Middlebury recognizes the importance of utilizing best practices for on-campus safety and security, including integrating technology into its safety planning and practices.
Security cameras are used to observe and record certain public areas with the purpose of enhancing safety and security on Middlebury’s Vermont campus, and shall be implemented with appropriate protections for personal privacy.
Information obtained from the Security Camera System shall be used for safety and security purposes and for investigations pertaining to violations of law and Middlebury policies. The specific functions of the Security Camera System include deterrence, detection, property protection, personal safety, situational awareness and investigative assistance. This Policy details procedures for installation, security, access, monitoring, training, retention, destruction and provides a complaint process. Reasonable measures are used to protect individual privacy and restricted Middlebury information.
|Responsible Senior Administrator||Executive Vice President for Finance and Administration|
|Policy Contact||Director, Department of Public Safety|
|Effective Date||February 25, 2020|
|Last Update||February 2020|
Next Review Date
Spring 2022. Public Safety convenes representatives from Human Resources, Student Affairs, the Dean of the Faculty, the General Counsel, Facilities Services (Facilities) and Information Technology Services (ITS).
Who Is Affected By this Policy
All individuals on Middlebury’s Vermont campus, including faculty, staff, students, and visitors.
This Policy does not apply to the existing security camera system at the Museum of Art, at this time; nor does it apply to cameras used for purposes other than security (e.g., recording public performances or events, interviews, academic purposes including research, or cameras used for specialized observation such as of ATMs or construction equipment) or recordings made by individuals or authorities, including law enforcement authorities, other than Middlebury.
Security Camera System: Any video installation in Vermont by Middlebury with capacity to view or record Middlebury-owned or Middlebury-controlled spaces in order to assess and enhance safety and security.
Recording Systems: Recording systems referenced in this policy are the computerized information storage and monitoring systems (DVR, Digital Video Recording Devices and/or NVR, Network Video Recorder) that are maintained by the Department of Public Safety and physically located in a secure location on the Vermont campus.
I. Installation and Operation
- Any requests for Security Cameras, including the justification for the request, must be submitted to the Director of Public Safety. Public Safety, ITS and Facilities will review all requests, proposals, and recommendations for Security Camera installations, the proposed locations, and related infrastructure needs. The Director of Public Safety has the authority to approve, reject or modify the request.
- The Middlebury College Department of Public Safety has the responsibility to coordinate with ITS and Facilities, as well as other Middlebury officials identified herein, to effectively select, operate, manage, and monitor Middlebury’s Security Camera Systems pursuant to this Policy.
- Middlebury College will limit camera locations, positions and views of certain areas. Security cameras will be placed in locations that provide the best view for safety, security and protection of the Middlebury community and property, while maintaining individuals’ reasonable expectations of privacy. All security cameras, including those in temporary locations or for active monitoring, will only be installed with the advance approval of the Director of Public Safety and the appropriate Middlebury vice president.
- Security cameras will not view private bedrooms, bathrooms, locker room dressing/shower areas, offices, classrooms not used as a lab, or areas through windows. Moreover, no audio shall be recorded with the Security Camera System.
- Unless the Director of Public Safety and the appropriate vice president provides prior approval, all Security Camera installations should be visible. Wherever reasonably possible, Middlebury will post signage indicating the presence of video recording
- The installation of non-operational Security Cameras is prohibited.
- Security Cameras are installed and configured to prevent tampering or duplicating recorded information. Any new security camera must connect to the College’s main system, under the oversight of Public Safety.
- The Department of Public Safety is responsible for monitoring recommendations and changes in the security industry regarding the Security Camera System consistent with best practices and all applicable laws. Public Safety is also responsible for maintaining a master inventory of all Security Cameras and monitoring the functionality of the Security Camera System on an appropriate basis in order to make notifications for service or maintenance needs.
- On an annual basis, Public Safety will lead an evaluation of the System in coordination with ITS and facilities.
II. Security and Access to Information
- Images collected by the Security Camera System will be secured appropriately to protect against unauthorized access, alteration or dissemination, and in compliance with legal requirements. All video recording devices and camera software monitoring equipment that is part of the Security Camera System will be stored in a secure location with access to authorized personnel only.
- Security Cameras are streamed into the Department of Public Safety and can be viewed remotely by authorized personnel. They are not monitored continuously under normal operating conditions but may be monitored for legitimate safety and security purposes that include, but are not limited to: high-risk areas or events, restricted access areas/locations, monitoring of access control systems, in response to an alarm, specific investigations, violations of campus policies, situational awareness of campus events.
- Security Camera recordings may not be altered, except that they may be edited to create relevant excerpts at the direction of the Director of Public Safety. An unaltered copy of the original recording will be created and retained.
- Public Safety personnel are prohibited from using or disseminating information or images acquired from the Security Camera System, except for official Middlebury purposes and within the scope of their employment. All information obtained and/or observations made via the use of the Security Camera System are considered confidential, are the property of Middlebury College, and may only be used for official College and law enforcement purposes with the approval of the Director of Public Safety.
- Only authorized Middlebury personnel, as determined by the Director of Public Safety and appropriate vice president, will be involved in, or have access to, Security Camera monitoring or the video recordings.
- A request from a Middlebury official for the release of any Security Camera System recordings must be submitted in writing to the Director of Public Safety or his/her designee.
- Any legal documents (subpoena, warrant, court order) in connection with any criminal or civil action, or for any risk management purpose from an outside entity requesting or directing access to or release of security camera recordings must be directed to the Office of the General Counsel.
III. Monitoring and Recording
- Middlebury’s use of Security Cameras for monitoring or recording is limited to use consistent with professional practices and legal requirements, and consistent with Middlebury policies.
- Security Camera control operators will monitor locations, events, and other conduct and activities based on risk and observed behavior, not individual characteristics. Monitoring and recording shall be conducted in ways that do not target individuals or groups based on protected personal characteristics (e.g., race, gender, ethnicity, sexual orientation, disability, etc.)
- The Department of Public Safety shall provide all authorized personnel with technical, legal, and ethical training for the responsible use of the Security Camera System. All personnel will be provided with a copy of this Policy and will sign an acknowledgement of receipt. Public Safety supervisors shall be responsible for the supervision of trained personnel and maintaining the training records.
IV. Retention of Recordings
All Security Camera System recordings shall be stored in a secure College location for a period not exceeding thirty (30) days and will then be erased or written-over. Exceptions include recordings subject to a legal hold, recordings required for criminal or civil legal actions, in connection with an on-going Middlebury investigation or otherwise necessary for Middlebury purposes, as determined by the Director of Public Safety.
V. Complaints or Violations
Public Safety is responsible for investigating any complaints or concerns regarding the misuse of the Security Camera System and determining if the policy is being followed. If a violation has occurred, the Director of Public Safety will consult the General Counsel and/or Human Resources regarding an appropriate outcome. Misuse of the Security Camera System or any images captured thereby is a serious violation of this Policy.
Department of Public Safety
125 South Main St.
Middlebury, VT 05753