Background:

The exchange of ideas, information, and data is the hallmark of the research endeavor. As part of these activities, individuals are anticipated to use images or other electronic recordings as research, education, or training resources. However, because images or other publicly available data can be misrepresented to target researchers and rally public support against animal research, the health of animals as well as the safety of researcher(s), staff, and other employees must be taken into consideration.

This Policy specifies the conditions and requirements for photography, videotaping and audio recording of animals, persons and animal use areas at the University of California, Riverside (UCR). It is not the intent of this policy to prohibit or limit the data collection/recordings needed to conduct research or to limit scientific publications.

NOTE: All situations involving outside requests to obtain images or video (e.g. news organizations) must be processed through the UCR University Communications Office.

Definitions:

Research animals - any vertebrate animal (i.e., traditional laboratory animals, agricultural animals, wildlife, and aquatic species) produced for or used in research, testing, or teaching. (Guide for the Care and Use of Laboratory Animals, 8th edition.)

Animal use area – All areas at UCR where research animals are housed or where researchers observe or perform any studies with animals, including field studies and for instructional purposes.

Filming or video recording – The capture of moving images (e.g., animals, facilities or equipment) by any means on any media now in use or that may be available in the future, including but not limited to, film, videotape, digital disk, or any electronic transmission to another medium or the internet.

Photography – The capture of still images onto any compatible medium, or posting to the internet, by any means or devices now in use or that may be available in the future, including but not limited to, film cameras, digital cameras, electronic devices such as personal computers, mobile phones or personal digital devices.

Audio Recording – The capture of sounds onto any compatible medium, or posting to the internet, by any means or devices now in use or that may be invented in the future including but not limited to, electronic devices such as personal computers, mobile phones or personal digital devices.

Policy:

The use of any recording device (e.g., film camera, digital camera, camera phone, digital recorder, sound recorder, live streaming equipment) to record images or sounds of research animals or animal use areas is prohibited unless one of the following exceptions applies:

1. When performed by the Principal Investigator (PI) or his/her designee(s) for scientifically justified reasons (e.g., behavioral analysis, clinical feature documentation, or research documentation) as described in an approved Animal Use Protocol (AUP) or an amendment; or,
2. When performed by, or at the discretion of, the Campus Veterinarian (CV) for diagnosing or documenting clinical disease, veterinary care, or treatment; or,
3. When performed by government inspectors (e.g., USDA Veterinary Medical Officer) or Office of Research Integrity (ORI) staff during USDA or Institutional Animal Care and Use Committee (IACUC) inspections of animal facilities; or,
4. When performed by a PI or his/her designee for instructional purposes under an IACUC-approved protocol (e.g., for training members of the lab, collaborators, or for coursework). The AUP must contain details of the instructional procedures to be recorded, how the recording will be used and distributed, and the intended audiences. For impromptu recordings of unusual or unexpected events, the Office of Research Integrity, the IACUC, and/or Campus Veterinarian must be informed within seven days to request approval to use the impromptu recording; Requests should be emailed to iacuc@ucr.edu.
5. When performed by personnel as required to document condition of facilities, compliance or animal handling issues at the direction of and authorized by University officials, IACUC, Campus Veterinarian, or representatives of federal agencies or, 
6. When performed by EH&S, emergency and other official personnel (e.g., fire, police) for purposes of accident/incident report and investigation.  When possible, the Campus Veterinarian or EH&S personnel should accompany non-UCR individuals.  The Office of Research Integrity (ORI), the IACUC, and/or Campus Veterinarian should be notified prior to the photography, if possible; if not, the ORI, the IACUC, and/or Campus Veterinarian must be informed within 48 hours of photography performed by or overseen by EH&S.

University personnel who wish to record in animal use areas for reasons not described in the above list of exceptions must obtain specific permission or authorization from the Office of Research Integrity, the IACUC, and/or Campus Veterinarian prior to recording. 

Violation of this policy or any of its parts will be considered noncompliance with this University policy. Requests for permission should be emailed to iacuc@ucr.edu.

Responsibilities:

The PI:

1. Must ensure that the act of taking photographs, audio or video recordings by the PI and his/her lab members accurately portrays what is described and approved in their AUP.
2. Is ultimately responsible for the security and use of all photographs/videotapes obtained of research animals and/or animal use areas by the PI or his/her designees, and for ensuring all research personnel in his/her laboratory have read and understand the requirements stated in this policy.

General Guidance for Implementing this Policy:

1. All recordings of research animals must be in accordance with the following requirements:
• All procedures to be recorded or shown must be described in the approved AUP.
• Animals that are ill; have visible lesions, or visible research alterations (implants, wounds, bite marks, lesions tumors, etc.) may not be photographed/video-recorded unless described in an approved AUP or with specific authorization or permission from the ORI, the IACUC, and/or the CV.
• No references to personal identifying information should be visible in the photograph, paying close attention to background and items (e.g., cage cards, personnel names, logos).
• Appropriate handling, restraint and research methods for the species must be used.
• Appropriate personal protective equipment (PPE) must be worn by all persons in the photograph, as appropriate for the species of animal and procedure demonstrated.
• Animals should be in clean surroundings, clean cages, or clean pens with clean accessories. Water bottles and feeders should be full if visible in the photograph or recording.
• Photographs or videos cannot be posted to social media unless expressly permitted or authorized by the Office of Research Integrity, the IACUC, and/or the CV. Requests should be emailed to iacuc@ucr.edu 
• All requests to publicly distribute materials (excluding scientific publications and posters) must be approved by the Office or Research Integrity, the CV and/or the IACUC Chair or Vice Chair, who may consult with UCR’s University Communications Office or other institutional officials. Requests should be emailed to iacuc@ucr.edu. 
2. Students cannot take pictures or videos of animals used in labs or in coursework without explicit permission from the PI in accordance with his/her approved AUP.
3. Videos, photos, and audio recordings must be stored on a secure — preferably password-protected and encrypted— electronic storage device or computer.  Recordings should not be stored on devices that are easily accessed or stolen, e.g., a USB stick. 
4. Additional points to consider when performing risk assessments:
• The potential for photographs and recordings of animals to be the subject of public records requests by activist organizations. Such photographs or recordings may be accessible to members of the public under either California’s Public Records Act (PRA) or the Federal Freedom of Information Act (FOIA).
• The public perception of the use of animals. i.e., species, age of the animals, or if the animals look distressed.
• Careless or casual use of recordings from animal use areas could unintentionally expose the University to unwanted attention and harassment or could misrepresent the nature of research activities occurring at the University.
• Digital photos or videos likely have ‘meta data’ that provide an exact GPS location of the recording and other details which may put you or your lab at risk of being targeted. This information should be removed before sharing photos or other recordings (e.g., at conferences, on websites or with journalists).  

This policy replaces Policy 529-279 and Guidance 529-268, effective: 9/21/20