Physical Security Systems: Data Governance and Disclosure

Purpose:

The University deploys physical security systems with the goal of mitigating risk by streamlining the process of detecting, assessing, and responding to breaches of physical security measures.

The presence and use of physical security systems implies the generation of data which should be considered private information. The University recognizes that all community and non-community members have a reasonable expectation of privacy.

Related Policy:

Scope:

This policy and procedure will regulate the expansion and use of these systems, as well as the storage, access, and use of the information and images generated by these systems, in order to support safety and security of persons and property, while upholding privacy as good stewards on behalf of the community.

Policy:

This policy governs the use of Physical Security systems and data. Equipment – including surveillance cameras, access control devices, interior and exterior detection sensors, alarm systems, and security response forces – shall be used to ensure the safety of property and persons by monitoring property, assessing alarms, securing spaces, preventing crimes, and informing emergency response.

Personal Web cameras ("Web Cams") connected to personal computers are not subject to this policy.

Definitions:

Physical Security Data - The aggregate of images and information generated and/or stored by the operation of physical security systems. This data includes, but is not limited to individual badge scan records, door operator records, and live or recorded surveillance imagery.

Physical Security Data may be nonpublic or private “security information” as defined by Minn. Stat. § 13.37 Subd. 1 (a) or private personnel or educational data pursuant to Minn. Stat. §§13.43, Subd. 4 and 13.32, Subd. 3, and FERPA, 20 USC 1232g, which may be accessed, used and disclosed to third parties only as consistent with those laws.

Physical Security Systems - Video surveillance and electronic access control systems.

Video Surveillance Systems - A video installation with the capacity to view or record university owned or controlled spaces, when used for the purposes set forth in this policy.

Electronic Access Control Systems - Electronic access control systems used to control entry to spaces, especially those that interface with a card reader for authorized personnel to access.

Surveillance Operator - A person viewing or controlling physical security systems. In their normal roles, Security Officers and Campus Safety Monitors will be the most frequent Surveillance Operators.

General Principles

Physical Security systems must be used in a professional, ethical, and legal manner. Their use must avoid unnecessary intrusions upon academic freedom and individual civil liberties such as privacy, freedom of expression, and freedom of assembly. Certain areas of campus will not be supplied with video surveillance equipment in order to protect these freedoms, especially classrooms and areas where there is a reasonable expectation of privacy in accordance with accepted social norms, such as restrooms, locker rooms, or dormitory rooms.

Only authorized personnel, as determined by the Director of Safety and Security or their designee, will be permitted to access physical security systems and data governed by this policy.

Appropriate and Prohibited Use

Neither Physical Security Systems nor Data may be accessed, used, or disclosed except as outlined in this policy. Disclosure and use of Data shall be on a need-to-know basis.

Physical Security Systems and Data shall be used in a manner consistent with all university policies, including those that cover nondiscrimination, sexual harassment, Student Privacy, and recording on campus.

Installation of Physical Security Systems

Expansions to physical security systems will be considered in light of assessed risks and the system’s ability to address specific vulnerabilities. Requests will be considered as an element of broader holistic physical security practices, and in accordance with the University’s Physical Security Technology standards and plan.

Video Surveillance Systems shall not be installed on Bethel’s property outside the bounds of this policy. Records of surveillance hardware shall be maintained by the Office of Safety and Security.

An exception shall be made for Non-University Tenants at the Anderson Center. Historically, some tenants have installed Physical Security Hardware that is not part of the University system. If incoming tenants desire such a service, it is recommended that hardware compatible with University systems be utilized for flexibility outside the lease terms.

Physical Security Monitoring and Operations

Physical Security Systems shall be operated by a limited number of authorized surveillance operators employed by the Office of Safety and Security. Employees found in violation of this policy or associated procedure will be subject to disciplinary action consistent with University policy.

Surveillance Operators will:

Be trained on technical and ethical use of physical security data
Perform their duties in accordance with this policy
Access surveillance images only to the extent permitted by this policy.
Be provided with appropriate work facilities so that the surveillance images are not viewed by unauthorized persons
Monitor based on behavior, NOT group characteristics (e.g., race, gender, sexual orientation, national origin, disability, etc.)
Escalate their observations to security officers immediately whenever any criminal or life-threatening activity is observed.
Document suspicious, criminal, or life-threatening activities in detail.

Surveillance Operators are prohibited from using the equipment addressed in this policy for viewing, recording, accessing or otherwise using a video surveillance system or surveillance images in any manner that is inconsistent with this policy and/or outside the scope of the usage approved by the designated campus authority:

Monitoring individuals based on characteristics other than observed behaviors.
Monitoring intimate behavior
Viewing spaces considered to have a reasonable expectation of privacy, such as the interior of residential rooms through windows, doors, or other means
Duplicating images or permitting access to surveillance images except as specifically permitted by this policy.

Review and Retention of Surveillance Images.

The Video Surveillance system shall be designed and maintained to store thirty (30) days of surveillance images. Review of these images should be performed only to investigate an incident, alarm, or suspicious activity. The cause for the footage review must be documented in a dispatch call. Findings relevant to suspicious activity or other incidents which are not refuted by the video review shall be submitted in a case report along with the details of the Security Officer’s response. Surveillance images deemed relevant and necessary to document an incident on campus shall be archived in a manner prescribed by the procedure for footage review, export, and archival. Archived footage must be stored in a secure location and configured to prevent unauthorized access, modification, duplication, or destruction.

Archived images will normally be kept for no longer than sixty (60) days unless a specific extension is requested or deemed necessary by the Assistant Director or Director of Safety and Security.
Long term archival of footage on storage drives must follow a naming convention which includes the case report number for the related incident.
Physical drives shall be stored in the safe, inside Safety and Security Office HC103.
Considerations should be made for duplicating storage and/or replacing physical drives on at least a 5 year rotating basis. Footage will not be kept for longer than four years.

Review and Retention of Electronic Access Control records

Electronic access control systems maintain a database of system events, including door and badge events, which are available back to the system’s latest generation update in 2019. The database is not configured to delete old badge events, though it has not maintained a full list of badge records over that period. Authorized personnel may request badge or space activity reports from the Assistant Director of Safety and Security or another System Admin, and these do not require specific backup or storage procedures.

Release of Archived Physical Security Data

Physical Security Data will only be released when authorized by the Director of Safety and Security or designee. Release of Physical Security Data may only be in support of official investigations, and is strictly limited to:

Bethel Security Officers, Campus Safety Monitors, Assistant Director and Director of Safety and Security
Assistant Deans or Deans of Student and Residence Life
University Title IX coordinator
Chief Human Resource Officer and AVP of People and Culture.
University General Counsel
Anderson Center Tenant groups
External Law Enforcement Agencies

All requests from sources external to the University for the release of information and results obtained through surveillance monitoring or recording must be escalated to the Director of Safety and Security and/or Vice President of Student Experience prior to release:

Requests from Insurance Companies

Requests from Insurance companies on behalf of their insured for the purpose of documenting motor vehicle incidents on campus will be handled in accordance with the Procedure for a Motor Vehicle Accident.

Requests from Anderson Center Tenants

Requests for physical security data from Tenants at the Anderson Center will be handled in a manner which maintains the integrity and confidentiality of the data, and in accordance with standard operating procedures for the incident being investigated.

Anderson Center tenants generally have autonomy over the areas they lease, and efforts will be made to cooperate in matters of physical security response, in order to maintain a secure environment at the Anderson Center.

Requests from Law Enforcement Agencies

Requests for information from a Law Enforcement Agent or Agency must comply with University Response to Requests by Law Enforcement.

Procedures

Responsible	Tasks
Surveillance Operator(s)	Monitors signals from exterior and interior sensors. When signals are detected, operators will assess alarms to identify the source of the alarm. When assessment does or cannot refute the alarm, operators shall initiate a personell response.
Security Officer(s)	Respond to investigate, interdict, and mitigate breaches. Identify potential threat actors and evaluate the situation based on observed actions, behaviors, and statements. Escalate as necessary and submit written documentation and evidence of incidents. When resources are insufficient for mitigation, violence is anticipated, or a legal threshold has been breached, escalate to University or non-university staff as appropriate, following the appropriate emergency response protocols.
Security Officer	Security officers shall write and submit a report documenting the incident response.
Assistant Director/Director	Ensure reporting obligations are met and timely warnings are issued to the community as required by Clery. Work with Marketing and Communications to issue timely warnings via Bethel Alert, and document the warning timeline. Make determination whether additional investigation is needed, report needs to be escalated to care & conduct, insurance, external law enforcement, etc. Enact recovery operations as necessary. Make system design changes and/or recommendations to alter future response in light of inefficiencies, deficiencies, and malfunctions.

Responsible

Task

Assistant Director/Director or Designees

In cases where a breach is determined to have occurred at some point in the past without assessment/response, an initial investigation should be completed into the situation prior to notification of law enforcement, such that evidence, including relevant documentation and incident reports, can be remanded at the time of the report.

Documentation is typically requested via a secure online portal, accessible via email.

When data is submitted as evidence, the Ramsey County case number should be added to the incident report, and/or the disclosure documented in a follow-up report as appropriate.

Responsible	Tasks

Responsible

Tasks

Security Employee

If receiving a request for Physical Security Data from an internal or external source, ask questions to get as much information about the incident as possible:

Has the incident been reported already/previously?
What happened?
Who was involved?
What information is needed?
Who needs the information?
How will the information be used?

This information can be escalated to the Assistant Director or Director.

Issues requiring immediate review can be escalated immediately. Issues not requiring immediate review or affecting life safety can be submitted by email.

Assistant Director/Director of Safety & Security

Review requests for accuracy and needs.

Disclose information as necessary based on policy criteria and documented in a case report or follow-up report as appropriate.