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Establishing Written Policies for the Use of Video Surveillance Systems

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Purpose

 

The installation of a video surveillance system at your facility can provide many benefits, but can also be the source of numerous problems that you might not have the thought of when you first installed the system. Many facility managers are blindsided when an employee requests to see a video from a parking lot camera to determine who may have backed into her car; or when a supervisor requests video to track the work habits of an employee. Requests for recorded video are also often made by neighboring businesses and members of the general public. How should the manager of the video system handle these requests?

 

Employees and tenants can also have unrealistic expectations of what the video surveillance system can do, often thinking that the single camera that views the parking lot will provide a close-up view of a person breaking into their car, even though it is located 300' away. If the recorded video doesn't provide enough detail, they request that the image be "enhanced and enlarged" so they can identify the "perp". (It works that way on the CSI and NCIS shows on television, right?)

 

To effectively manage these issues, every organization that uses a video surveillance system should establish written policies regarding its purpose and use. These policies should be known by everyone in the organization so that expectations are realistic and so that there are no surprises after an incident has occurred. These written policies provide guidelines to the manager of the video surveillance system telling exactly how each specific type of situation should be handled.

 

Your organization should develop a video surveillance system policy that is specifically tailored to meet your needs. At a minimum, your video surveillance policy should address the following topics:

  • Purpose of video surveillance system.
  • Where cameras are typically used.
  • Where cameras are generally never used.
  • Where video surveillance system is monitored.
  • How video is recorded and for what duration.
  • Who is responsible for the management of the video surveillance system.
  • Who has access to video recordings and for what purposes.
  • The use of covert cameras.
  • Procedures for requesting video recordings.
  • Archival storage of video recordings related to security incidents.

 

Because your video surveillance system policy may have legal implications, the policy should be reviewed by your in-house counsel or an outside attorney before it is finalized.

 

Example of Video Surveillance System Policy

 

The following is a example of a video surveillance policy for a medium-sized organization. This policy is intended to provoke thoughts that can be used in developing your own policies. It is not intended to be used as a template or to be used without modification.

 

 

 

 

Video Surveillance System Policies for the Acme Corporation

Version 1.00

1/10/12

 

Purpose

 

The Acme Corporation makes limited use of video surveillance systems on its corporate campus. Video surveillance systems are primarily used to record access at building entrances and at the garage elevator lobbies. Video surveillance cameras are also used to provide surveillance of the exterior of the building and surrounding streets.

 

Video surveillance cameras are generally not used to observe employee work areas, and are never used in areas where employees would have an expectation of privacy, such as restrooms or locker rooms.

 

The primary purpose of the video surveillance system is to allow the after-the-fact investigation of crimes committed against the company. The system may also be used to assist in the investigation of certain types of occupational health and safety violations.

 

The video surveillance system is not intended to be used as a method of tracking the work habits or productivity of individual employees.

 

Management of Video Surveillance Systems

 

The Acme Corporation Security Department is responsible for the management of all video surveillance systems used at the corporation. Other corporate departments shall not install video surveillance system without the knowledge and approval of the Security Department. In particular, the use of covert camera systems must first be approved by both the Acme Corporation Security Department and Legal Department.

 

Video Surveillance Monitoring

 

The video surveillance systems are capable of being monitored from the Security Desk located at the Omega Building lobby. Security officers generally view video surveillance cameras on a periodic basis or in response to a specific incident. Because of the many responsibilities of the officer at the Security Desk, the video surveillance system is not monitored on a continuous basis.

 

Video Surveillance Recording

 

All video surveillance cameras are capable of being recorded continuously by a digital video recording system. Recorded video is used exclusively for the investigation of security and safety incidents and not for other purposes.

 

The Acme Corporation Security Department is responsible for the management of the video surveillance system and has exclusive control of the release of video recordings produced by this system.

 

Recorded video is not made directly available to Acme Corporation employees, building tenants, or the general public. In the event that a security incident occurs, employees should report the incident to the Security Manager. If the event occurred in an area where video surveillance coverage is available, the Security Manager will review the recorded video and make a determination if any video relevant to the incident is available. This video will be used by the Security Manager to investigate and resolve the reported security incident.

 

Requests to provide video recordings directly to non-employees (such as tenants, neighbors, or members of the general public) will not be accommodated. If a crime has been committed, non-employees should be encouraged to report it to the police. If it is believed that recorded video from the Acme Corporation would assist in the investigation of this crime, the police should be told to contact the Acme Corporation Security Manager. If relevant video is available, a permanent video clip of the incident will be produced and made available to the police. All requests for video recordings by law enforcement agencies shall be coordinated through the Acme Corporation Legal Department.

 

Recorded video is generally stored for a period of thirty days. Any video associated with a specific security incident or event is generally converted into a permanent video clip and stored for the duration of the investigation. Video clips which could become evidence in civil or criminal proceedings are kept indefinitely unless other direction is given by the Legal Department.

 

Limitations of Video Surveillance Systems

 

Employees should be aware that a security officer is not watching most cameras most of the time and employees should not have an expectation that they are under continuous surveillance when they are in the range of a camera. For example, employees walking to their car late at night should call Security and request an escort rather than assume that they are already being watched by a security officer using a camera.

 

Employees should also be aware that the video surveillance system has cameras that cover only a small fraction of the total campus, and even when camera coverage exists, it may not provide the level of detail necessary to spot suspicious activity or identify criminals.

 

 

 

If you have questions about video surveillance policies, or need help in writing a policy for your organization, please contact us.

 

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