UNITED STATES RAILROAD RETIREMENT BOARD 

OFFICE OF INSPECTOR GENERAL 

MARTIN 

DICKMAN

Digitally signed by MARTIN 

DICKMAN 

Date: 2023.03.31 13:53:55 

-05'00'

Memorandum

March 31, 2023 

TO All Office of Investigations Staff 

FROM Martin J. Dickman, Inspector General 

SUBJECT Body-Worn Camera Policy 

Please review the attached Office of Inspector General for the Railroad 

Retirement Board body-worn camera policy, effective date as described in the 

policy. 

Attachment 

844 N RUSH STREET CHICAGO IL 60611-1275 Printed on recycled paper 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Body-Worn Camera Policy 

FOR OFFICIAL USE ONLY (Public Availability to be Determined Under 5 U.S.C. 552) 

I. Background 

A. Policy Development 

This policy addresses the U.S. Railroad Retirement Board (RRB) Office of the Inspector General 

(OIG) Office of Investigations (OI) body-worn camera program. 

Parts of this policy are contingent on the availability of RRB OIG-issued body-worn cameras for 

RRB OIG special agents. This policy applies to all RRB OIG special agents who have been issued a 

body-worn camera. This policy mandating the use of a body-worn camera will only apply to RRB 

OIG special agents who have been provided an RRB OIG-issued body-worn camera. 

This policy will fully take effect upon the purchase and acquisition of body-worn camera 

equipment, the training of RRB OIG special agents in the use of that equipment, the conclusion 

of any pilot and training programs, and the development and deployment of the RRB OIG bodyworn camera program. 

This policy is promulgated to conform with the following: 

Deputy Attorney General “Body Worn Camera Policy” Memorandum dated July 7, 2021. 

https://www.justice.gov/dag/page/file/1402061/download 

Executive Order 14074, “Advancing Effective, Accountable Policing and Criminal Justice 

Practices to Enhance Public Trust and Public Safety,” requires that federal law enforcement 

agencies publicly post body worn camera policies. https://www.whitehouse.gov/briefingroom/presidential-actions/2022/05/25/executive-order-on-advancing-effective-accountablepolicing-and-criminal-justice-practices-to-enhance-public-trust-and-public-safety/ 

Policy: Special agents of the RRB OIG Office of Investigations (OI) must wear and activate their 

body-worn camera to record their actions during the tactical portion of enforcement 

operations (i.e., arrest and search warrants) unless otherwise authorized. Body-worn cameras 

will also be used during other enforcement operations where the use of a body-worn camera is 

appropriate for the proper performance of official duties and where recording is consistent 

with OIG policy and the law. Finally, body-worn cameras will be deployed when, based on the 

training and experience of the special agent, a situation could lead to the use of force or where 

it may be prudent to record their interactions (e.g., for transparency). 

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B. Importance of Body-Worn Cameras to Increase Policing Transparency 

Body-worn cameras can improve public trust, transparency, and accountability where the use 

of force can be reasonably anticipated during planned law enforcement operations by RRB OIG 

special agents. 

Body-worn cameras also provide an additional layer of safety for RRB OIG special agents. 

These devices document contact between RRB OIG special agents and others during planned 

law enforcement operations, which can help resolve complaints made against the special agent 

and protect the special agent from inaccurate allegations of misconduct. 

C. Body-Worn Camera Policy Relationship to Other Office of Investigations Policies 

Body-worn cameras may record things that a special agent did not see, hear, or perceive in a 

real-time interaction. But body-worn camera recordings are also limited by what the camera 

can perceive, and a special agent may have heard or seen things not recorded by the bodyworn camera. This policy does not supersede existing OIG OI policies for the collection of 

evidence, conducting interviews, the use of surreptitious recording devices in consensual 

monitoring, or investigative technique policies, including the RRB OIG Use of Force Policy. 

D. Definitions 

In this policy, a body-worn camera is an RRB OIG-provided device used to record video and 

audio of interactions between RRB OIG special agents and other individuals where the use of 

force may reasonably occur. The video and audio recorded by a body-worn camera and stored 

by the RRB OIG according to this policy is for use by law enforcement to document RRB OIG law 

enforcement interactions and give transparency to law enforcement actions where the use of 

force may reasonably occur. 

II. Body-Worn Camera Program Coordinator 

The Assistant Inspector General for Investigations (AIGI) or their designee will assign an RRB 

OIG OI employee to be the body-worn camera training program coordinator. 

The body-worn camera program training coordinator, and any relevant designees or associated 

staff, oversees the use of body-worn cameras and the RRB OIG OI body-worn camera program. 

Duties of the body-worn camera program coordinator include: 

• Training or arranging training (in coordination with the training agent) on the use of 

body-worn cameras. This is both to comply with any training requirements and ensure special 

agents know when to use their body-worn camera and feel comfortable doing so. 

• Maintaining auditable logs of all body-worn camera recordings. 

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• Periodic review or inspections of body-worn cameras to ensure equipment is operating 

properly and special agents are using the devices appropriately and in accordance with this 

policy. 

III. Training for the use of Body-Worn Cameras 

All RRB OIG special agents will complete initial and recurring training to establish and maintain 

proficiency and knowledge related to body-worn camera deployment, use and operation. 

IV. Body-Worn Camera Equipment 

A. Use of Body-Worn Camera Equipment 

Special Agents shall protect and conserve Federal property, including the body-worn camera 

and related equipment, and shall not use it for other than authorized activities. Special agents 

will exercise reasonable care when using body-worn cameras and related equipment to ensure 

proper functioning of the devices. 

Special agents will ensure that the body-worn camera is fully charged before deployment. 

B. Types of Body-Worn Cameras Authorized for Use 

The only type of body-worn camera authorized for use by RRB OIG special agents conducting 

RRB OIG operations are body-worn cameras provided by the RRB OIG. 

Additionally, RRB OIG special agents must follow all policies and procedures related to the 

storage of audio and video captured by their body-worn cameras, as detailed in this policy. 

RRB OIG special agents are not authorized to use a personal body-worn camera device. 

C. Equipment Malfunctions 

Special agents will notify their supervisor and the body-worn training program coordinator of 

any equipment malfunctions as soon as possible after discovering the malfunction. 

D. Loss or Theft of Equipment 

Special agents will notify their supervisor immediately, but no later than within 24 hours of the 

discovery of the loss or theft of a body-worn camera. 

The supervisor will notify the AIGI or their designee and the body-worn camera training 

program coordinator. 

V. Failure to Activate a Body-Worn Camera or Termination of a Body-Worn Camera Recording 

Failure of an RRB OIG special agent to activate a body-worn camera as directed or required by 

this policy may result in disciplinary action. 

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Unauthorized termination or inappropriate use of a body-worn camera recording may result in 

disciplinary action. 

Any misuse of a body-worn camera, including for personal use, may result in disciplinary action. 

VI. Deployment, Activation, and Deactivation of Body-Worn Cameras 

A. Circumstances Requiring the Use of Body-Worn Cameras 

RRB OIG special agents must wear and activate their body-worn camera to record their actions 

during the tactical portion of enforcement operations where the use of force is reasonably 

anticipated. This includes the planned execution of a search warrant or an arrest. 

Body-worn cameras will be used during other enforcement operations where the use of a bodyworn camera is appropriate for the proper performance of official duties and where recording 

is consistent with OI policy and the law. 

Body-worn cameras may be deployed when, based on the training and experience of the 

special agent, a situation could lead to the use of force or where it may be prudent to record 

their interactions (e.g., for transparency). RRB OIG special agents must request approval from 

their supervisor to deploy body-worn cameras for this purpose. 

B. Circumstances Prohibiting the Use of Body-Worn Cameras 

Body-worn cameras will not be used for recording interviews or for only evidence collection 

purposes. 

C. Activation of Body-Worn Cameras 

RRB OIG special agents must activate their body-worn cameras during planned law 

enforcement activities where a use of force may be reasonably anticipated, such as the planned 

execution of a search warrant or arrest warrant. 

The RRB OIG special agent leading an operation will inform all personnel participating in the 

enforcement operation and equipped with a body-worn camera when to activate their bodyworn cameras. Body-worn cameras will be activated at the beginning of a law enforcement 

action. Activation will generally be when approaching the persons or premises that is the 

subject of the operation for preplanned arrests or searches. Body-worn cameras will be 

programmed to record for a specified period prior to activation and after deactivation 

(buffering period). This footage will be preserved along with the recording after activation 

occurs. 

If an RRB OIG special agent wearing a body-worn camera encounters an individual who is 

uncooperative, violent, assaultive, or discussing criminal conduct that could (in the professional 

judgement of the special agent) lead to the use of force, the special agent should activate and 

record the encounter using the body-worn camera as soon as it is safe and practicable. 

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In the interest of transparency and to ensure the integrity of the recordings, body-worn 

cameras must remain activated until the activity is completed, unless the contact moves into an 

area restricted by this policy. 

D. Exceptions to Activating Body-Worn Cameras During Required Law Enforcement Activities 

RRB OIG special agents using body-worn cameras will attempt to be mindful of locations where 

recording may be: 

• Insensitive 

• Inappropriate 

• Prohibited. 

Additionally, body-worn cameras will not be used to record: 

• Operational or law enforcement-sensitive communications with other law enforcement 

personnel. 

• Undercover operations, including preplanned arrests or searches involving undercover 

employees or other covert personnel. 

• The execution of search warrants or orders for records or data when said execution 

does not involve entry of a physical location (e.g., a search warrant for emails issued to Google 

or Microsoft). 

• Searches of property lawfully in Government custody or control. 

• OI workplaces (e.g., regional field offices). 

• Routine activities unrelated to enforcement. 

• Locations where individuals have a reasonable expectation of privacy and have not 

consented to the recording (e.g., restrooms and locker rooms). 

An RRB OIG special agent requesting to record in one of these excepted places or situations can 

only do so if they receive express written permission from the RRB OIG AIGI or their designee. 

Special agents are not expected to activate their cameras when it would be unsafe, impractical, 

or impossible to do so. 

E. Deactivation of Body-Worn Cameras 

1. General Deactivation Statement 

If, for any reason, a special agent deactivates a body-worn camera, the special agent will 

verbally state the reason for the deactivation, the date, and the time prior to deactivating the 

body-worn camera. 

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2. Permission to Deactivate a Body-Worn Camera (Planned Operations) 

Special agents will only deactivate their body-worn camera at the direction of an operation’s 

lead RRB OIG special agent. 

An operation’s lead RRB OIG special agent can direct other RRB OIG special agents to deactivate 

their body-worn cameras, which will generally be when the site is safe and under law 

enforcement control. 

Reasons for deactivation of a body-worn camera include: 

• Battery conservation, if authorized by an operation’s lead RRB OIG special agent. (This 

does not negate the Section IV(A) requirement that all body-worn cameras should be fully 

charged before a law enforcement operation.) 

• For the RRB OIG special agent to obtain medical attention. 

• For the RRB OIG special agent to attend to a non-law enforcement personal matter (e.g., 

using the restroom). 

• The operation becomes restricted or exempted according to the recording policy (as 

described above). 

• Those exceptions identified in Section VI(D). 

VII. Joint Operations 

RRB OIG special agents will comply with and follow RRB OIG policy, regardless of any agency 

that may be the lead in a joint operation. 

The RRB OIG AIGI or their designee may determine that the use of a body-worn camera is not 

prudent during a joint operation and authorize in writing that the RRB OIG special agents 

participating do not have to use their body-worn cameras during the joint operation. Any 

deviation from the RRB OIG policy in this way will be documented in writing with the rationale 

and placed in the appropriate OI case file. 

In accordance with any applicable privacy laws, the body-worn camera program coordinator 

will coordinate the sharing of recordings related to joint law enforcement operations with the 

other participating agencies as necessary and will request that other participating law 

enforcement agencies share their recordings as well. When sharing RRB OIG body-worn camera 

recordings with other agencies, the body-worn program training coordinator will inform that 

agency that it may not share RRB OIG recordings with anyone outside of that agency without 

the express written permission of the AIGI, DIG, or IG. 

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VIII. Documenting the Use of Body-Worn Cameras 

A. Documentation in the Investigative Tracking System 

After the conclusion of a law enforcement activity or operation where a special agent used a 

body-worn camera to make a recording, the case agent will document the usage in a 

Memorandum of Record (MOR) (I-103). 

The MOR will follow the relevant timeliness guidelines for MOR set forth in the RRB OIG Special 

Agent Manual. 

B. Contents of Body-Worn Camera Recording Memorandums of Activity 

An MOR documenting the use of a body-worn camera will include: 

• Names of the team members (e.g., the RRB OIG special agents) participating in the 

operation, activity, or incident. 

• Whether all special agents wore body-worn cameras during the operation, activity, or 

incident. 

• Whether all body-worn cameras were activated prior to the operation, activity, or 

incident. 

• If any body-worn cameras malfunctioned or were inoperable during the activity, 

operation, or incident. 

• If any body-worn cameras were not activated prior to or during the activity, operation, 

or incident. 

• If any body-worn cameras were turned off during the activity, operation, or incident. 

• If any body-worn camera recordings were interrupted or terminated during the activity, 

operation, or incident. 

C. Documentation of Failure to Activate Body-Worn Camera 

If an RRB OIG special agent fails to activate their body-worn camera, fails to record an entire 

contact that should be recorded according to this policy, or interrupts the recording, the special 

agent will document in the MOR why the recording was not made, interrupted, or terminated. 

IX. Download and Storage of Body-Worn Camera Recordings 

The download and storage of body-worn camera recordings is governed by the technological 

solutions and environment of the RRB OIG’s body-worn camera program. 

All body-worn camera recordings will be downloaded and securely saved for storage as 

appropriate and according to records retention policies in this document. 

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Each body-worn camera recording will have an associated date and time of recording, recording 

identifier, and an identified lead or case agent. 

X. Records Retention 

A. Recordings Associated with Use of Force Incidents and Complaints or Allegations Against 

RRB OIG Special Agents 

Body-worn camera recordings associated with use of force incidents that involve RRB OIG 

special agents or complaints or allegations that involve RRB OIG special agents will be retained 

as evidence and retained according to the RRB OIG policy, in consultation with the RRB OIG 

Counsel and as directed by the AIGI, a Federal or State prosecutor, or other investigating 

agency. 

B. Recordings Not Associated with Complaints or Allegations 

Body-worn camera recordings that are not associated with complaints, allegations, or use of 

force incidents involving RRB OIG special agents or staff will be retained in compliance with 

records retention requirements following case closure unless a request is provided in writing to 

the body-worn camera program coordinator through the AIGI or their designee. 

C. Recordings Associated with Training Exercises 

Body-worn camera recordings associated with normal training exercises (e.g., a training 

exercise where there is no reported injury) will be retained in compliance with records 

retention requirements. 

XI. Body-Worn Camera Recordings 

RRB OIG body-worn camera equipment and all data, images, video, and metadata captured, 

recorded, or otherwise produced by the equipment are the sole property of the RRB OIG. 

Special agents will not edit, alter, erase, duplicate, copy, share, or otherwise release, disclose, 

or distribute any body-worn camera recording in any manner without prior written 

authorization from the AIGI or their designee. 

Unauthorized access, copying, or release of body-worn camera recordings or files is prohibited. 

XII. Deleting Recordings 

Any request to delete a portion or portions of a recording (for example, in the case of an 

accidental recording) must be submitted in writing. The request will include the specific reason 

for requesting the recording be deleted. 

The IG, DIG, or the AIGI in consultation with the IG Counsel must approve all deletion requests 

in writing. A memorandum will authorize the deletion or explain the reasons for not approving 

the request for deletion. The memorandum will be filed in the appropriate case OI case file. 

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The body-worn camera program coordinator may delete the recording only after receiving an 

approved memorandum authorizing the deletion. 

XIII. Access and Review of Body-Worn Camera Recordings 

A. Prohibited Reviews of Body-Worn Camera Recordings 

Viewing of body-worn camera recordings at the scene of an incident is prohibited. 

B. Permitted Reviews of Body-Worn Camera Recordings 

RRB OIG special agents are entitled to access the audio and video derived from their issued 

body-worn camera recording when it is reasonable and necessary for the special agent to 

access the body-worn camera recording to perform essential functions of their job. This 

includes but is not limited to a review necessary to create an MOR describing a recorded 

operation. 

An RRB OIG special agent may also access body-worn camera recordings when necessary to 

respond to allegations of administrative or criminal misconduct related to the recorded 

enforcement activity, with the following limitations: 

1.Administrative investigation of a special agent’s conduct related to a recorded 

enforcement activity. 

When a special agent is subject to an administrative investigation related to a recorded 

enforcement activity, the special agent may review their own body-worn camera recording 

prior to being interviewed (by either RRB OIG OI personnel or non-OIG personnel) about 

allegations related to the special agent’s conduct. 

The special agent may review a copy of their own body-worn camera footage with their 

attorney or other representative. 

2. Following a Use of Force incident (including the discharge of a firearm) 

Following a use of force incident or discharge of a firearm, the special agent will be given an 

opportunity to view their own body-worn camera recording prior to giving a formal statement. 

Special agents who are witnesses to a special agent-involved shooting or use of force incident 

will also be allowed to view their own body-worn camera recording prior to giving a formal 

statement. 

C. Internal Investigations 

RRB OIG special agents who are conducting an official internal investigation of another RRB OIG 

special agent may request permission to review body-worn camera recordings. 

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The investigating special agents must request permission to review the subject special agent’s 

body-worn camera recording in a memorandum to the AIGI or their designee. The 

memorandum will state the reason for the request and will be filed in the appropriate case file. 

D. Access and Review of Body-Worn Camera Recordings 

All instances where access to a recording is granted will be audited to ensure that only 

authorized persons are accessing the data for legitimate and authorized purposes. 

Any requests to review body-worn camera recordings—except for permitted reviews as 

specifically stated elsewhere in this policy (for example, a special agent may review their bodyworn camera footage to write an MOR)—must be made in a memorandum to the AIGI or their 

designee. The request must state the reasons for requesting to review the recording. 

E. Training 

Body-worn camera recordings may be used for training purposes. 

Access to body-worn camera recordings for training purposes will be coordinated through the 

body-worn camera program coordinator, in consultation with IG Counsel. IG Counsel will obtain 

the written permission of any RRB OIG personnel whose recordings or images are or would be 

depicted in any training videos or materials. 

F. Supervisory Reviews of Body-Worn Camera Recordings 

1.Permitted Review for After-Action Debrief and Training 

Supervisors are permitted to view body-worn camera recordings to conduct “after-action 

debriefs” and for training purposes as described elsewhere in this policy. 

Requests to review body-worn camera recordings for this purpose require the written approval 

of the AIGI or their designee. The supervisor will document the request in a memorandum that 

states the reason for the review. 

2. Prohibited 

Generally, with the exception of a supervisor’s “after-action debrief” referenced above, bodyworn camera recordings will not be reviewed or used solely for the purpose of evaluating an 

RRB OIG special agent’s performance during an operation. A supervisor may request an 

exception to this prohibition by submitting a request in writing to the AIGI, who will obtain legal 

guidance from IG Counsel. 

Body-worn camera recordings will not be reviewed solely for conducting performance 

appraisals. 

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XIV. Disclosure of Body-Worn Camera Recordings 

All requests for disclosure of body-worn camera recordings or related information will be 

forwarded to the body-worn camera training program coordinator, with a cc to the AIGI or their 

designee. 

The body-worn camera training program coordinator will prioritize and expedite the review of 

all requests for body-worn camera recordings that involve the serious bodily harm, injury, or 

death of any individual. 

A. Redacting Recordings 

The body-worn camera training program coordinator and IG Counsel will make, oversee, and 

approve any redactions to body-worn camera footage prior to any disclosure. 

B. Body-Worn Camera Recordings as Law Enforcement Sensitive Information 

In all instances, RRB OIG body-worn camera recordings will be treated as law enforcement 

sensitive information. The premature disclosure of law enforcement sensitive information could 

reasonably be expected to interfere with enforcement proceedings. 

Body-worn camera recordings will also be treated as potential evidence in a Federal 

investigation, subject to applicable Federal laws, rules, and policies concerning any such 

disclosure, and therefore deemed privileged, absent appropriate redaction prior to disclosure. 

All requests for body-worn camera recordings unrelated to pending RRB OIG criminal 

investigations or cases will be forwarded to the body-worn camera program coordinator and IG 

Counsel, who will coordinate the response for such requests. 

Nothing in this policy will be deemed to provide a right of public access to RRB OIG body-worn 

camera recordings. RRB OIG body-worn camera recordings are controlled by and are the 

property of the RRB OIG and will be retained and managed by the RRB OIG OI. 

C. Expedited Public Release of RRB OIG Body Worn Camera Recording(s). 

If RRB OIG body worn camera recording(s) depicts conduct resulting in serious bodily injury or 

death of another, the RRB OIG shall notify the United States Attorney as early as possible if it 

desires to publicly release the body-worn camera recording(s). The RRB OIG and the United 

States Attorney will expeditiously review the recording(s) and provide official concurrence with 

public release as soon as practical, unless there are specific and compelling circumstances 

justifying an objection to public release that cannot be resolved by redaction or other means. 

Upon official concurrence, the RRB OIG may immediately release the recording(s) with any 

agreed-upon redactions, giving as much advance notice as possible to the United States 

Attorney as to the time and manner of its release. 

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D. Freedom of Information Act Requests 

Body-worn camera recordings can be subject to release pursuant to Freedom of Information 

Act (FOIA) requests. 

Any FOIA requests for the release of body-worn camera recordings will be forwarded to the 

body-worn camera training program coordinator and IG Counsel. The body-worn camera 

training program coordinator and IG Counsel will coordinate to release recordings in an 

expeditious manner, taking into account any applicable FOIA exemptions, to satisfy the FOIA 

request as necessary or required by law. 

E. Privacy Act Referrals 

The Privacy Act of 1974 (Title 5 United States Code Section 552a) provides safeguards for 

individuals against an invasion of personal privacy through the misuse of records by Federal 

agencies. The Privacy Act balances the individual’s personal privacy interest against the 

Government’s need to maintain information about individuals. 

RRB OIG special agents will follow agency procedures for Privacy Act referrals. IG Counsel will 

coordinate with OI to respond to Privacy Act referrals related to body-worn camera recordings 

to satisfy any legal requirements or response. 

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