Student Disability Services Testing Center Camera Monitoring and Recording Policy

Policy Number: #703

Responsible Executive(s):

• Director

Responsible Office(s):

• Student Disability Services

A. Purpose

1. This policy establishes clear, fair, privacy-conscious, and accessible guidelines for the use of camera monitoring and recording within the Regis University Student Disability Services Testing Center.
2. This policy also affirms that camera monitoring and recording in the Testing Center must not interfere with approved disability accommodations, must not be used to evaluate or question a student's disability, and must not be used for discriminatory, retaliatory, or unrelated surveillance purposes.

B. Scope

1. This policy applies to camera monitoring and recording used in spaces designated for accommodated testing, make-up testing, exam proctoring, or other approved Testing Center activities administered by Student Disability Services.
2. This policy is intended to operate alongside the Regis University Security Surveillance Camera and Acceptable Institutional Use Policy. It does not replace or supersede that policy.

C. The Policy

1. Authorized Use of Testing Center Cameras
   1. The Student Disability Services Testing Center may use camera monitoring and recording to support academic integrity, exam security, testing administration, and documentation of testing irregularities or suspected violations of testing procedures.
   2. Testing Center cameras may be used only for legitimate Testing Center, exam administration, and academic integrity purposes.
   3. Authorized purposes include, but are not limited to:
      1. Maintaining a fair and secure testing environment.
      2. Supporting academic integrity.
      3. Documenting potential testing irregularities.
      4. Verifying compliance with Testing Center procedures and faculty-provided exam instructions.
      5. Reviewing reported concerns involving unauthorized materials, unauthorized technology use, communication during testing, disruption, impersonation, exam handling concerns, or other suspected testing misconduct.
      6. Protecting the integrity of exams, students, staff, faculty, and university testing processes.
      7. vii. Supporting authorized university review processes when there is a legitimate educational, operational, compliance, legal, safety, or conduct-related reason to review an incident.
   4. Camera monitoring and recording shall not be used for general surveillance, curiosity, retaliation, intimidation, harassment, or any purpose unrelated to Testing Center operations.
2. Access to Live Monitoring and Recordings
   1. Access to live camera monitoring or recordings shall be limited to authorized personnel with a legitimate educational, operational, compliance, legal, safety, or conduct-related need.
   2. Authorized personnel may include:
      1. Student Disability Services leadership.
      2. Approved Testing Center staff or proctors.
      3. Authorized university officials involved in academic integrity, student conduct, legal compliance, records review, or institutional operations.
      4. Campus Safety, when required for safety, criminal-related incidents, system operation, investigation, or university policy compliance.
      5. Information Technology Services, when required for system security, technical support, storage, access control, or cybersecurity compliance.
      6. Legal Affairs or other authorized university officials, when required for legal review, subpoena, litigation hold, investigation, grievance, complaint, audit, or other official university purpose.
   3. Faculty may be informed of relevant findings related to an exam integrity concern but should not receive direct access to recordings unless approved through the appropriate university process.
   4. Approval to review information from a recording does not automatically authorize direct viewing, copying, downloading, distribution, or possession of the recording.
   5. Recordings shall not be copied, downloaded, saved, shared, emailed, photographed, posted, or distributed except as authorized by university policy, legal requirement, or approved institutional process.
3. Review of Recordings
   1. Recordings may be reviewed only when there is a legitimate reason to do so.
   2. Legitimate reasons may include:
      1. A reported testing irregularity.
      2. A suspected academic integrity violation.
      3. A safety concern.
      4. A technology issue affecting exam administration.
      5. A student complaint or grievance.
      6. A proctor report.
      7. A faculty or academic department concern.
      8. A request from an authorized university office.
      9. A legal, compliance, audit, conduct, or records-related need.
   3. Routine random review of recordings should be avoided unless approved as part of a documented Testing Center quality assurance, security, compliance, or operational process.
   4. When a recording is reviewed, the review should be documented.
   5. Documentation should include:
      1. Date and time of review.
      2. Name and role of reviewer.
      3. Reason for review.
      4. Exam, course, or testing session involved.
      5. General outcome or finding.
      6. Any referral made to faculty, Student Disability Services leadership, Community Standards and Care, Campus Safety, Legal Affairs, or another authorized university office.
   6. Review documentation should be maintained according to applicable records retention requirements.
4. Academic Integrity Concerns
   1. If Testing Center staff observe or later identify a potential academic integrity concern, staff should document the concern objectively and avoid assumptions about intent.
   2. Documentation may include:
      1. Date, time, and location of the testing session.
      2. Student name.
      3. Course, instructor, or exam information.
      4. Observed behavior or incident.
      5. Testing Center rule, faculty instruction, or exam condition involved.
      6. Whether the behavior may relate to an approved accommodation.
      7. Whether a recording was reviewed.
      8. Action taken by Testing Center staff.
      9. Any referral made to faculty, Student Disability Services leadership, Community Standards and Care, Campus Safety, Legal Affairs, or another authorized university office.
   3. Student Disability Services may share relevant information with faculty, academic departments, Community Standards and Care, Campus Safety, Legal Affairs, or other appropriate university offices when there is a legitimate educational, operational, compliance, legal, safety, or conduct-related reason to do so.
   4. Student Disability Services does not determine academic misconduct unless such authority is granted by university policy. Otherwise, the role of Student Disability Services is to document and report relevant facts through the appropriate university process.
   5. When a behavior may be related to a disability accommodation, Student Disability Services should review the accommodation context before referring the matter as a potential academic integrity violation, unless immediate safety, exam security, or urgent operational concerns require prompt action.
5. Privacy, FERPA, and Student Records
   1. Testing Center recordings may contain personally identifiable student information.
   2. When a recording is directly related to a student and maintained by the University for an official purpose, it may be treated as a student education record under applicable law and university policy.
   3. Access to recordings and related documentation must be limited to university officials with a legitimate educational interest or others authorized by law, consent, subpoena, court order, or applicable university policy.
   4. If a recording includes multiple students, Student Disability Services and the appropriate university office shall evaluate access, redaction, review, disclosure, or release obligations consistent with applicable law and university procedures.
   5. Student Disability Services shall handle recordings and related documentation in a manner that protects student privacy, disability-related information, and the integrity of university records.
6. Security, Storage, and System Controls
   1. Testing Center recordings shall be stored and managed in accordance with applicable university Information Technology Services cybersecurity standards, records management requirements, and access control procedures.
   2. Access to systems containing Testing Center recordings should be role-based and limited to authorized personnel.
   3. Student Disability Services shall make reasonable efforts to ensure that recordings are protected from unauthorized access, disclosure, alteration, deletion, or misuse.
   4. Any suspected unauthorized access, disclosure, loss, tampering, or misuse of recordings shall be reported to the appropriate university office, which may include Student Disability Services leadership, Information Technology Services, Campus Safety, Legal Affairs, Human Resources, or Community Standards and Care.
7. Retention and Deletion
   1. Testing Center recordings shall be retained only as long as necessary for academic integrity, testing administration, legal compliance, university operations, records management, or other legitimate university purposes.
   2. Unless a longer retention period is required by university policy, legal hold, investigation, student conduct process, academic integrity process, grievance, complaint, subpoena, audit, Clery Act-related matter, criminal investigation, or other legitimate university purpose, recordings should be automatically deleted or overwritten according to the approved university retention schedule.
   3. When a recording is preserved because it relates to a reported incident, academic integrity matter, grievance, complaint, investigation, legal issue, or criminal-related incident, it shall be retained according to applicable university records retention requirements and any instructions from Legal Affairs, Community Standards and Care, Campus Safety, or another authorized university office.
   4. For criminal-related incidents, Campus Safety shall be consulted as appropriate.
   5. If the recording becomes part of an incident report, investigation, disciplinary proceeding, Clery Act-related record, or other official university record, the recording shall be retained according to applicable federal law, university policy, and records retention requirements.
   6. Recordings shall not be retained indefinitely unless required by legal hold, active investigation, pending proceeding, university records requirement, or other authorized institutional purpose.
8. Student Questions
   1. Students may ask questions or raise concerns about Testing Center camera monitoring and recording by contacting Student Disability Services at disability@regis.edu.
   2. Student Disability Services shall review concerns in a timely and individualized manner.
   3. When appropriate, Student Disability Services may consult with Campus Safety, Information Technology Services, Legal Affairs, Community Standards and Care, Academic Affairs, faculty, or other authorized university officials.
9. Training
   1. Testing Center staff, proctors, student workers, and other authorized personnel who have access to live monitoring, recordings, or testing-related video documentation shall receive training appropriate to their role.
   2. Training should include:
      1. This policy.
      2. The Regis University Security Surveillance Camera and Acceptable Institutional Use Policy.
      3. Student privacy and FERPA-related considerations.
      4. Disability accommodation protections.
      5. Academic integrity documentation.
      6. Appropriate and prohibited uses of recordings.
      7. Secure handling of recordings and testing records.
      8. How to respond to student questions or concerns.
      9. When to consult Student Disability Services leadership, Campus Safety, Information Technology Services, Legal Affairs, Community Standards and Care, or other authorized university offices.
   3. Staff must understand that camera monitoring is used to support academic integrity and testing operations, not to question disability status, penalize disability-related behavior, or create unnecessary barriers for students receiving accommodations.
10. Violations
    1. Violations of this policy may include, but are not limited to:
       1. Unauthorized access to live monitoring or recordings.
       2. Unauthorized review of recordings.
       3. Unauthorized copying, downloading, saving, sharing, emailing, photographing, posting, or distributing recordings.
       4. Tampering with, altering, disabling, disconnecting, or attempting to bypass camera systems.
       5. Using recordings for discriminatory, retaliatory, personal, or unrelated purposes.
       6. Using recordings to question, verify, or challenge a student's disability outside the appropriate Student Disability Services process.
       7. Failing to protect recordings or related documentation from unauthorized access or disclosure.
       8. Retaining or deleting recordings contrary to university policy, legal hold, investigation requirements, or records retention requirements.
    2. Violations may be referred to the appropriate university office, including Student Disability Services leadership, Human Resources, Community Standards and Care, Campus Safety, Information Technology Services, Legal Affairs, or another authorized university office.
    3. Employees, students, contractors, vendors, or other individuals who violate this policy may be subject to corrective action, disciplinary action, loss of access privileges, referral to an appropriate university process, or other action permitted by university policy.

D. Definitions

1. Academic Integrity: The ethical standards and university expectations that require students to complete academic work honestly, fairly, and in accordance with course, exam, Testing Center, and university requirements as defined and enforced under the Academic Integrity Policy, available at www.regis.edu/policies/academic-integrity.
2. Authorized Personnel: University employees or approved representatives who have a legitimate educational, operational, compliance, legal, safety, conduct, or technical need to access live monitoring, recordings, or related documentation.
3. Camera Monitoring: The viewing of camera images in real time by authorized university personnel.
4. Camera Recording: Video footage captured and stored by a camera system.
5. Campus Safety Surveillance Infrastructure: Security surveillance cameras, recording systems, video management servers, and related infrastructure owned, operated, maintained, or managed by Campus Safety.
6. Criminal-Related Incident: An incident that may involve criminal activity, law enforcement involvement, Campus Safety review, subpoena, criminal investigation, or a matter requiring consultation with Campus Safety or Legal Affairs.
7. Legitimate Educational Interest: A need to access student information or related records in order to perform an assigned university responsibility, support academic integrity, administer testing, conduct an authorized review, comply with legal obligations, or carry out another official university function.
8. Testing Center: A space administered by Student Disability Services for accommodated testing, make-up testing, exam proctoring, or other approved testing activities.
9. Testing Irregularity: Any observed or reported concern involving exam administration, exam security, student conduct during testing, unauthorized materials, unauthorized technology, communication, disruption, accommodation-related concerns, or deviation from Testing Center or faculty-provided exam instructions.

E. Related Policies, Procedures, Forms and Other Resources

1. Security Surveillance Camera and Acceptable Institutional Use Policy
2. Academic Integrity Policy
3. Ranger Guide: Official Student Handbook
4. Student Disability Services testing procedures
5. Student Disability Services accommodation procedures
6. Record Retention Policy
7. Responsible Use of University Technology Resources Policy
8. Privacy Policy
9. FERPA
10. Electronic and Information Technology Accessibility Policy
11. Clery Act Policy Statements
12. Faculty exam submission and Testing Center instruction forms
13. Policy on Policies

F. End Notes

This policy is intended to support academic integrity, accessible testing, student privacy, and appropriate use of camera monitoring and recording within the Student Disability Services Testing Center.

This policy shall be interpreted consistently with applicable federal and state law, Regis University policy, approved disability accommodations, records retention requirements, and the university's policy approval process.

Nothing in this policy limits the authority of Regis University to take appropriate action in response to academic integrity concerns, student conduct matters, safety concerns, criminal-related incidents, legal obligations, or other official university matters.

Questions about this policy may be directed to Student Disability Services at disability@regis.edu.