ECAF-R, Use of Video and Audio Monitoring

Placement and Notification

Video surveillance equipment may be installed in and around schools, district buildings and school transportation vehicles where there is a legitimate need for video surveillance to assist district administration in monitoring inappropriate behavior and maintaining safe and secure schools, as approved by the superintendent or designee
Equipment will not be used or installed in locations of district buildings where visitors, students and/or staff have a reasonable expectation of privacy, including locker rooms and restrooms.
Video recording equipment may be in operation 24 hours per day on a year- round basis at any and all times, whether or not school is in session and whether or not the facilities or buildings are in use.
Video surveillance equipment shall not be located in an administrative office or in the school's or district's central security office.
Video monitors displaying active surveillance shall not be located in an area that enables public viewing.
Conduct and conversations of any kind occurring in publicly accessible locations on district property or in district buildings and school transportation vehicles (e.g. school hallways, buses, athletic facilities, etc.) may be recorded by video and audio recording devices.
The district shall specifically notify students, staff and the public that video surveillance and/or audio recording systems are present. Such notification will be included in staff and student handbooks or posted on signs that are prominently displayed in appropriate locations around schools, district buildings and transportation vehicles.
Specific notification will not be provided when a recording device has been added or is being utilized in a school building or school transportation vehicle.

Use

The use of video surveillance equipment on district or school property shall be supervised and controlled by the Chief Operations Officer or designee. The use of video surveillance equipment on school vehicles shall be supervised and controlled by the Chief Operations Officer or designee. The use of video surveillance equipment at sites other than schools or school vehicles will be supervised and controlled by the Chief Operations Officer or designee.
Staff and students are prohibited from unauthorized use, tampering with, or otherwise interfering with video recordings and/or video camera equipment. Violations will be subject to appropriate disciplinary action. Disciplinary action shall be consistent with applicable Board policies and regulations and may include, but not be limited to, written reprimand, suspension, demotion or dismissal for staff and suspension and/or expulsion for students, depending upon the nature and severity of the situation.
The Chief Operations Officer or designee will review the use and operations of the video surveillance system with each school on a periodic basis.
Video recordings may be used as evidence that a student, staff member or other person has engaged in behavior that violates state law, Board policies and/or school rules.

Storage/Security

Recordings will remain the property of the District and may be reproduced only in accordance with applicable law and Board policy.
The District shall provide reasonable safeguards including, but not limited to, password protection, well-managed firewalls and controlled physical access to protect the video surveillance system from hackers, unauthorized users and unauthorized use.
Video recordings will be maintained in their original format for 30 days after the date of the initial recording. If the designated district administrator and/or designee know no reason for continued storage, such recordings will be erased.
Video recordings held for review will be maintained in their original form pending resolution of the incident. When a video recording is used for investigative or disciplinary action involving a student or staff member the District shall make and maintain a copy of the recording for administrative purposes. Recording media will then be released for erasure, copied for authorized law enforcement agencies or retained in accordance with applicable law and Board policy.
Video recordings may become part of a student's educational record or a staff member's personnel record in accordance with applicable law and collective bargaining agreements. To the extent video recordings create student records or personnel records, the District will afford all privacy protections required by law for such records, including all applicable state and federal laws related to record maintenance, retention, disclosure, access, and destruction of records, including the Family Educational Rights and Privacy Act (FERPA) and applicable state laws and Board policy.

The Executive Director of Student Support Services shall serve as the District's official custodian of video recordings that are deemed student education records and this official shall be responsible for determining whether and how these records will he maintained.

Similarly, the Chief Human Resources Officer will act as the District's official custodian of personnel records and this official shall be responsible for determining whether and how these records will be maintained.
To ensure confidentiality, all video storage devices that are not in use will be stored securely in a locked receptacle located in a controlled access area. All storage devices that have been used will be numbered and dated. Access to the storage devices will be limited to authorized district personnel.
No recordings of video can be taken with a cell phone or any other personal electronic device.

Viewing Requests

Requests for review of video recordings that are considered a student education record or personnel record will be as follows:

All viewing requests must be submitted in writing. Requests for viewing will be limited to those parents/guardians, students, staff and/or district officials with a direct interest in the recording as authorized by the designated district administrator. Only the portion of the recording concerning the specific incident at issue will be made available for viewing.
1. When a video recording is an education record of multiple students, an individual parent of a student or an eligible student is entitled to review the video upon request.
  
  When possible, the District is required to reasonably redact or segregate out the portions of the video recording directly related to other students without destroying the meaning of the record. When such redaction or segregation of the video recording cannot reasonably be accomplished, or if doing so would destroy the meaning of the record, then the parents of each student and each eligible student to whom the video recording directly relates are entitled to review the video upon request.
Written requests for viewing may be made to the designated district administrator within 5 school days of the date of recording. Video images obtained by the District will be viewed by authorized District personnel only. Upon knowledge of an event, authorized staff will direct access to and preserve all data in a "hold" status. Password protected access to information will be limited to specific school staff, District Safety and Security staff, and top administrators.
Approval or denial for viewing will be made within 5 school days of receipt of the request and so communicated to the requesting individual.
Recordings will be made available for viewing within 3 school days of the approval of the request.
In taking into account the totality of the circumstances, if the District determines that there is an articulable and significant threat to the health or safety of a student or other individuals, then live or recorded video maintained as education records may be viewed by appropriate parties, including but not limited to dispatch officers, law enforcement units, fire department, public health officials, and trained medical personnel, in connection with an emergency if knowledge of the information is necessary to protect the health or safety of the student or other individuals.
Video recordings maintained as education records of a student may be disclosed to teachers and school officials, including law enforcement unit officials who are designated as "school officials," who have legitimate educational interests in the behavior of a student.
The district may employ a "law enforcement unit," which, for purposes of this regulation, shall mean an individual, office, department, division or other school component of the district that is officially authorized or designated by the district to enforce federal, state or local laws or to maintain physical security and safety of the district. Records created by a law enforcement unit are not education records and may be disclosed to anyone, such as outside law enforcement authorities or school officials responsible for discipline, without parental consent. Law enforcement unit records will be maintained separately from education records.
Actual viewing will be permitted only at district sites including a school building or district administrative office, unless otherwise required by law or authorized by the Chief Operations Officer or designee.
All viewing will take place with a designated district administrator or designee present.
To the extent required by law, a written or electronic log will be maintained of those viewing video recordings including the date and location of viewing, reasons for viewing, date the recording was made and the viewer's signature.
The electronic viewing log will be monitored by the safety and security department.
When a recording is requested by law enforcement or district administrator a chain of custody form will be completed at the time of request. The chain of custody form will have a designated case number associated with the incident.

Training and Orientation

District regulations related to video surveillance, and associated District policies, will be incorporated into staff training and orientation programs.

Revision History

December 6, 2017
Revised: February 5, 2020
Revised: June 21, 2023

4865-2116-3830, V. 2

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