Administrative Policies and Procedures Manual - Policy 6140: Video Security Systems

Date Originally Issued: 06-22-2023

Authorized by RPM 8.2 (“Law Enforcement on Campus”)

Process Owner: Executive Vice President for Finance and Administration

1. General

As part of its commitment to provide a safe and secure environment on campus, the University of New Mexico may install video security systems (“Video Security Systems”) in public areas to enhance the safety and security of the University community, while preserving reasonable privacy expectations, academic freedoms, and civil liberties of the campus community. This policy regulates the installation and use of video security systems for law enforcement, safety, and security purposes on campus, which for the purpose of this policy, includes any property owned/leased by and/or controlled by the University. Only authorized video security systems may be installed on campus.

Video Security Systems are defined as wired or wireless cameras, including the software, cameras and related hardware for recording events from an authorized location for purposes of improving campus safety and security.

The use of recording devices for purposes other than for law enforcement, safety, and security is outside the scope of this policy; however, such uses may be restricted or prohibited under state or federal law, contractual obligations, or other policies. Such uses include video that is collected for purposes of authorized research, education and training, patient care and medical treatment or areas containing HIPAA Protected Health Information (PHI), personal mobile recording, video conferencing, or commercial use is not subject to this policy, but may be subject to additional policies or guidelines.

2. Authority and Responsibilities

2.1. UNM Police Department

The Executive Vice President for Finance and Administration and the Chief of the UNM Police Department have delegated day-to-day responsibility to the Security Operations Director for enforcing this policy, including the approval, installation, and oversight of video security systems on campus. The Security Operations Director will periodically review units’ or branch campuses’ guidelines on video security and may recommend alternate policies or operational procedures. The UNMPD shall maintain an up-to-date, comprehensive inventory of camera installations and the storage locations of all Video Security System Network Video Recorders (NVR’s) subject to this policy. This policy shall be reviewed on a yearly basis by the Security Operations Director.

2.2. Security Operations Task Force

Chaired by the Security Operations Director, the Security Operations Task Force is charged with developing standards and design specifications for video security systems and related software and hardware on campus. The Security Operations Task Force oversees the ongoing implementation of such standards and design specifications to help ensure compliance with this policy and associated guidelines and procedures.

2.3. Requesting Unit

Units desiring to install video security systems must submit a request to the Security Operations Director prior to the vendor providing a quote or assessment. The requests must include written approval by the appropriate dean, director, department head. The UNM helpdesk may be utilized to complete a request. Help desk link

The initial cost of video security system hardware, cabling, and installation is the fiscal responsibility of the requesting unit. Cost sharing may be an option for cameras that benefit other units within a multi-unit building. Non-functional or unauthorized systems or components are not allowed and must be reported to the Security Operations Director; these systems must be replaced or removed at the unit’s expense. All new installations will be considered an extension of the UNM Enterprise Video Security System and UNMPD shall be given access to video security systems.

2.4. Acceptable Video Use

Individual departments within the University may define additional policies or procedures for cameras in their environments. These terms must be consistent with this overall policy but may provide additional detail, guidelines, and/or restrictions. Such policies may be more restrictive, but not less restrictive than, this policy. Where such policies and procedures exist, the enforcement mechanisms defined within this policy shall apply. Individual departments are responsible for publicizing both the terms they establish and their policies concerning the authorized and appropriate use of the equipment and services for which they are responsible. In such cases, the department administrator shall provide the cognizant vice president and the University Security Operations Director with a copy of such supplementary policies, and approval of the Security Operations Director is required prior to their implementation. All requests for video distribution must follow the current University of New Mexico policy on https://publicrecords.unm.edu/

1. Requesting units shall have the ability to monitor only their video security systems and not all cameras on the Enterprise Security Camera System

a) Users will not have the ability to download or copy video from the system. That must be requested in writing through the Security Operations Directors office.

3. Installation

Video security systems installed after the effective date of this policy must comply with this policy and the standards and design specifications adopted by the Security Operations Task Force. In the absence of standards or design specifications for a particular request or situation, decisions will be made by the Security Operations Director.

Units are required to register their existing video security systems with the Security Operations Director within thirty days of the effective date of this policy. Existing installations must be brought into compliance with this policy and the standards and design specifications when units initiate repair, replacement, or upgrades of video security systems, or within eighteen months of the effective date of this policy, whichever is sooner.

Use of video security systems is limited to public areas, unless specifically authorized by the Security Operations Director. Video security systems may not be installed in bathrooms, shower areas, locker and changing rooms, faculty and staff offices, non-public areas of on-campus housing facilities, or other areas where a reasonable expectation of privacy exists.

3.1. Notifying Signage

Locations with video surveillance systems should, as deemed appropriate, post signage stating,

"Security cameras in use in this area, pursuant to UAP 6140. For questions, contact UNMPD."

4. Use and Monitoring

The use and monitoring of video security systems will be conducted in a professional, ethical, and legal manner and will not violate reasonable expectations of privacy. The intended purpose of video security systems is to enhance public safety and security, protect university assets, and deter crime. Video security systems are not necessarily monitored in real time, twenty-four hours per day, seven days per week.

4.1. Prohibited Uses

It is strictly prohibited to monitor individuals based on characteristics of race, gender, ethnicity, sexual orientation, disability, or other protected classes, or based on union membership. It is also prohibited to monitor or record sensitive institutional or personal information, such as medical, personnel, or student records.

Video security systems may not be used by unauthorized users (see Section 4.3). Unauthorized use or access is prohibited and may lead to disciplinary action. Suspected misconduct regarding video security systems may be reported according to UAP 2200 (“Reporting Suspected Misconduct and Whistleblower Protection from Retaliation”).

4.2. Accepted Uses

Video footage can be used for the protection of the university community or its assets, law enforcement purposes, and for investigations of alleged violations of university policies.

4.3. Authorized Users

Access to video security systems is limited to authorized users. The authorized users of video security systems are individuals who have been assigned responsibility by the appropriate dean, director, department head, or branch campus chancellor. Each user will have their own account created and will not share account login information (UAP 2500; “Acceptable Computer Use”).

The Security Operations Director will train employees in the appropriate use of the video security systems equipment. On an annual basis, all employees involved in the supervision, use, or monitoring of video security systems will:

Be trained in the protection of personal privacy and information, including protected health and student information covered under federal and/or state law;
Be trained in the security of recorded images; and
Receive a copy of this policy and provide written acknowledgement that they have read and understood its contents.

Once employees receive such training, they will be considered authorized users. The Security Operations Director shall maintain a list of all authorized users. Upon reassignment of duties or separation of authorized users for any reason, units must notify the Security Operations Director and ensure that camera operator access is withdrawn within 24 hours of termination or transfer.

5. Retention, Review, and Release of Recorded Video

5.1. Retention

All recorded videos must be stored in an approved secure location established by the Security Operations Director or UNM IT. The storage locations will be accessible only to authorized users, and configured to prevent unauthorized modification, duplication, or destruction.

Recorded videos will be retained for no less than thirty (30) days. Recordings will be kept for a longer period if the recording is a part of a criminal or civil court proceeding, employment investigation, legal hold, court order, or where there is a demonstrated business need by an investigative body that is authorized by the University of New Mexico to conduct investigations. The electronic recordings captured by the video security systems are the property of the University. Video used as part of a criminal investigation will be subject to the UNM Police Department evidence SOP section. Video retained for a criminal investigation will be disposed of in accordance with UNMPD SOP for destruction of evidence. Video requested for the non-criminal proceedings will be retained by the requesting unit in accordance with applicable state law or university policy.

Investigative bodies outside of UNMPD are responsible for developing procedures for complying with these and other university records requirements.

5.2. Access

Video security systems may only be accessed by authorized users. Authorized users have viewing access only and may not copy, alter, or download live or recorded images, except as permitted by Section 5.3 below.

UNMPD personnel will be permitted access to monitor all video security systems at all times for security and law enforcement purposes.
UNM IT personnel, will be permitted access to video security systems as needed for the purposes of installing and maintaining the video security systems.
Approved vendors will be permitted access to the video security system as needed for the purposes of installing and maintaining the video security system. This includes regular maintenance and installation of new cameras on campus.

5.3. Release

Recordings obtained from video security systems will only be released under the following circumstances:

Law Enforcement, Authorized Internal Investigations, or Legitimate Business Use of the University of New Mexico. UNMPD will cooperate and assist law enforcement as requested with criminal investigations. Requests for access to recorded video for investigations or legitimate business use may be made to the Security Operations Director.
Litigation. Requests that take the form of subpoenas or other legal documents compelling production must be submitted to and approved by the Office of University Counsel.
Public Records. All other requests should be forwarded to the Custodian of Public Records.
Authorized internal investigations or legitimate business use of the University of New Mexico.

6. Equipment

This policy is intended to standardize the video security systems used on all University of New Mexico campuses. For those buildings on the Albuquerque campus, UNMPD will have the ability to use the system to enhance the security on campus. The use of the video security system will be especially useful during a critical event on campus. Cameras that are listed on the Secure Equipment Act of 2021 must be removed immediately.

Any deviation from the standardized products: must be reviewed and approved in writing by the Executive Vice President for Finance and Administration, the Chief of the UNM Police Department or their delegate the Security Operations Director.

6.1 Cameras

Refer to UNMPD website, Security Operations tabfor details on current video security vendor.

6.2 Video Storage

The recommended video storage will be done on vendor approved servers, located on UNM property in secure IT server rooms.

7. Appeals Process

The Executive Vice President for Finance and Administration, in consultation with the Chief of Police and the Office of University Counsel, may grant exceptions to this policy. Exceptions shall be documented in the inventory of video security systems.

Decisions by the Security Operations Director and Security Operations Task Force may be appealed to the Executive Vice President for Finance and Administration.