1.0 Policy Purpose
The purpose of this policy is to establish the principles for governing the placement and use of Security Cameras by Brown University on its campus, including College Hill and the Jewelry District, and the retention of data recorded by those Security Cameras. This policy advances Brown’s priorities for ensuring campus security and the protection of University persons and property while respecting the privacy of the Brown community in a manner consistent with the University’s core institutional values.
2.0 To Whom the Policy Applies
This policy applies to all academic and administrative units and all faculty, staff, students, and contractors of Brown University, as well as any visitors to or users of Brown-owned, -leased or -controlled Premises. It covers all University owned and operated Security Camera Systems used for and on Brown-owned, -leased and -controlled interior and exterior Premises, including but not limited to College Hill and the Jewelry District. This policy does not apply to cameras used for non-security purposes, such as, but not limited to, academic instruction and research and video conferencing, except with regard to access and disclosure as specified in Section 3.4.
3.0 Policy Statement
The University uses a risk-based, integrated approach to physical security. All Security Camera installations and data retention practices align with and support Brown’s broader security strategy and policies. All Security Cameras are operated in a manner that is consistent with University core institutional values and policy and in compliance with all applicable policy and legal requirements.
3.1 Governance and Oversight
The Safety and Security Steering Committee (SSSC) serves as the senior governance body for this policy. The SSSC provides strategic direction, institutional alignment, and executive oversight for all physical security systems. The Safety and Security Working Group (SSWG) acts as the operational advisory body to the SSSC. The SSSC is informed in carrying out its charge by advice and input from the Campus Safety Advisory Committee, composed of staff, faculty, and students and other representative bodies.
3.2 Security Camera Installation Approval and Operating Principles
All Security Camera installations must be approved by the Vice President for Public Safety and Emergency Management (VP-PSEM) and Chief of Police. Administrative and academic departments, students, faculty and staff are prohibited from installing Security Cameras or similar infrastructure (e.g., Ring cameras or other wireless security devices) at their own initiative, and any such non-approved, non-standard equipment on any Brown-owned, -leased or -controlled Premises will be removed. Requests for new or additional Security Cameras must be processed through the integrated intake system managed by the Department of Public Safety and Emergency Management (DPSEM), the Office of Information Technology (OIT), and Facilities Management and Campus Operations.
Security Cameras will be limited to uses that do not violate the reasonable expectation of privacy as defined by law. Accordingly, Security Camera Systems will not be installed to directly monitor areas where there is a reasonable expectation of privacy. These areas include, but are not limited to:
- Restrooms;
- Lactation rooms;
- Locker rooms, changing rooms, and other areas where a person might reasonably expect to change their clothes in private;
- Residential hallways not in the immediate area of an entryway door;
- Private rooms, or residence hall lounges, where students’ living, studying, and social activities take place;
- Private offices; and
- Areas dedicated to medical, physical, or mental therapy or treatment.
Care will be taken to ensure that Security Cameras installed adjacent to such spaces have a restricted field of view such that no area(s) with a reasonable expectation of privacy are monitored.
The installation of Security Cameras is based upon the need to mitigate an identified risk or vulnerability. Such needs include, but are not limited to:
- Safeguarding human life;
- Protection of buildings owned, leased or controlled by the University;
- Protection of University property and assets;
- Monitoring access to University-controlled buildings;
- Verification of security alarms;
- Monitoring storage, pick up, and drop off of hazardous materials;
- Rapid response to emergency events or incidents;
- Law enforcement and/or criminal investigations;
- Protection of high security spaces;
- Responding to a lawful subpoena or other lawful request from a government agency (or other compliance needs); and
- Management of safety risks at large events on campus, including, but not limited to, Spring Weekend, Reunions, Orientation, Convocation, Commencement, athletics events, and/or lectures or events with dignitary speakers and guests.
Security Camera field of view, operational parameters and configurations for Camera Security Systems are determined by DPSEM or its designee.
OIT is responsible for the operation and maintenance of the network applications and the physical system hardware that support Security Camera Systems at the direction of the VP-PSEM and oversight of the SSSC.
Security Camera Systems owned and operated by the University do not record audio and do not use facial recognition tools. However, it is possible that if a University Security Camera Recording is provided to a government agency in response to a search warrant, subpoena, or other lawful request, the government agency may use biometric and/or video analytics, or similar technologies, on the recording.
Camouflage or other deliberate concealment of cameras is not permitted unless specifically authorized by the VP-PSEM. The VP-PSEM may authorize the placement of temporary concealed Security Cameras for use in criminal investigations or in Exigent Circumstances involving credible threats to the safety of the campus, to the life, health or safety of any person, or of theft or destruction of property, where, in each case, making the camera visible would undermine the University’s response to the situation. Such Security Camera placements must be authorized in writing by the VP-PSEM or delegated authority for each discrete incident and reported to the Executive Vice President for Finance and Administration or their designee for approval prior to installation.
The existence of this policy does not imply or guarantee that Security Cameras will be monitored in real time, continuously or otherwise. Additionally, while the University makes reasonable efforts to ensure its Security Cameras are functional/operational, this policy is no guarantee of this, given the possibility of unforeseen circumstances that may disrupt functionality (e.g., weather events, tampering, technological or infrastructure malfunction, etc.).
3.3 Recording Retention
- Standard Retention: Security Camera Recordings are generally retained for 30 days.
- Automatic Overwriting: Systems are configured to automatically delete data exceeding the retention window on a rolling basis.
- Exceptions: The standard retention and automatic overwriting period will be suspended where recordings are required to be maintained due to a litigation hold issued by the Office of the General Counsel (OGC), authorized use by an agency or University office in an external or internal investigation, or where otherwise required by applicable law. The SSSC may authorize longer retention periods for specific high-risk areas.
Security Camera Recordings are classified as Level 3 data as defined by Brown University’s Data Risk Classifications. All Security Camera Recordings must be stored in a secure location and are strictly limited to role-based authenticated access by authorized and trained personnel. To prevent unauthorized access, modification, duplication, or destruction, all infrastructure supporting these systems must adhere to the University’s Minimum Security Standards for Desktop, Laptop, Mobile and Other Endpoint Devices. This mandate applies equally to centrally managed systems and to any Brown endpoint device used to access, view, or export footage. If any storage, processing, or hosting of Security Camera data is cloud-based or vendor-managed, the University requires that such vendors operate under a formalized contract that includes robust data-protection terms aligned with Level 3 data compliance requirements.
3.4 Access and Disclosure
Access to recorded footage is restricted to authorized DPSEM personnel and University officials approved for access by the VP-PSEM. Any other request for access by University officials or third parties must comply with the Electronic Information Access Policy and receive authorization from the VP-PSEM and Chief of Police or the OGC.
If approved by the VP-PSEM, Security Camera Recordings and/or recordings made by other University-owned and -operated cameras, such as, but not limited to, cameras used in academic instruction (lecture capture), research and/or videoconferencing, may generally be accessed and distributed to the following:
- University officials conducting University investigations;
- University officials responsible for managing emergency situations relating to the administration and operation of the University (e.g., matters involving the health and safety of campus members and the protection of University property);
- University officials responsible for the maintenance, management and operation of Security Cameras;
- Third parties pursuant to a court order or subpoena, or as otherwise required under applicable law; and
- The University’s insurance carriers when a recording is necessary for the carriers to determine liability.
4.0 Definitions
For the purpose of this policy, the terms below have the following definitions:
- Brown-owned, -leased or -controlled Premises:
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All Brown University buildings and facilities, including but not limited to all interior and exterior spaces owned, leased or controlled by the University for any purpose. Explicitly includes all exterior green spaces, courtyards, pathways, alleys and access areas in and around buildings and facilities.
- Exigent Circumstances:
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An immediate threat to life or safety requiring emergency access to safety systems.
- Security Camera:
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A camera owned and operated by Brown University for campus security purposes which is enabled to make only visual recordings (i.e., no audio recordings).
- Security Camera System:
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Any electronic service, software, or hardware directly supporting or deploying a Security Camera.
5.0 Responsibilities
All individuals to whom this policy applies are responsible for becoming familiar with and following this policy. University supervisors and employees with student oversight duties are responsible for promoting the understanding of this policy and for taking appropriate steps to help ensure and enforce compliance with it.
The following governance groups and University units have additional responsibilities, as defined here:
Safety and Security Steering Committee (SSSC): Responsible for establishing physical safety priorities, overseeing the tiered building framework, and ensuring stakeholder engagement in policy refinement. Serves as the senior governance body for this policy.
Safety and Security Working Group (SSWG): Acts as the operational advisory body to the SSSC.
Campus Safety Advisory Committee: Provides advice and input on campus safety and security matters, composed of staff, faculty and students, and other representative bodies.
VP-PSEM and Chief of Police: Responsible for the operational execution of this policy, approving camera placements, and managing the intake and delivery system.
DPSEM, OIT, and Facilities Management and Campus Operations: Responsible for operating as an integrated system to maintain equipment, manage storage, and ensure technical compliance with retention standards.
Department Heads and Supervisors: Responsible for ensuring that no unauthorized "private" surveillance systems are installed within their units.
6.0 Consequences for Violating this Policy
Failure to comply with this and related policies may result in disciplinary action, up to and including suspension without pay, or termination of employment or association with the University, in accordance with applicable disciplinary procedures (e.g., staff, faculty, student) or for non-employees may result in the suspension or revocation of the user’s relationship with Brown University.
7.0 Related Information
Brown University is a community in which individuals are encouraged to share concerns with University leadership. Additionally, Brown’s Anonymous Reporting Hotline allows anonymous and confidential reporting on matters of concern online or by phone (877-318-9184).
The following information complements and supplements this document. The information is intended to help explain this policy and is not an all-inclusive list of policies, procedures, laws and requirements.
7.1 Related Policies
7.2 Related Procedures
- Physical Safety Request Intake Process
7.3 Related Forms
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7.4 Frequently Asked Questions
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7.5 Other Related Information
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Policy Owner and Contact(s)
Policy Owner: Executive Vice President for Finance and Administration
Policy Approved by: President
Contact Information:
Policy History
Policy Issue Date:
Policy Effective Date:
Policy Update/Review Summary:
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