Policy 3510 – Use of Security Cameras and Electronic Equipment

The Board authorizes the District’s lawful placement and use of video surveillance and other electronic monitoring equipment on District property and/or in connection with District programs, operations, and services. Any such placement and use shall not conflict with any express restriction or prohibition included within this policy.

This policy is not intended to grant or create any expectation of privacy as to any time or location where a person would not already have an enforceable expectation of privacy to be free from such surveillance or monitoring.  Subject to this and other District policies and rules, information that the District obtains through the use of the District’s surveillance/electronic monitoring equipment may be used by the District for lawful purposes.

Regular Surveillance Activities

Regarding the electronic monitoring equipment that the District uses for surveillance purposes on an ongoing and reasonably regular basis:

  • The equipment may be placed and used in locations where individuals do not have a legally enforceable expectation of privacy from the applicable surveillance and monitoring. For example:
    • Video surveillance and monitoring may be used in areas such as
      • common areas and other shared spaces within District buildings, such as hallways, entryways, libraries, gymnasiums, cafeterias, and, unless exceptional considerations apply, rooms that are regularly used as classrooms;
      • District parking lots; and
      • outdoor District facilities.
    • Subject to the separate section of this policy that specifically addresses limited authorization for certain audiovisual recording of the interior of vehicles used for student transportation services, vehicles that are owned, leased, borrowed, or contracted by the District may be equipped with electronic monitoring equipment that is lawfully used by the District and other law enforcement agencies as a safety, security, or accountability measure.
  • No camera, video recorder, or similar device that is capable of recording, capturing, or transmitting images or video shall be placed or operated as electronic monitoring equipment under this policy in any restroom, locker room, or other designated changing area where it would be reasonably expected that individuals may be in a state or full or partial undress such that a person’s intimate body parts or a person’s normally-covered undergarments may be exposed to view. Use of audio surveillance functions/capabilities of such electronic monitoring equipment shall be authorized by the Board or Superintendent.
    • The Board expressly authorizes the lawful use of equipment that transmits and that may also record audio (1) as part of the verification procedures for controlling building access and obtaining visitor identification (e.g., for a visitor arriving at a building entry to contact and communicate with District staff); or (2) to temporarily provide actively-monitored supervision of a room/area in a District building in a manner that is consistent with building-based instructional procedures and that is announced or otherwise reasonably identified to the individuals being supervised
  • The Superintendent or their designee shall periodically review the placement and use of District-controlled electronic monitoring equipment that is currently in use and shall approve the placement and planned use of any newly-added equipment. No employee or agent of the District may unilaterally place/install electronic monitoring equipment on or in any District property without appropriate administrative authorization and oversight.
  • If state or federal law requires posting or other form of notice as a condition to the operation of the applicable equipment in a particular setting, then the Superintendent or their designee shall be responsible for ensuring that such notice requirements have been addressed. Even when not required by law, the Superintendent or their designee may authorize, direct, or approve postings or other steps intended to inform people that their conduct may be monitored and/or recorded.

The District does not intend to have employees who are normally and regularly assigned to directly observe and immediately assess and respond, on a real-time basis, to activity that is captured using electronic monitoring equipment. However, the District has staff with the knowledge and  ability to access equipment in real time during emergencies when equipment in nearby areas is available.

Audiovisual Recordings of the Interior of Vehicles Used for Student Transportation

  • School Buses. The Board expressly authorizes the lawful use of electronic monitoring equipment that creates audiovisual recordings of the interior of any school buses owned, leased/rented, borrowed, or contracted by the District to transport students to and from school or to or from any school-sponsored activities. Depending on the equipment available and any situation-specific legal restrictions, such authorized recording may include video, audio, or both. All recordings are subject to the notice, use, and confidentiality restrictions identified in section 347.446 of the state statutes and to all other applicable laws.
  • Non-School Bus Vehicles Used as an Alternative Method of Student Transportation. Electronic monitoring equipment used inside non-school bus vehicles operated by or under the direction of the District, including through contracted services, as an alternative method of student transportation under section 121.555, Wis. Stats., is subject to all applicable requirements of this Policy. Audio recording capabilities used for general surveillance must remain disabled unless expressly authorized by the Board or Superintendent. If the Board or administration approves or directs video and/or audio recording for general surveillance in these vehicles, the notice provided to students and parents under section 347.446, Wis. Stats., regarding audiovisual recording on school buses must also include these vehicles.
  • Service by Chartered Motor Bus, Common Carrier, or Taxi. To the extent the District arranges to provide student transportation for a co-curricular or extracurricular activity using a chartered motor bus that is not a school bus, any use of audiovisual recording equipment that is located on or in the motor bus shall occur pursuant to the policies and procedures and at the discretion and control of the charter carrier unless a District contract with the charter carrier provides otherwise. This paragraph shall also be applied to any student transportation that the District may arrange by common carrier or by a licensed taxi service.

Access to Records and Records Management

The Superintendent or their designee shall establish protocols for the proper retention of audiovisual media and other data that is captured by or from District-controlled electronic monitoring equipment for possible future access and review. The protocols shall be consistent with the District’s records retention obligations, including any formally-adopted retention schedules that the District has adopted. Retention protocols shall account for audiovisual media and other data that has been accessed or reviewed for a specific purpose (e.g., to evaluate an incident) or that becomes subject to a litigation hold, specific records request, subpoena, or similar situation. Until such media or other data is deleted or purged at an appropriate time, the District shall maintain at least one copy that remains unaltered and unedited.

The Superintendent, administrative-level designees, and building principals shall be the primary individuals who have authority to access and view audiovisual media and other data captured by the District’s surveillance/electronic monitoring equipment. These primary authorized individuals may approve other staff members or persons who are performing an institutional function on behalf of the District to access/view such media, with any restrictions/limitations that are appropriate to the specific circumstance. Acting in consultation with a designated legal custodian of District records, the primary individuals may also provide access to a recording or other surveillance data to law enforcement officials provided that the District official granting such access determines that the disclosure is either (1) required by law; or (2) legally permissible and in the District’s best interests. No official, employee, or agent of the District may access or view such media or other data, or grant access to another person, unless they have (1) appropriate authorization or approval, and (2) a legitimate purpose for doing so.

Prohibited Conduct

Any student who takes action to disable, disrupt, block, move, or alter any electronic monitoring equipment (including altering its viewing angle or changing its field of view) is subject to possible disciplinary action, up to and including possible expulsion.

A District employee shall be subject to possible disciplinary action, up to and including termination, if he/she (1) without express administrative authorization, takes action to disable, disrupt, block, move, or alter any electronic monitoring equipment, or (2) uses electronic monitoring equipment, recordings, or transmissions without authorization or in a manner that is inconsistent with applicable law, this Policy, or any other Board policy or regulation.

Policy Applicability

This Policy addresses Board authorization and various parameters related to electronic monitoring equipment that is placed and used by officials, employees, or other authorized agents of the District primarily for purposes of safety, security, and/or accountability. This Policy does not address or cover the use of devices that capture, record, or transmit audiovisual content or other data primarily for other purposes, such as instances in which authorized employees or other agents of the District record or livestream/transmit (1) a specific District event (e.g., a fine arts performance, athletic contest, graduation ceremony, Board meeting, or other public meeting) or (2) a specific classroom activity or school activity (e.g., for an authorized educational purpose).

Legal References:

  • Wisconsin Statutes
  • Wisconsin Administrative Code
    • Chapter Trans 300 [regulations governing transportation of school children, including equipment standards]
  • Federal Laws and Regulations

Cross Reference:

AFFIRMED:  August 25, 2026