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Video Surveillance Policy

Video Surveillance Policy


The University of Dayton is committed to enhancing the safety of the campus community by integrating best practices for campus safety and security with enhanced technology. A critical component of a comprehensive security program is the use of video surveillance. This policy establishes the standards for the installation, regulation and use of video surveillance systems in a way that enhances security and plays a critical role in the University’s compliance and risk management programs, while respecting the privacy rights of the University community. 


This policy is applicable to all students, faculty, staff, vendors, and visitors, regarding the use of video surveillance systems for purposes of safety and security on any University-owned, leased, or controlled property, as well as surrounding public areas.  

This policy does not apply to: 

1.  Video surveillance systems or cameras used strictly for academic purposes or the use of webcams that are dedicated to computers or systems intended for use only by an individual interacting with the connected device and  has no significant secondary security function. Such exceptions include systems used to deliver education, conduct research, conduct video conferencing, record public performances, record practices or rehearsals, record news or press coverage, produce promotional materials, and/or record construction progress. Any camera use outside of the above mentioned exceptions need to be approved by the Office of the Provost. 

2.  Installation or use of systems or devices – such as Ring, Blink or similar security devices installed on the exterior of a residential house in the Student Neighborhood (without causing damage to the property per the housing agreement).

3.  Automated teller machines (ATMs) that may use cameras and are the property and responsibility of the specific vendor. 

4.  Body cameras worn as part of a police officer's uniform.

5.  Criminal investigations conducted by or in conjunction with University of Dayton Police Department (UDPD).

Policy History

Effective Date:  March 22, 2023

Approval:  March 22, 2023

Policy History:

  • Approved in original form: March 22, 2023

Maintenance of Policy:  Associate Vice President Audit, Risk & Compliance/Chief Risk Officer, Division of Audit, Risk and Compliance


For purposes of this policy: 

“Video Surveillance System”- Refers to any system that monitors and/or records at a specific location or activity through processes, technology device, and equipment used in conjunction with network, for purposes of gathering, monitoring, recording or storing an image or images of University facilities and/or people in those facilities.  Such devices may include but are not limited to microphones, analog and digital surveillance cameras, images, audio, video, snapshots, configuration settings, logs, software, and hardware. 

“Monitoring” - Watching live or viewing historical recordings from a video surveillance system. 

“Public and Semi-Public Areas” - Those areas in which there is not a reasonable expectation of privacy.  Areas that may have restricted access do not create an expectation of privacy (e.g., University-owned, leased or controlled property with electronic card access).  

“Private Areas” - Areas on campus in which there is a reasonable expectation of privacy. Such private areas are prohibited from being subject to video surveillance under this policy. These areas include, but are not limited to, private living quarters, restrooms, changing rooms, single occupancy offices, etc. 

“Reasonable Expectation of Privacy” - An expectation of privacy generally recognized by society and or the University community and in certain circumstances protected by law.


This policy defines the appropriate standards for video surveillance, including but not limited to system locations, installation, handling, viewing, dissemination, and destruction of surveillance recordings. Video surveillance will be conducted in a professional and respectful manner, consistent with applicable laws and regulations and/or all existing University policies.  Any deviation from this policy and/or use of surveillance records for purposes not delineated in this policy is prohibited unless approved in writing by Audit, Risk and Compliance in consultation with the Office of Legal Affairs. Video surveillance will not be exploited for purposes of profit or commercial publication, nor will such recordings be publicly distributed except as may be required by law. 

A.  Approval and Installation

I.  Audit, Risk and Compliance maintains the responsibility for video surveillance on campus.  All University offices and University personnel must seek and receive written permission from Audit, Risk and Compliance prior to the installation of a new video surveillance system, or the re-activation or upgrade of an existing system, on University-owned, leased or controlled property. In determining whether to permit installation of a new video surveillance system, Audit, Risk and Compliance may consult with the Department of Public Safety, UDit, Office of Legal Affairs, and/or other appropriate University units.

II.  All surveillance installations covered by this policy will use the enterprise video surveillance system chosen and supported by the University unless prior approval for a different system is received by Audit, Risk and Compliance in consultation with UDit, or the system is an off-site location not supported by the University’s enterprise system. Unauthorized and/or personalized video surveillance equipment is prohibited. Video surveillance systems and equipment covered by this policy must be maintained by UDit.

III.  Schools, divisions or offices may request a security assessment to determine video surveillance placement. Strategic placement of video surveillance systems will be determined and authorized by Audit, Risk and Compliance in consultation with UDit and the Assistant Vice President of Public Safety and/or that individual’s designee. Video surveillance systems included in capital projects must be coordinated with UDit.  Installation of video surveillance equipment that is deemed to be solely for department use shall be the financial responsibility of the requesting unit.   

IV.  Periodically, based on incident analysis or other relevant data, Audit, Risk and Compliance, in consultation with UDit and the Assistant Vice President of Public Safety will evaluate existing locations of campus video surveillance systems. Based on this assessment, video surveillance may be repositioned or added and those deemed no longer necessary will be removed.

V.  Prior to installation of a new video surveillance system or repositioning of an existing system, Audit, Risk and Compliance will coordinate with the Office for Research Security to determine appropriate placement in University of Dayton Research Institute (UDRI) facilities and other campus locations where controlled research is being conducted.

B.  Use of Video Surveillance

I.  Information obtained from video surveillance is considered University property and will be used for safety and security purposes and/or for law enforcement purposes.

II.  Video surveillance will not record or monitor sound.  Audio recordings shall be prohibited unless permitted by law and authorized by Audit, Risk and Compliance in consultation with other appropriate offices on campus. Surreptitious recordings without a lawful purpose of any kind are prohibited and can only be authorized in writing by Audit, Risk and Compliance.

III.  Use of video surveillance shall be limited to public or semi-public areas.  Video surveillance shall not be used in private areas, including but not limited to:

     1.  Residential rooms, suites or apartments.

     2.  Directed at a window of a residential house that would allow surveillance of the interior of the designated location.

     3.  Restrooms and showering/bathing facilities.

     4.  Locker rooms and other changing facilities.

     5.  Offices of individuals (except where requested by the occupant). 

IV.  Any variance to the private areas must be authorized by Audit, Risk and Compliance. If cameras are unavoidable in private areas, electronic shielding or other means must be used to protect the privacy of the occupants. 

V.  No video surveillance system shall be tampered with, disconnected, or altered as to affect the proper operation of the camera system. Any known maintenance, renovation or system failure should be reported to Audit, Risk and Compliance.

VI.  Monitoring individuals based on characteristics of race, gender, ethnicity, sexual orientation, disability, or other protected classification (as set forth in the University’s Nondiscrimination and Anti-Harassment Policy) is strictly prohibited. 

VII. Monitoring individuals using such technologies as facial recognition or other artificial intelligence must be authorized by Audit, Risk and Compliance and the Office of Legal Affairs, and in accordance with the Biometric Information Policy.  

C.  Disseminations and Destruction

I.  Offices charged with investigatory authority on campus, including but not limited to Internal Audit, the Office of Legal Affairs, and the Department of Public Safety, may access all live and historical video surveillance systems. Any access outside of these offices to monitor or view recordings on video surveillance shall be limited to authorized personnel as determined by Audit, Risk and Compliance and the Office of Legal Affairs.   Any person who has been granted access will not allow their access to be used by another person and will use their access only for the purpose of their job duties. 

II.  Recordings shall follow the Record Retention Policy and if the data is not included in the retention schedule, be retained for a minimum of 30 days. After that time, the files can be overwritten, unless otherwise requested by Internal Audit, the Assistant Vice President of Public Safety or Office of Legal Affairs. Recordings and other files related to ongoing investigations or threatened or pending legal proceedings are exempt.

III. Recordings and other records created from video surveillance systems shall be recorded to the University’s centralized server(s) and configured to prevent unauthorized access, modification, duplication, or destruction. The copying or retransmission of live or recorded video from a video surveillance system shall be limited to persons authorized by Audit, Risk and Compliance. 

IV.  Personnel are prohibited from using or disseminating information acquired from such systems, except for purposes related to their job responsibilities. All information and observations made in the use of security cameras are considered confidential and can only be used for official University and/or law enforcement purposes. No attempt should be made to alter any part of the video recording. 

V.  Video recordings that have been maintained will be made available to University officials conducting bona fide investigations by the office(s) identified in Section C. I.  Agencies outside the University may need to obtain a subpoena and/or court order for video recordings, as determined by the Office of Legal Affairs. The University will request that, if an outside agency receives copies of any video recordings but determines such recordings are of no value to them and/or not subject to the investigation, the agency should return such video(s) to Audit, Risk and Compliance for destruction authorization.  Copies of recordings determined to have value should be retained by the investigating department, subject to their retention policy.  A chain of custody will be used when a video recording is provided to an internal department or an agency outside of Audit, Risk and Compliance. 

VI.  Signs may be used to make the community aware of the use of video surveillance systems. Any signage posted shall include a statement indicating that the area is subject to video surveillance.

VII. All personnel involved with installation, maintenance or monitoring of video surveillance systems will be instructed in the technical, legal and ethical parameters of appropriate camera use.  Personnel will receive a copy of this policy and provide written acknowledgement that they have read and understood its contents. 

Reference Documents

  1. University of Dayton Nondiscrimination & Anti-Harrassment Policy
  2. Univeristy of Dayton Record Retention Policy
  3. Univeristy of Dayton Biometric Information Policy

Appendix A

Operating Standards for Video Surveillance

(Outline of manual still to be developed)

For questions relating to the University policies of Audit, Risk and Compliance please contact:

Robin Oldfield, Assistant Vice President- Office of Audit, Risk and Compliance