending on the severity of the violation .

   Exclusions. This policy does not apply to the following:

   1. Video equipment for recording public performances/creative or artistic performances and events/sports, interviews/commercial television recordings.
   2. Academic use of video cameras for educational purposes, class recordings by faculty, webcams/video cameras owned and operated by individual members of the University community.
   3. Video cameras or webcams established temporarily or permanently by the University for reasons unrelated to surveillance activity, such as remote monitoring of facility construction to ascertain project progress, campus marketing, public relations initiatives, or fundraising activities.
   4. Use of in-car or body-worn cameras by police while on campus.
   5. Video in ATM machines managed by financial institutions on premises.
   6. The legitimate, academic use of video or image capture activities approved by the University’s Institutional Review Board for the Protection of Human Subjects is also not governed by this policy.

   Exceptions

   The President, CIO, and the relevant Vice President or delegate may approve deviations from or exemptions to this policy, aligning with legal requirements and the University's commitment to enhancing the safety of its community.

4. Procedures (Major)

   1. Video surveillance installation requests shall be submitted to ITS and require approval from the Chief Information Officer or authorized designee.
      
      1. If, upon assessment by the CIO or designee, the request confirms an institutional need for video surveillance, IT resources may be allocated to fund the proposed camera purchase and installation. Approved requests will be included in the queue for scheduling camera installations.
      2. For requests that do not fulfill an institutional need, ITS will allow the requesting department to fund the purchase independently and collaborate with ITS Purchasing to proceed. The hardware, provider, and installation location must comply with the specifications outlined by the University and be integrated into the University's video surveillance system.
   2. Request Access for Transactional Area Monitoring and Asset Protection Surveillance.  Request and provide justification for the need to receive live monitoring access by completing an ITS Quick Ticket Form.
   3. Operator Access for Viewing Live Video and Access to Recorded Video. The direct supervisor of an employee shall request operator access for viewing live video and access to recorded video by completing an ITS Quick Ticket Form.
   4. Process for Requesting Recorded Footage. University staff can request recorded footage by completing the Security Camera Review Request Form.  The form must include justification for the request, including date/time range, location, and the specific purpose aligned with university policy (e.g., safety investigation, property protection, etc.).  All requests must be approved by a University officer at the level of Dean, Vice President, or higher. A record of each request, its justification, approvers, and access outcome will be retained for audit purposes.

5. Related Documents, Forms, and Tools

   IT Quick Ticket

   Security Camera Review Request

   Dakota State University Confidentiality Agreement (under development)

   NIST SP 800-53 (Rev. 5)

6. Policy History

   Adopted: 06/30/2025