I. Purpose 

With this policy, the University of Colorado Boulder (“CU Boulder”) adopts and implements uniform procedures and standards for the installation, maintenance, and use of security cameras on all property owned or controlled by CU Boulder. This policy also governs security camera data access, control, and retention. This policy and any accompanying procedures created by the University Safety Working Group will support the use of security cameras at CU Boulder to deter crime, assist law enforcement, and protect people and property, while respecting the privacy and rights of employees, students, and campus guests. 

II. Policy 

  1. This policy governs security cameras on all property owned or controlled by CU Boulder.  A “security camera” is any device capable of capturing video recordings, with or without audio, used by any CU Boulder-affiliated individual or unit to promote campus safety and security by monitoring areas such as exterior common areas; CU Boulder-owned or operated property and buildings; rooms and labs containing high-value equipment or information; cash-handling areas where money is exchanged, such as cashier locations; and common areas and areas accessible to the public. This policy does not apply to cameras not used for security, such as those used for: the recording of live lectures or performances; instructional purposes; clinical patient care; human subjects research; video conferencing; use by individuals or organizations with whom CU Boulder has a valid, contractual landlord/tenant relationship relating to CU Boulder property; capturing images and data of vehicle license plates for parking or law enforcement purposes; and private use by persons not acting pursuant to their employment or agency relationship with CU Boulder, or under CU Boulder’s direction and control. 

  2. CU Boulder shall regulate the installation and appropriate uses of security cameras by all CU Boulder-affiliated individuals and units. The Associate Vice Chancellor for Public Safety (“Associate Vice Chancellor”) shall authorize and approve all security camera placements and installations, including all new security camera installations and all existing security cameras. The Associate Vice Chancellor has the authority to prohibit security camera installations or remove existing security cameras that do not comply with this policy. The Associate Vice Chancellor may designate another employee to perform the Associate Vice Chancellor’s duties under this policy or the accompanying procedures. 

  3. The Associate Vice Chancellor shall appoint the University Safety Working Group to review requests for Security Camera installations, requests for approval of existing Security Cameras, and lists of Authorized Users, and to make recommendations to the Associate Vice Chancellor or the Associate Vice Chancellor’s designee about those issues. The Associate Vice Chancellor, or other person designated by the Associate Vice Chancellor to serve in the Associate Vice Chancellor’s place, will serve as Chair of the University Safety Working Group. The University Safety Working Group shall have the discretion and authority to determine the Working Groups’s operating procedures and rules, as approved by the Associate Vice Chancellor.  

  4. The University Safety Working Group shall review all new installations and upgrades of security cameras at CU Boulder to assure that they meet certain requirements for hardware, placement, installation, use, data viewing and storage, secure access, and centralized monitoring. These measures help avoid incompatibility of systems, reduce exposure to liability arising from the use of such systems, and assure appropriate respect for personal privacy. 

  5. Security camera use shall be limited to public areas. CU Boulder security cameras must not capture footage of any private areas, including residence hall rooms or windows. Security camera administrators must apply electronic shielding over those windows. Security cameras shall not be directed at the windows of any privately-owned residence not located on CU Boulder property. 

  6. CU Boulder security cameras must not capture audio recording. Audio file data must not be stored or retained. 

  7. Security camera data must be stored on secure servers with appropriate security safeguards based on the sensitivity, criticality, and level of identified risk of the stored data. Except as outlined in Section 8 of this policy, only authorized users may view security camera data. Security camera data must be retained for at least thirty (30) days, and data may be retained longer, as required by law.  

  8. Copies of security camera data may be released as approved by the University Safety Working Group. Copies of security camera data will not be released to any other party except pursuant to valid legal process or in response to valid requests made pursuant to the Colorado Open Records Act (CORA), Colo. Rev. Stat. § 24-702-201, et. seq., or other applicable statute. The University Safety Working Group and relevant security camera administrator will work with the CORA Compliance Administrator and other CU Boulder personnel as necessary to respond to valid requests for security camera data. University Counsel may provide advice regarding any requests for security camera data. All requests for security camera data related to events or incidents involving potential criminal activity should first be made to University of Colorado Boulder Police Department. 

  9. All CU Boulder security camera administrators must receive training on technical, legal, and ethical use of security cameras and data retention and release. All security camera administrators must receive and acknowledge a copy of this policy and any accompanying procedures created by the University Safety Working Group. 

  10. CU Boulder security camera administrators must retain records of access to and release of security camera data in a manner sufficient to demonstrate compliance with this policy and any accompanying procedures created by the University Safety Working Group. 

  11. Monitoring individuals via security cameras based on characteristics of race, color, national origin, sex, pregnancy, age, disability, creed, religion, sexual orientation, gender identity, gender expression, veteran status, political affiliation, or political philosophy is prohibited.  

  12. Any violation of the Security Camera Policy or any accompanying procedures created by the University Safety Working Group may be considered misconduct resulting in removal of the security camera, denial of access to security camera data, and if applicable, corrective or disciplinary action, up to and including termination. 

III. Definitions

  1. Authorized User means any CU Boulder–affiliated individual authorized by a Security Camera Administrator to have ongoing viewing access to Security Camera Data. 
  2. Data means any digital video data captured by Security Cameras that can be monitored, transmitted, stored, retrieved, or modified. 
  3. Security Camera means any device capable of capturing video recordings, with or without audio, that a Security Camera Administrator uses to promote campus safety and security by monitoring: 
    1. Exterior common areas; 
    2. CU Boulder-owned or operated property and buildings; 
    3. Rooms and labs containing high-value equipment or information;
    4. Cash-handling areas where money is exchanged, such as cashier locations; and 
    5. Common areas and areas accessible to the public. 

  4. Security Camera Administrator means any CU Boulder employee responsible for installation, management, operation, maintenance, and use of the infrastructure associated with Security Cameras for a specific CU Boulder college, department, program, office, research center, business service center, or other operating unit of CU Boulder. Security Camera Administrators are also responsible for data maintenance and access. Security Camera Administrators shall be designated by the Associate Vice Chancellor. Current Security Camera Administrators include: 

    1. Facilities Management Security Camera Administrator – responsible for all CU Boulder Security Cameras not under the purview of another Security Camera Administrator; 

    2. CU Boulder Police Department (“CUPD”) Security Camera Administrator – responsible for all CUPD Security Cameras; 

    3. Student Affairs Camera Administrator – responsible for all Student Affairs Security Cameras; 

    4. University Memorial Center Security Camera Administrator – responsible for all University Memorial Center Security Cameras (except those maintained by the CU Bookstore Security Camera Administrator); and 

    5. CU Bookstore Security Camera Administrator – responsible for all CU Bookstore Security Cameras. 

  5. University Safety Working Group​ means the committee appointed by the Associate Vice Chancellor for Office of Public Safety to review requests for Security Camera installations, requests for approval of existing Security Cameras, and lists of Authorized Users; and to make recommendations to the Associate Vice Chancellor or the Associate Vice Chancellor’s designee about those issues.  

  6. Private Areas means areas in which an individual has a reasonable expectation of privacy, including but not limited to residential living areas, bathrooms, shower areas, locker and changing rooms, and rooms used for ombudsman, medical, physical, or mental health treatment. 

IV. Procedures 

https://www.colorado.edu/policies/security-camera-procedures

Effective Date

February 17, 2023

Approved By

Philip P. DiStefano, Chancellor

Policy Owner

Associate Vice Chancellor for Public Safety