Having carefully weighed and balanced privacy rights against the School District’s obligation to ensure the safety and security of its students, staff, visitors and property, the Smithfield School Committee has authorized camera surveillance within the District under the following guidelines:
Placement of Video Cameras
Cameras will be in plain view and authorized for use in the following places where students, staff and visitors have no reasonable expectation of privacy: entrances, hallways, cafeterias, gymnasiums, libraries, building exteriors, parking lots, and outdoor areas on school grounds.
Cameras will not be installed in staff break rooms or in student or staff restrooms, locker rooms or changing areas. Cameras shall not be permitted in classrooms and other instructional areas, except gymnasiums and the high school library hallway. Actively monitoring cameras in such instructional areas shall be limited to time outside of the normal instructional period or when perceived emergency situations exist. Any video footage in these instructional areas shall not be used for evaluative purposes.
In consultation with other appropriate administrators, the Superintendent and/or the Superintendent’s designee will identify specific locations where video cameras and monitoring equipment shall be installed and operated. Only an authorized employee or agent may install, access and/or monitor the camera systems.
Under no circumstances will the camera systems make or monitor audio recordings.
Students and staff shall be informed that the District is using a video surveillance system to monitor and/or record the behavior and activity of all persons on school property or grounds. A notice regarding the use of the video surveillance system will be included in the student handbook and in the District’s facility use application, agreement, and form.
Each building or area in which video surveillance may occur shall have clearly worded signs posted at conspicuous locations informing persons that the buildings and grounds may be under video surveillance. The signs shall be in both English and Spanish.
Operation of Video Surveillance
Video surveillance may be used to monitor and/or record behavior and activity of all persons on school property or grounds for the purpose of ensuring a safe school environment. In no cases shall video surveillance be used to monitor or evaluate instructional practices or professional responsibilities of Smithfield employees.
Real-time and archival access to camera systems (on-site) shall be limited to the Superintendent, district administrators, building principals, office staff, and technology staff for legitimate administrative purposes, unless otherwise authorized by the Superintendent. Remote (off-site) access will be limited to the Superintendent, Director of Technology, and Superintendent’s designee as needed. Law enforcement may be allowed to view the District’s real- time video surveillance feeds or recordings in emergency situations, when an incident is reported or observed, when an alarm system is activated, or to investigate a potential crime reported by school administration. A Memorandum of Understanding between the school and police departments shall communicate conditions under which remote access by the police department to the District’s camera systems is allowed.
Real time viewing may also be available in school offices or designated locations in each building to facilitate monitoring of the building and grounds.
The Director of Technology will implement and control the camera systems. The Director of Technology shall periodically view random images from the video surveillance to verify that the equipment is operating properly and has not been blocked, moved or altered, and that the System is not capturing images from any areas as to which individuals would have a reasonable expectation of privacy. The Director of Technology shall implement a maintenance program for the camera system equipment.
Use of Video Recordings
The overall purpose of the camera systems is to promote the safety and security of students, staff, visitors and property.
The School Committee or administration may rely on the images recorded by the camera system in aid of enforcing School Committee policies, rules and regulations, and other applicable law, including but not limited to student and staff disciplinary matters, and matters referred to law enforcement. The camera system shall not be used to monitor staff professional practice or professional responsibilities. Evidence obtained through the system’s general use, following a report of a specific incident of conduct unbecoming of a Smithfield staff member, may be used in the investigation and discipline of a staff member. In such instances, the staff member should be informed that he/she is the subject of an investigation, the nature of that investigation, who specifically is conducting the investigation and the reason for the investigation. In no situations shall video footage be used to observe or monitor instructional practices or responsibilities for evaluative purposes.
Information shall not be retained or used for purposes other than those sanctioned by School Committee policy, rules and regulations and state and federal law.
Misuse, abuse, and/or attempts to compromise the camera system are subject to discipline, and will be addressed on a case-by-case basis by the administration.
Viewing of Recordings
In addition to the authorized users previously identified, archival video recordings may be viewed by:
parents and students, to the extent allowed by and consistent with state and federal rules and regulations, including the need for permissions from parents of other students shown in the recording;
staff with a direct involvement in the recorded content of the specific video recording, or if such video recording is part of an investigation of alleged misconduct by the specific staff member;
staff or agents responsible for the technical operation of the camera system (for technical purposes only);
law enforcement, where allowed under the Family Educational Rights and Privacy Act (FERPA) and under the Memorandum of Understanding; and
as otherwise required by law or court order.
Real-time or video recordings may be viewed by authorized users when an incident or concern related to the safety and security of students, staff, visitors and/or property is reported to the District, and/or to investigate an incident reported to the district concerning student and/or staff performance and conduct.
Protection of Information and Disclosure: Security and Retention of Video
The district will digitally store recordings for a period of not less than 14 days. Data beyond that period of time may still be available or may be overwritten by the system. All video recordings which constitute student and/or personnel records will be stored in accordance with applicable state and federal laws, regulations, School Committee policies and rules and regulations
The district’s video archive software will maintain a log of access to the system.
When appropriate, and consistent with applicable laws, School Committee policy, and rules and regulations, archived video recordings will be disposed of in a secure manner.
The Superintendent is authorized to establish administrative guidelines to further implement the camera systems.
The content of video recordings may become a part of a student’s educational record and may be produced as evidence in student administrative discipline conferences and hearings or other proceedings, subject to district policy and procedure concerning student records and disciplinary or other proceedings. The District shall comply with state and federal laws related to student record maintenance and retention, as provided in the Family Educational Rights and Privacy Act (FERPA) as applicable in particular cases. Only those people with a legitimate educational or administrative purpose may view and/or listen to the electronic video recordings. Where appropriate, the video recording may be shared with law enforcement officials. Students are prohibited from tampering with electronic recording devices. Students who violate this policy will be disciplined in accordance with the School Committee’s discipline policy and shall reimburse the District for the cost of any necessary repairs or replacement.
LEGAL REF.: Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g; 34 CFR § 99.3
ADOPTED: October 15, 2018