601.8 Video Surveillance Policy

600-Campus Facilities Policies / 601.8 Video Surveillance Policy

Date Adopted: 04/22/2024
Date Last Revised: 10/30/25
Issuing Office: Administration and Finance
Approved By: Vice Chancellor for Administration and Finance

Purpose

The purpose of this policy is to regulate the use of Security Camera System (SCS) on University of Montana Western (UMW) Property and formalize the procedures to request a new SCS, update an existing SCS, and request an individual to become an SCS Operator or Investigator. Additionally, this policy outlines the requirements for recording, handling, viewing, retaining, and the dissemination of recorded SCS images.  This policy regulates the use of SCS but should not be construed as a directive or guarantee that SCS will be monitored in real time, twenty-four (24) hours per day, and seven (7) days per week.   

This scope applies to all property that is under the ownership or control of the UMW and regulates the actions of UMW personnel who are responsible for installing, recording, or monitoring security camera equipment or systems.  This includes security camera technologies installed during either the course of capital construction or as an independent project.

This scope does not apply to video recording devices that are used specifically for educational purposes by faculty, staff or students in accordance with an academic course, research or training program, such as video recording devices used for mass communication classes or secure testing activities specifically equipped for such a purpose. This policy is not intended to prohibit the use of video recording devices used to record campus life activities such as sporting events, campus club events, or other UMW-sponsored events.

Audio recordings are not authorized under this policy.

Policy

The use of SCS on UMW Property is intended as a deterrent of criminal activity, aid in the detection of misconduct, used as an investigatory tool for law enforcement, and enhance the overall safety for individuals and security of property for the campus community. 

Definitions

Security Camera is a camera that records images in or outside of a building or in a public place, in order to monitor and protect against crime or other security threats. 

Executive Safety and Security Committee is the group designated by the Vice Chancellor of Administration and Finance with responsibility for reviewing and approving operational aspects of the SCS as set forth in this Policy. 

Image refers to a depiction or likeness captured or recorded in a single frame (still, snapshot, photograph); a sequence of multiple, single frames shot over a period of time (stop action, time lapse); or multiple frames that form a moving picture (motion, film, video). 

Investigator refers to an individual or group of individuals chosen from within the Executive Safety and Security Committee that are trained and qualified to utilize the Security Camera System as a tool to investigate complaints of misconduct or illegal activities that occur within the UMW properties.  Examples of “Investigators” may include; the Director of Crisis and Emergency Management, Dean of Students, Director of Facilities, Senior Director of Auxiliary Services, and/or law enforcement officials.  Investigators must have the ability to view the SCS system in real-time as well as review recorded data on the system.  

Operator is an individual who has been approved by the Executive Safety and Security Committee with a primary purpose of performance health checks of the SCS on a regular basis.  Approved operators will have access to the SCS system for the purpose of installing, managing, storing and retaining data captured on the SCS.  In addition, an operator may be tasked by investigators to preserve images or video recordings for safe-keeping and/or evidentiary purposes.  

Organization Head refers to the Vice Chancellor for Administration and Finance. 

Preservation refers to the process of securely storing and maintaining SCS images to prevent their loss or destruction. 

Security Camera Systems (SCS) refer to the individual cameras, recorded images, and any system that is used to manage, maintain, store, or control access of individual cameras and/or recorded images.

Procedures

Use of Video Surveillance Equipment

1. In the interest of safety and security, the UMW may monitor areas under the ownership or control of the University through the use of security camera or video surveillance equipment in order to promote, maintain, and enhance the safety and security of its faculty, staff, students, visitors and property. This may include the installation of security cameras/devices or other video recording equipment upon any property owned or controlled by UMW, the monitoring of information obtained or collected from such devices (either in real time or recorded), and the recording of such information.
2. Video monitoring for security purposes will be consistent with all existing UMW policies and adhere to all applicable state or federal laws, regulations or judicial orders.
3. Security cameras will not be placed for the sole purpose to evaluate employee performance or monitor employment-related duties or functions.  However, if video surveillance reveals a criminal act, criminal offense, policy violation, or other misconduct, video data may be used as evidence in disciplinary purposes and/or other university proceedings.
4. UMW respects the privacy of UMW community members. Any video monitoring conducted upon UMW property pursuant to this policy shall occur in public areas. Public areas include, but are not limited to, parking lots, bus stops, sidewalks, bike paths, building entrances and lobbies, staircases and stairwells, hallways and corridors, common areas, and point of sale/monetary transaction areas or other areas with no expectation of privacy. 
5. Private areas such as the following shall not be subject to video surveillance: residence hall rooms, bathrooms, shower areas, locker and/or changing rooms, areas where a reasonable person might change clothes, classroom or private offices such as faculty/staff offices. Additionally, rooms for medical, physical, or mental health therapy or treatment are private.
6. Signs shall be conspicuously displayed in all areas under video surveillance. The minimum text for these signs must state, “NOTICE: Recorded Video Surveillance in Use”.

Approval Process

1. The Chancellor hereby delegates to the Vice Chancellor of Administration and Finance the administrative responsibility over the Security Camera System.
2. The Vice Chancellor for Administration and Finance hereby delegates operational management responsibilities over the Camera Security System to the Executive Safety and Security Committee (ESSC).  
3. The Executive Safety and Security Committee (ESSC) has been delegated operational management responsibilities over the Security Camera System which includes:
   1. Authorizing placement of all cameras, associated equipment and signage;
   2. Authorizing the purchase of any new camera systems and associated signage;
   3. Reviewing existing security camera systems and installations and associated signage;
   4. Ensuring that all security installations remain in compliance with this policy; 
   5. Creating and approving the procedures for use of security cameras; and
   6. Authorizing specific personnel (Investigators) to review security camera system(s) for the purpose to investigate misconduct or criminal conduct complaints.
      
4. Written requests for camera placement shall be addressed to the Vice Chancellor of Administration and Finance.  The request will be forwarded to the Executive Safety and Security Committee for consideration and approval.  The request should include the following details: (See Attachment A).
5. In addition, for requests to install security cameras or associated equipment in faculty workstations (labs) or classroom spaces on campus, the request must be approved by the Vice Chancellor of Administration and Finance and the Provost and Vice Chancellor for Academic Affairs.
6. Exceptions to the review and written approval requirements may be made in the event of an emergency or other situation reasonably appearing to pose an imminent threat to the safety and security of the UMW community.  In such circumstances, law enforcement may be involved and the Vice Chancellor for Administration and Finance shall be immediately notified and has final decision-making powers.  
7. Any unauthorized, unethical or illegal use or installation of any security or surveillance camera without authorization by the ESSC is in violation of this policy and may subject an employee or student to disciplinary action and/or criminal proceedings.  

Executive Safety and Security Committee (ESSC)

1. The Executive Safety and Security Committee (ESSC) will assist the Vice Chancellor for Administration and Finance in balancing the concerns related to the use of security camera technologies to improve security on campus, with the community members’ interests in privacy, along with right to assemble and free speech.
2. The ESSC shall be comprised of the following:
   1. Director of Crisis and Emergency Management 
   2. Director of Facilities
   3. Dean of Students
   4. Director of University Communications
   5. Senior Director of Auxiliary Services
   6. Athletic Director
   7. Director of the Montana Youth Challenge Program
3. The ESSC shall meet annually to review security camera installations for appropriateness, verify consistent application of surveillance controls, and review objection decisions.
4. If the ESSC finds that a security camera installation (or some part thereof) is not in compliance with this policy, the ESSC Committee shall advise the Vice Chancellor of Administration and Finance of the need to correct the compliance issue.

Notification to Employees and Bargaining Units

1. Human Resources (HR) will notify the affected members of the campus community and applicable collective bargaining units, in writing, of the University’s intent to install a SCS at a particular location and/or area upon University property no less than thirty (30) days prior to its operation, unless such intent is in response to criminal activity on campus or by state or federal directive.
2. If required by state law, contract or judicial order, the University will negotiate the installation, use and monitoring of the SCS that directly affects members of a particular bargaining unit recognized by a labor agreement. If lawfully required, the University shall post notices in designated locations to alert the campus community that the particular location may be monitored by SCS.
3. Conspicuous public signage must be displayed at all SCS locations, except at emergency or investigative locations. SCS installations may or may not be monitored continuously. Therefore, units with active installations shall post signage stating, “NOTICE: Recorded Video Surveillance in Use”.
4. Individuals who want to object to the placement of SCS equipment or believe the presence of SCS equipment is in violation of this policy may file an objection with the ESSC.  
5. The ESSC shall rule on the objection within twenty (20) working days.  If the petitioner is not satisfied with the ESSC ruling, the petitioner can file an appeal with the Vice Chancellor of Administration and Finance within five (5) working days of receiving the ESSC ruling. 
6. The Vice Chancellor of Administration and Finance shall rule on the appeal within five (5) working days. The decision of the Vice Chancellor for Administration and Finance on appeals is final.

Monitoring and Recording Evidence

Any data collected through the use of video surveillance equipment is considered UMW property and/or records. The Vice Chancellor of Administration and Finance has designated the ESSC to be responsible for determining the specific personnel to be assigned as operators and investigators who will have access to SCS equipment and images for all university investigative purposes or to detect criminal activity.  

The SCS is not required nor intended to be actively monitored in real time and is not intended to serve as a way to request or attract security staff assistance.  Persons in need of assistance should dial 911 to report emergency situations or 406-683-3701, the Dillon Police Department for non-emergency situations.  However, those members identified as “Investigators” have the ability to actively monitor SCS images in real time or recorded data as a security prevention practice.

To report misconduct, criminal activity, or suspicious circumstances, follow the steps below;

1. A person must submit or be directed to submit a Campus Safety or Student Conduct Incident Report Form.  Campus Safety or Student Conduct Incident Report Forms can be found on the UMW webpage under “Campus Reporting Forms”.   
2. Upon receipt, the UMW Dean of Students, or designee will review the Campus Safety or Student Conduct Incident Report Form, and if deemed appropriate, will assign an investigator to look into the matter to determine facts and circumstances of the incident.  When deemed appropriate, the Dean of Students will consult with the Title IX Coordinator and/or Clery Compliance Coordinator.  
3. The investigator assigned to the incident report will consider the option to review the SCS as an investigatory tool to identify supportive evidence that may help determine the facts and circumstances related to the complaint.  The investigator may communicate with the reporting party to gather clarifying details of the complaint.  
4. The investigator will report their findings to the UMW Dean of Students, or designee.  If any SCS evidence is found, the investigator is responsible for sharing SCS evidence with the UMW Dean of Students.  The investigator may require/request the expertise from an SCS Operator to properly flag, clip, store and/or preserve the image(s) for future use in criminal or campus misconduct proceedings.  
5. The UMW Dean of Students or designee, will work with legal counsel to determine whether the SCS images are to be shared with any other University officials and/or supervisors.  When appropriate, lawful, and consistent with University practices, images may also be shared with third parties.  
6. This policy does not apply to covert surveillance utilized by the Dillon Police Department or other authorized law enforcement agency for criminal surveillance as governed by Montana law.  
7. The University will take all reasonable and necessary security precautions to prevent unauthorized access to, use, or disclosure of data recorded by the SCS.
8. It is the responsibility of the ESSC to remove any system access given to an individual at the time of separation from the University.

Training

1. Operators and Investigators must receive a copy of this policy and procedure. Such standards prohibit the targeting of individuals based upon perceived individual characteristics or classifications such as race, gender, ethnicity, sexual orientation or disability.
2. Operators and Investigators will:
   1. Perform their duties in accordance with this policy; and
   2. Access images only to the extent permitted by this policy.
3. Operators and Investigators are prohibited from:
   1. Monitoring individuals based on inappropriate characteristics such as race, gender, ethnicity, sexual orientation, or disability;
   2. Viewing the interior of residential rooms through windows, doors or other means;
   3. Duplicating images or permitting access to others of SCS images except as specifically permitted by this policy; and
   4. Viewing, recording, accessing or otherwise using SCS equipment or images in any manner that is inconsistent with this policy and/or outside the scope of the usage approved by the designated campus authority.

Collection and Storage of Information

1. SCS equipment has the ability to record, collect and store information, which then may be preserved as an official record or kept temporarily.
2. Information not requested or utilized by the ESSC, UMW, shall only be stored temporarily, as determined by the capabilities of the specific SCS equipment purchased by the respective unit, and shall not be considered documents “maintained” by the University.
3. SCS images will be retained for a period of thirty (30) days. This retention period may be extended at the request of University legal counsel, the Chief of Police, or as required by law.
4. SCS images may be preserved and retained longer than thirty (30) days under specific circumstances. This retention may only occur:
   1. Upon receiving credible notification of a University or law enforcement investigation for alleged illegal activity;
   2. Upon receiving notice from our legal counsel that such storage is otherwise needed to comply with legal obligations to retain materials;
   3. Upon receiving authorization from the Chancellor or Vice Chancellor for Administration and Finance indicating that such retention reasonably appears necessary to protect University interests;
   4. Where there is a reasonable belief that the SCS images and data may be related to illegal activity that has occurred, is occurring, or is imminently about to occur; or
   5. Where the SCS images or equipment has historical significance.
5. SCS images stored for specific purposes must be destroyed in a secure manner as soon as they are no longer needed for the purpose for which they were retained.

Compliance with Laws

The Vice Chancellor for Administration and Finance, in consultation with legal counsel, will monitor new developments in security industry practices to ensure that the manner in which UMW utilizes SCS is consistent and compliant with the highest standards and protections, and any applicable laws.

Violations and Sanctions

Violations of any aspect of this policy may subject the violator to employment, civil or criminal action, as permitted by University policy, applicable collective bargaining agreement(s), and/or any applicable laws.

Disclosure of information obtained from video surveillance to non-University officials or personnel with no legitimate purpose will be subject to disciplinary action and will be handled in accordance with any applicable state or federal laws or regulations.