HomeMy WebLinkAboutPortable Audio Video Recorders 8-11-2023Policy
422
Otter Tail County Sheriff's Office
Otter Tail Cnty SO Policy Manual
Copyright Lexipol, LLC 2023/08/11, All Rights Reserved.
Published with permission by Otter Tail County Sheriff's Office Portable Audio/Video Recorders - 1
Portable Audio/Video Recorders
422.1 PURPOSE AND SCOPE
This policy provides guidelines for the use of portable audio/video recording devices by members
of this office while in the performance of their duties (Minn. Stat. § 626.8473). Portable audio/video
recording devices include all recording systems whether body-worn, hand-held, or integrated into
portable equipment.
This policy does not apply to mobile audio/video recordings, interviews, or interrogations
conducted at any Otter Tail County Sheriff's Office facility, undercover operations, wiretaps, or
eavesdropping (concealed listening devices).
422.1.1 DEFINITIONS
Definitions related to this policy include:
Portable recording system - A device worn by a member that is capable of both video and audio
recording of the member’s activities and interactions with others or collecting digital multimedia
evidence as part of an investigation and as provided in Minn. Stat. § 13.825.
422.2 POLICY
The Otter Tail County Sheriff's Office may provide members with access to portable recorders,
either audio or video or both, for use during the performance of their duties. The use of recorders is
intended to enhance the mission of the Office by accurately capturing contacts between members
of the Office and the public.
422.3 MEMBER PRIVACY EXPECTATION
All recordings made by members on any office-issued device at any time or while acting in an
official capacity of this office, regardless of ownership of the device, shall remain the property of
the Office. Members shall have no expectation of privacy or ownership interest in the content of
these recordings.
422.4 MEMBER RESPONSIBILITIES
Prior to going into service, uniformed members will be responsible for making sure that they are
equipped with a portable recorder issued by the Office, and that the recorder is in good working
order (Minn. Stat. § 13.825). If the recorder is not in working order or the member becomes aware
of a malfunction at any time, the member shall promptly report the failure to their supervisor and
obtain a functioning device as soon as reasonably practicable. Uniformed members should wear
the recorder in a conspicuous manner at or above the mid-line of the waist and notify persons that
they are being recorded, whenever reasonably practicable (Minn. Stat. § 626.8473).
Any member assigned to a non-uniformed position may carry an approved portable recorder at any
time the member believes that such a device may be useful. Unless conducting a lawful recording
in an authorized undercover capacity, non-uniformed members should wear the recorder in a
Otter Tail County Sheriff's Office
Otter Tail Cnty SO Policy Manual
Portable Audio/Video Recorders
Copyright Lexipol, LLC 2023/08/11, All Rights Reserved.
Published with permission by Otter Tail County Sheriff's Office Portable Audio/Video Recorders - 2
conspicuous manner when in use or otherwise notify persons that they are being recorded,
whenever reasonably practicable.
When using a portable recorder, the assigned member shall record their name, employee number,
and the current date and time at the beginning and the end of the shift or other period of use,
regardless of whether any activity was recorded. This procedure is not required when the recording
device and related software captures the user's unique identification and the date and time of
each recording.
Members should document the existence of a recording in any report or other official record of the
contact, including any instance where the recorder malfunctioned or the member deactivated the
recording (Minn. Stat. § 626.8473). Members should include the reason for deactivation.
422.5 ACTIVATION OF THE AUDIO/VIDEO RECORDER
This policy is not intended to describe every possible situation in which the recorder should be
used, although there are many situations where its use is appropriate. Members should activate
the recorder any time the member believes it would be appropriate or valuable to record an
incident.
The recorder should be activated in any of the following situations:
(a)All enforcement and investigative contacts including stops and field interview (FI)
situations
(b)Traffic stops including, but not limited to, traffic violations, stranded motorist assistance
and all crime interdiction stops
(c)Self-initiated activity in which a member would normally notify the Communications
Center
(d)Any other contact that becomes adversarial after the initial contact in a situation that
would not otherwise require recording
Members should remain sensitive to the dignity of all individuals being recorded and exercise
sound discretion to respect privacy by discontinuing recording whenever it reasonably appears to
the member that such privacy may outweigh any legitimate law enforcement interest in recording.
Requests by members of the public to stop recording should be considered using this same
criterion. Recording should resume when privacy is no longer at issue unless the circumstances
no longer fit the criteria for recording.
At no time is a member expected to jeopardize his/her safety in order to activate a portable recorder
or change the recording media. However, the recorder should be activated in situations described
above as soon as reasonably practicable.
422.5.1 CESSATION OF RECORDING
Once activated, the portable recorder should remain on continuously until the member reasonably
believes that his/her direct participation in the incident is complete or the situation no longer fits
Otter Tail County Sheriff's Office
Otter Tail Cnty SO Policy Manual
Portable Audio/Video Recorders
Copyright Lexipol, LLC 2023/08/11, All Rights Reserved.
Published with permission by Otter Tail County Sheriff's Office Portable Audio/Video Recorders - 3
the criteria for activation. Recording may be stopped during significant periods of inactivity such
as report writing or other breaks from direct participation in the incident.
422.5.2 SURREPTITIOUS RECORDINGS
Minnesota law permits an individual to surreptitiously record any conversation in which one party
to the conversation has given his/her permission (Minn. Stat. § 626A.02).
Members of the Office may surreptitiously record any conversation during the course of a criminal
investigation in which the member reasonably believes that such a recording will be lawful and
beneficial to the investigation.
Members shall not surreptitiously record another office member without a court order unless
lawfully authorized by the Sheriff or the authorized designee.
422.5.3 EXPLOSIVE DEVICE
Many portable recorders, including body-worn cameras and audio/video transmitters, emit radio
waves that could trigger an explosive device. Therefore, these devices should not be used where
an explosive device may be present.
422.6 PROHIBITED USE OF PORTABLE RECORDERS
Members are prohibited from using office-issued portable recorders and recording media for
personal use and are prohibited from making personal copies of recordings created while on-duty
or while acting in their official capacity.
Members are also prohibited from retaining recordings of activities or information obtained while
on-duty, whether the recording was created with office-issued or personally owned recorders.
Members shall not duplicate or distribute such recordings, except for authorized legitimate office
business purposes. All such recordings shall be retained at the Office.
Members are prohibited from using personally owned recording devices while on-duty without
the express consent of the Shift Sergeant. Any member who uses a personally owned recorder
for office-related activities shall comply with the provisions of this policy, including retention and
release requirements.
Recordings shall not be used by any member for the purpose of embarrassment, intimidation or
ridicule.
422.7 IDENTIFICATION AND PRESERVATION OF RECORDINGS
To assist with identifying and preserving data and recordings, members should download, tag or
mark the recordings in accordance with procedure and document the existence of the recording
in any related case report.
A member should transfer, tag or mark recordings when the member reasonably believes:
(a)The recording contains evidence relevant to potential criminal, civil or administrative
matters.
(b)A complainant, victim or witness has requested non-disclosure.
Otter Tail County Sheriff's Office
Otter Tail Cnty SO Policy Manual
Portable Audio/Video Recorders
Copyright Lexipol, LLC 2023/08/11, All Rights Reserved.
Published with permission by Otter Tail County Sheriff's Office Portable Audio/Video Recorders - 4
(c)A complainant, victim or witness has not requested non-disclosure but the disclosure
of the recording may endanger the person.
(d)Disclosure may be an unreasonable violation of someone’s privacy.
(e)Medical or mental health information is contained.
(f)Disclosure may compromise an under-cover officer or confidential informant.
(g)The recording or portions of the recording may be protected under the Minnesota Data
Practices Act.
Any time a member reasonably believes a recorded contact may be beneficial in a non-criminal
matter (e.g., a hostile contact), the member should promptly notify a supervisor of the existence
of the recording.
422.7.1 RETENTION REQUIREMENTS
Portable recordings may be considered criminal investigative data subject to public disclosure
(Minn. Stat. § 13.82, Subd. 7). All recordings shall be retained for a period consistent with the
requirements of the organization’s records retention schedule but in no event for a period less
than 180 days.
422.8 REVIEW OF RECORDED MEDIA FILES
When preparing written reports, members should review their recordings as a resource (see the
Officer-Involved Shootings and Deaths Policy for guidance in those cases). However, members
shall not retain personal copies of recordings. Members should not use the fact that a recording
was made as a reason to write a less detailed report.
Supervisors are authorized to review relevant recordings any time they are investigating alleged
misconduct or reports of meritorious conduct or whenever such recordings would be beneficial in
reviewing the member's performance.
Recorded files may also be reviewed:
(a)By a supervisor as part of internal audits and reviews as required by Minn. Stat. §
626.8473.
(b)Upon approval by a supervisor, by any member of the Office who is participating in
an official investigation, such as a personnel complaint, administrative investigation,
or criminal investigation.
(c)Pursuant to lawful process or by court personnel who are otherwise authorized to
review evidence in a related case.
(d)By media personnel with permission of the Sheriff or the authorized designee.
(e)In compliance with the Minnesota Data Practices Act request, if permitted or required
by the Act, including pursuant to Minn. Stat. § 13.82, Subd. 15, and in accordance
with the Records Maintenance and Release Policy.
All recordings should be reviewed by the Custodian of Records prior to public release (see the
Records Maintenance and Release Policy). Recordings that are clearly offensive to common
Otter Tail County Sheriff's Office
Otter Tail Cnty SO Policy Manual
Portable Audio/Video Recorders
Copyright Lexipol, LLC 2023/08/11, All Rights Reserved.
Published with permission by Otter Tail County Sheriff's Office Portable Audio/Video Recorders - 5
sensibilities should not be publicly released unless disclosure is required by law or order of the
court (Minn. Stat. § 13.82, Subd. 7; Minn. Stat. § 13.825, Subd. 2).
422.9 COORDINATOR
The Sheriff or the authorized designee should designate a coordinator responsible for (Minn. Stat.
§ 626.8473; Minn. Stat. § 13.825):
(a)Establishing procedures for the security, storage, and maintenance of data and
recordings.
1.The coordinator should work with the Custodian of Records and the member
assigned to coordinate the use, access, and release of protected information to
ensure that procedures comply with requirements of the Minnesota Government
Data Practices Act (MGDPA) and other applicable laws (Minn. Stat. § 13.01 et
seq.) (see the Protected Information and the Records Maintenance and Release
policies).
2.The coordinator should work with the Custodian of Records to identify recordings
that must be retained for a specific time frame under Minnesota law (e.g., firearm
discharges, certain use of force incidents, formal complaints).
(b)Establishing procedures for accessing data and recordings.
1.These procedures should include the process to obtain written authorization
for access to non-public data by OTCSO members and members of other
governmental entities and agencies.
(c)Establishing procedures for logging or auditing access.
(d)Establishing procedures for transferring, downloading, tagging, or marking events.
(e)Establishing an inventory of portable recorders including:
1.Total number of devices owned or maintained by the Otter Tail County Sheriff's
Office.
2.Daily record of the total number deployed and used by members and, if
applicable, the precinct or district in which the devices were used.
3.Total amount of recorded audio and video data collected by the devices and
maintained by the Otter Tail County Sheriff's Office.
(f)Preparing the biennial audit required by Minn. Stat. § 13.825, Subd. 9.
(g)Notifying the Bureau of Criminal Apprehension (BCA) in a timely manner when new
equipment is obtained by the Otter Tail County Sheriff's Office that expands the type
or scope of surveillance capabilities of the office's portable recorders.
(h)Ensuring that this Portable Audio/Video Recorders Policy is posted on the Office
website.