Surveillance tape retention

How long to Security surveillance tapes need to be retained? Is there a difference in retention between recordings that occur when triggered vs. continuous monitoring (VCR) system?

I recall from prior discussion that there may be statutory retention times in some states. Barring that, the benchmark I use for retention is the dispute timeframes allowed to depositors. The longest of these is Reg E- 60 days from the date of the statement. When I add that 60 days to the 1 month that the statement itself covers, that gives me a minimum retention time of 90 days.

I have been recommending 90 days also. However, someone gave me a record retention schedule that listed Security Video tape that stated a retention period of 1 year. There is no title on the retention schedule to indicate where it came from They don't know where they found it either, it was just laid on my desk...

In NY there is a law that deals specifically with ATM Surveillance tapes. You might want to check that too.

When I was in charge of Surveillance tapes, which was some 5 years or more ago, we kept the tapes for about 3 months. The tape was changed every week, and after about 3 months of this, we would go back to the first original tape and start all over.

I'm thinking that there is no retention requirement. I've never seen one within any regulation or law. It seems to me that this is an internal matter.

I finally found the retention list in question and of all places it is on BOL under BOL Tools. It was published by a user and linked through one of Ken's responses. It does indicate 1 year for Surveillance video tape. I wonder if this was just the publishers internal retention policy or if there is a requirement somewhere? Lot's of remodeling at our bank is making it difficult to put my hands on a hard copy record retention guide...is it addressed in there

I am not aware of any (federal) legal or regulatory requirements in this regard. The examiners were just here and never asked about it. None of our outside or (external) internal auditors have ever said anything about such a requirement. The only folks who regularly ask are the police and FBI.
We operate on the principle that no VCR tape should be utilized more than four times, which obviously translates into a 3 month retention period. If the FBI wants the tape after a robbery we give it to them, so we don't always reach 3 months with every tape. Still, this seems to be as long as law enforcement feels is appropriate.
Opinions expressed are my own and may not be shared by my employer. As legal advice they are worth exactly what you paid for them.

FYI - The Commonwealth of Kentucky requires retention of security tapes for one year.

Since you should be changing the tape daily to maximize the resolution does that mean each of your branches have 365 tapes? That seems excessive considering the only party hurt if you don't have video evidence is your institution.

The tapes are changed weekly, not daily. All branches retained 52 tapes as required by the State of Kentucky.

Autumn, in May of last year this issue came up with our institution. We emailed the Department of Finanacial Institutions (State of KY), where in turn the email was forwarded to staff counsel. The response was "there are no specific state requirements regarding how long a financial institution should maintian its security tapes. Moreover, I have not been able to find any federal guidelines on the point either. Accordingly, the amount of time that the bank retains a securty tape befoe reusing it is a policy matter for the bank." Could you give me the KRS where you have that information?

It's in the Kentucky retention schedule dated 1/4/91 and yes, that's the most recent. One page 4 under the security section it states 'camera surveillance log and film' - 1 year after date of record. The cover letter is signed by Ed Hatchett, Jr. If you want to send me a private message I can probably e-mail this to you on Monday. I'll be out of here in a few minutes.