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The following language is excerpted and adapted from Marine Corps Community Services Order 1754.1A (2 Apr 13). Specific references to location have been changed. This is intended as a sample to help you think about policies on your installation. No endorsement is intended. Talk to your installation’s legal Counsel for information about policies you should follow.

Execution:

1. CCTV video surveillance systems can serve as a significant child abuse and neglect deterrent mechanism for staff. Video monitors provide families a certain comfort level as it allows them to observe their children adjusting to childcare without interrupting or distracting from the child’s daily routine and activities. Moreover, the digital storage of images (i.e., “video recordings”) can protect staff from false allegations of child abuse or neglect, and can be used by management to observe behaviors of both staff and children for future training and development purposes.
2. Reference (a) provides that families have primary responsibility for the health, safety, and well-being of their child(ren), and that families shall have access to their children while at the CDC and Youth Center. In the spirit of providing “unrestricted access” to children, families will be allowed to view their children interacting with other children and the staff by viewing their children through CCTV monitors. This is live real-time monitoring, not a video recorded account.
3. When CDC and Youth Center operations are memorialized in a video recording, the recordings become Government records, maintained by the Government, for the exclusive use of the Government. These video recordings are maintained for several reasons, including the training of CDC and Youth Center staff, monitoring the progress and development of children, deterring and preventing child abuse and neglect, and protecting the Government’s interests in the event of a potential legal claim. Consequently, family requests to view all or a portion of a CCTV video recording of activities at the CDC and Youth Center, including requests for copies thereof, fall within the purview of reference (b). Families desiring to view or obtain a copy of a recording must submit a written request pursuant to the provisions of reference (b), and should call the FOIA Coordinator at XXX-XXX-XXXX for information regarding how to properly submit a FOIA request. The rules and procedures governing release of official Government records set forth in reference (b) will determine whether any particular request to view a recording, or obtain a copy thereof, will be granted.
4. Unless required for internal management purposes, CDC and Youth Center CCTV video recordings shall be maintained for no longer than 30 days. This will provide the staff a reasonable period of time to review the tapes for any internal business. As an exception, should management become aware of a claim against the Government or foresee litigation as a result of events by the CCTV system, the responsive recording should not be destroyed until released for destruction by MCCS Counsel (XXX-XXX-XXXX).

Logistics:

1. Under no circumstances will anyone outside of [installation name] be permitted to view any portion of a CCTV video recording without first consulting Counsel.
2. Under no circumstances will CDC or Youth Center staff respond directly to a family requesting to either view, or obtain a copy of, a CCTV video recording except to direct the parent to the FOIA Coordinator.
3. Upon notification that a family member has submitted a FOIA request to either view, or obtain a copy of, a video recording, CDC and Youth Center staff shall preserve the video recording in question by “burning” a copy of the recording onto a disk and retaining the disk until a release determination has been made pursuant to the provisions of reference (b).