Chapter 45 – Video Surveillance

(Amended 8/20/12)

45.1 Scope of Policy

This policy applies to all University of Iowa students, faculty, staff, and visitors to campus in their use of video equipment for the purpose of surveillance on or in any University property, facilities, and spaces and/or during the course of University-sponsored activities. Employing units of the University may establish more specific expectations in addition to this policy or elaborate on this policy in greater detail. 

45.2 Exclusions

This policy does not apply to video used by or for:

  1. Non-surveillance purposes. Examples of non-surveillance video recordings include, but are not limited to, video recordings made for:
    1. instructional, academic, or artistic purposes,
    2. capturing public events and performances,
    3. recording promotional or news events,
    4. convenience such as weather or construction site viewing,
    5. video conferencing,
    6. University research purposes, or
    7. patient care or medical treatment.
  2. The University of Iowa Department of Public Safety (DPS). DPS is authorized to utilize video surveillance as necessary to fulfill their mission and responsibilities as a law enforcement agency.
  3. Cameras installed in University space leased to an external party. The external party will provide the location of all video surveillance equipment in University space to DPS.

This policy also does not apply to audio recordings as they are addressed by Iowa Code 727.8, including the audio portion of a video recording. 

45.3 Principles and Rationale

  1. The University of Iowa is committed to protecting the safety and property of our community by promoting a secure campus environment while avoiding unnecessary intrusions. This policy is intended to assure the appropriate use of video surveillance for reasons of safety, security, and stewardship of people and resources and provide transparency in the use of that technology/equipment.
  2. Video surveillance of individuals is prohibited if the use of such surveillance is based upon considerations that violate the University's Policy on Human Rights (see II-3).
  3. Video surveillance will be used in a professional and ethical manner in accordance with University policy and local, state, and federal laws and regulations, as well as any other relevant standards, such as those specific to health care organizations.
  4. The use of personal "webcam" technology that records video using portable electronic devices for surveillance purposes is prohibited.
  5. Virtual or "fake" surveillance cameras are prohibited. 

45.4 Procedures

  1. An administrative committee will be formed to monitor the application of this policy to new and existing uses of video surveillance; to create operational procedures related to the approval of requests, retention of and access to video surveillance footage, use of signage; and to provide for timely reviews of this policy.
  2. Process for approval. Prior to design, purchase, installation, and/or any use, all video surveillance equipment and systems must be approved in writing as consistent with this policy.
    1. For all University organizations other than University of Iowa Hospitals and Clinics:
      1. Requests for design, purchase, installation, and/or use must be made to one of the following University officials:
        1. The vice president, or a designee, for the requesting unit;
        2. Assistant Vice President and Director of Public Safety, or a designee; or
        3. Chief Human Resources Officer, or a designee.
      2. Upon receiving a request, the University official will consult with the other University officials listed above and the Information Security and Policy Officer or a designee, prior to approval. Upon approval, these same individuals shall be notified of the written response by the approving University official.
    2. For University of Iowa Hospitals and Clinics (and the operations of other health care units under the authority of the hospital):
      1. The Vice President for Medical Affairs or a designee will be responsible for all requests for the design, purchase, installation, or use of video surveillance equipment and systems within the hospital. This person will also be responsible to assure appropriate consultation with other hospital and/or University officials, such as the Associate Vice President for Human Resources for UI Health Care, regarding the application of this policy.
      2. UIHC's Department of Safety and Security is responsible for notifying the Department of Public Safety of the locations of surveillance cameras and for the retention of recordings.
  3. Confidentiality statements. All University faculty, staff, and students with access to video surveillance systems are required to sign a confidentiality statement approved by the Office of the General Counsel.
  4. External releases of footage.
    1. Public records requests. All public records requests, including requests for the release of video surveillance footage, should be submitted to the UI Transparency Officer, 101 Jessup Hall, according to normal University practice.
    2. Other external release. Prior written authorization from the Office of the General Counsel, or a designee, is required for any other release of video surveillance footage to any party external to the University.
  5. If video surveillance is installed where identification of individuals is possible, signage should be used when appropriate for the context. The following language is suggested: "This area is subject to video surveillance and may or may not be actively monitored." 

45.5 Responsibility/Authority for Control

  1. The University officials in V-45.4 above are responsible for and will maintain oversight for the appropriate use of video surveillance consistent with this policy.
  2. DPS shall be given access to video surveillance equipment and footage upon demand when necessary to fulfill their mission and responsibilities as a law enforcement agency.
  3. Distribution of video surveillance footage to University personnel other than those originally approved at the time the request was made or for a specific use other than the original purpose must be approved in writing following the process established in V-45.4 above, by the University official, or a designee, that approved the original request. Any such distribution will be for legitimate University purposes and subject to applicable regulations and/or University policy.
  4. The location of all existing video surveillance equipment must be provided to DPS by December 31, 2012, and may be subject to review by the administrative committee in V-45.4a above. 

45.6 Compliance

Violations of this policy may result in the following:

  1. Immediate removal of equipment and/or violators from University facilities;
  2. Resolution in accordance with applicable University policies and procedures, which may include disciplinary action up to and including expulsion or termination from the University; and/or
  3. Being reported to DPS for possible criminal investigation. 

45.7 Standards

All video surveillance equipment located outside of the UI Hospitals and Clinics (or the operations of other health care units under the authority of the hospital) must be brought into compliance with the following technical, financial, and installation standards no later than June 30, 2017:

  1. Information Technology Standards available from the ITS service description located at: https://its.uiowa.edu/video-surveillance
  2. Design and Construction Standards located at: www.facilities.uiowa.edu/pdc/designstandards/index.html
  3. Security and Access Control Standards available from Facilities Management, 200 University Services Building.