Chapter 3772-19 Surveillance
(A) Each casino operator must comply with the minimum surveillance requirements as approved by the commission. The casino surveillance system shall be in place to assist the casino operator and the commission in safeguarding assets, in deterring, detecting and prosecuting criminal acts, and in maintaining public confidence and trust,
(B) Each casino operator shall install, maintain and operate in the casino facility a surveillance system in accordance with the specifications of this rule and as approved by the commission. The surveillance system shall provide access and override access to the commission.
(C) At any time and without notice, the casino surveillance system, and its component parts, shall be subject to testing by the commission.
(D) Upon good cause shown, the commission may, at its discretion, grant a waiver from compliance with any surveillance requirement. All requests for waivers must be in writing and state the reasons for the request and the alternative measures that the casino operator will undertake to accomplish the objectives of the surveillance requirements. The casino operator must comply with the surveillance requirements approved by the commission while the request for waiver is pending. The commission may impose additional terms or requirements as a condition of granting a waiver.
Cite as Ohio Admin. Code 3772-19-01
R.C. 119.032 review dates: 03/14/2014 and 06/01/2019
Promulgated Under: 119.03
Statutory Authority: 3772.03
Rule Amplifies: 3772.03 , 3772.10, 3772.11
Prior Effective Dates: 10/12/2011
(A) A casino operator must submit a surveillance plan to the commission for approval at least sixty days before the commencement of casino gaming. The surveillance plan must include the following
(1) A floor plan of the casino facility that shows the placement of all surveillance equipment;
(2) A detailed description of the surveillance system and its equipment;
(3) The procedures utilized for operation of the casino surveillance department;
(4) Staffing plans;
(5) Plans for monitoring security detention rooms;
(6) A list of personnel authorized to access the casino surveillance room;
(7) The surveillance retention schedule, evidencing that all cameras are set for a retention period pursuant to this chapter; and
(8) Any other information the commission deems necessary.
(B) Alterations to the surveillance plan, including system changes and upgrades, shall be submitted to the commission for approval. The request to alter the surveillance plan must include details of the change, including a copy of the applicable areas of the casino facility floor plan and the reason for the change.
(C) A casino operator shall not commence casino gaming until the surveillance plan or alterations are approved by the commission and changes in coverage are examined and approved by the commission or the commission's agent.
(D) A casino operator shall maintain a copy of its current surveillance plan in the surveillance department and make the plan immediately available to the commission upon request.
Cite as Ohio Admin. Code 3772-19-02
(A) The casino operator shall install in the casino facility a surveillance system complying with the specifications herein and shall provide access and override access for the system to the commission's agents.
(B) The surveillance system must include components that meet or exceed the following:
(1) Video cameras of sufficient quality so as to meet the following requirements:
(a) Video cameras must possess the capability of having their picture displayed on a video monitor and recorded;
(b) Video camera image quality must be approved by the commission.
(c) Video cameras must include a combination of cameras installed to fixed positions and cameras installed with pan, tilt and zoom capabilities.
(d) Video cameras must be installed in a manner that will prevent them from being readily obstructed, tampered with, or disabled; and
(e) Video cameras must be installed in a manner which provides ambiguity of their direction and coverage capabilities;
(2) Video monitors that provide for the viewing of both live and recorded surveillance video and audio. Each video monitor screen must be of such a size that all images depicted are clearly discernible by the surveillance operator;
(3) Image capturing utility with the ability to generate, upon command, a clear, color copy of the image depicted on the digital recording. The image shall be in a format which allows for adjustment and printing;
(4) Date and time generators based on a synchronized, central or master clock, recorded on all digital recordings and visible on any monitor. Date and time generators shall remain accurate at all times the casino surveillance system is operational;
(5) Wiring installed in a way that will prevent tampering;
(6) An uninterrupted power supply system which is automatically engaged in case of a power outage. It shall be capable of providing power to the casino surveillance system, date and time generators, and full lighting to the casino facility within ten seconds;
(7) The ability to execute manual and automatic sequential switching;
(8) A central processor whereby all closed-circuit video cameras must be routed before reaching recorders; and
(9) A digital video recording system approved by the commission. The system shall be configured so that a failure of any single component will not result in the loss of any data from the media storage system. The system shall also be configured so that any recordings that are dubbed or clipped and saved off the main recording system are watermarked and in a non-editable format.
(C) The surveillance system, including servers used to store surveillance recordings and data, must be secure and separated from other casino systems, including casino information technology, ticket vouchering technology, and electronic gaming device and network systems. The surveillance system may interface with point of sale, slot data, or table games systems so that point of sale, slot data or table games systems may feed information to the surveillance system and sufficient firewalls prevent information from the surveillance system from feeding to those other systems.
(D) The surveillance system must have a failure notification system that provides an audible and a visual notification of any failure in the surveillance system or the digital video recording media storage system.
(E) The casino facility must have adequate lighting in all areas where camera coverage is required. The lighting shall be of sufficient intensity to produce clear digitally recorded and still picture production.
(F) Any failure of a digital video recording storage media system must be repaired or replaced within eight hours of the failure.
(G) Access to devices and software controlling the surveillance system must be limited only to surveillance employees and shall be secured by unique user identification and confidential password. Passwords must be specific to each surveillance employee and shall be changed every thirty days or sooner if the director of surveillance or an employee has reason to believe that the password may be compromised.
(H) The surveillance system must include a system log to capture all activities of persons accessing the surveillance system.
(I) Reformat and erase capabilities of the surveillance system must either be de-activated or password protected.
(J) Applicable cameras capable of movement must be programmed to turn to the site of activated facility alarms.
(K) Cameras capable of movement must be programmed to return to a set home location after a set period of inactivity.
Cite as Ohio Admin. Code 3772-19-03
(A) The casino operator shall have a commission surveillance room at the casino facility for the exclusive use of the commission's agents to monitor and record activity at the casino facility. The commission shall designate and approve the location and size of the commission surveillance room.
(B) The commission surveillance room shall have at least two separate workstations approved by the commission, each with multiple monitors, and shall have appropriate switching capabilities to ensure that all surveillance cameras are accessible to monitor in the commission surveillance room. The commission's agent shall have total control to determine what is visible on the monitors located in the commission surveillance room.
(C) The casino operator shall provide on-site commission facilities at the casino facility for the exclusive use of the commission's agents. These rooms shall be separate and secure and be in addition to the commission surveillance room. The commission shall designate and approve the location and size of the on-site commission facilities.
(D) The casino operator shall provide separate telephone and internet communication systems for use by the commission's agents as approved by the commission.
Cite as Ohio Admin. Code 3772-19-04
(A) The surveillance system for all licensed casino facilities shall be maintained and operated from the casino surveillance room. All equipment that is utilized to monitor or record must remain solely accessible to the casino surveillance room personnel and exclusively for casino facility surveillance, except when equipment is being repaired or replaced.
(B) The entrance to the casino surveillance room must be located so that it is not readily accessible by either casino employees who work primarily on the casino floor or the general public.
(C) Access to the casino surveillance room must be limited to surveillance personnel. Any agent of the commission must be provided access to the surveillance room immediately upon request and presentation of proper identification. Other persons may only enter the casino surveillance room after obtaining specific authorization by the director of surveillance and by the commission or a commission agent.
(D) The casino surveillance room must be staffed by at least two surveillance employees at all times. The minimum casino surveillance room staffing may be increased at the discretion of the commission.
Cite as Ohio Admin. Code 3772-19-05
(A) The director of surveillance, the individual with direct responsibility and oversight of the surveillance department, must be subject only to the direct control of the licensed organization's outside senior corporate or organizational management, including, but not limited to, an appropriate board of directors or other executives within the casino operator's corporate or organizational structure regarding matters of policy, purpose, responsibility, and authority. The director of surveillance shall remain impartial and must not be subject to the control of the general manager or other casino facility manager.
(B) Surveillance employees shall be trained in surveillance techniques, the operation of all surveillance equipment, the requirements of Chapter 3772. of the Revised Code, the rules promulgated thereunder, and the casino operator's internal control procedures and surveillance plan.
(C) Surveillance employees shall only perform tasks in the course of their employment that further the purpose of the surveillance operation.
(D) A casino operator may not divert surveillance system resources or surveillance employees from their intended surveillance purposes or functions without the permission of the commission or the commission's agent. This prohibition does not forbid a casino operator from using existing surveillance recordings for operational or other legitimate purposes when necessary and at the ultimate discretion of the commission or the commission's agent. Additionally, surveillance employees are not permitted to transfer to gaming-related positions within the casino prior to one year after leaving the surveillance department, unless otherwise approved by the commission.
(E) All surveillance employees must be employees of the casino operator. Surveillance functions may not be outsourced to an unlicensed entity.
Cite as Ohio Admin. Code 3772-19-06
(A) All surveillance coverage at the casino facility must be approved by the commission.
(B) The surveillance system of all casino facilities that operate table games must monitor and record:
(1) Each table game area, with sufficient clarity to identify patrons and dealers; and
(2) Each table game surface, with sufficient coverage and clarity to simultaneously view the table bank and determine the configuration of wagers, card values, game outcome, and table number.
(C) Each progressive table game must also be recorded and monitored by a camera that provides continuous coverage of the progressive jackpot meter.
(D) Each table game area used for craps and roulette must also be recorded and monitored by dedicated cameras that provide continuous coverage sufficient enough so that the dice and roulette wheel outcomes may be clearly viewed.
(E) The surveillance system of all casino facilities must monitor and record a general overview of the activities occurring at slot machines and the casino floor area surrounding and containing slot machines in the casino facility.
(F) The surveillance system of all casino facilities must possess the capability to monitor and record each slot machine, sufficient to simultaneously distinguish the specific location or asset number of the slot machine, the display of the outcome (reel strips), and credit meter.
(G) The surveillance system of all casino facilities must monitor and record with a dedicated camera each slot machine offering a payout of more than two hundred fifty thousand dollars including all patrons and employees at the slot machine and the face of the slot machine with sufficient clarity to identify the payout line(s) of the machine.
(H) The surveillance system of all casino facilities must monitor and record with a dedicated camera at each redemption kiosk, including all patrons and employees at the redemption kiosks.
(I) The surveillance department must receive an audible or visual alert indicating unauthorized access to any slot machine. A surveillance employee shall monitor all slot machines for which an alert is received until such
(J) The surveillance system of licensed casino facilities must monitor and record a general overview of activities occurring in each casino cage and vault area, with sufficient clarity to identify employees within the cage and patrons and employees at the counter areas including a facial view of the patrons.
(K) The casino cage or vault area in which fills and credits are transacted must be monitored by a dedicated video camera or motion-activated dedicated video camera that provides coverage with sufficient clarity to identify chip values and the amounts on the fill and credit slips.
(L) The surveillance system of all casino facilities must monitor and record with a dedicated camera, in both audio and video, the count room, including all doors to the room, all drop boxes, safes, and counting surfaces, and all count team personnel. The counting surface area must be continuously monitored by a dedicated video camera during the count. A notice must be posted in the count room advising all persons that the area is under video and audio surveillance.
(M) The surveillance system of all casino facilities must monitor and record all areas where currency is sorted, stacked, counted, verified or stored during the count process. Coverage of the currency counting machines and currency sorting machines must be sufficiently clear to view the currency input, output and reject areas.
(N) All counting surfaces must be transparent so that activity occurring under the table can be observed.
(O) The surveillance system of all casino facilities must monitor and record, in audio and video, the area of any security office or other room in which persons may be detained by casino security personnel. A notice must be posted in the security office or other room advising all persons that the area is under video and audio surveillance.
(P) When a person is detained by casino security personnel in the casino security office, the detention and any questioning must be recorded. A person is considered to be detained when the person has been confined in the casino security office in such a manner as to deprive him of the ability to leave voluntarily.
(Q) The surveillance system of all casino facilities must monitor and record activity in all non-gaming areas as approved by the commission.
(R) The surveillance system of all casino facilities must monitor and record all entrances, exits, parking areas, and event spaces surrounding the casino facility.
Cite as Ohio Admin. Code 3772-19-07
(A) All recordings of coverage, including audio recordings, must be retained for a minimum of thirty days.
(B) Recordings of detentions and questioning by security personnel must be retained for a minimum of ninety days.
(C) Recordings of activities perceived by casino surveillance employees as unusual, illegal, in violation of Chapter 3772. of the Revised Code or the rules adopted thereunder, or recorded at the request of commission agents must be retained for a minimum of ninety days.
(D) Upon request by any law enforcement agent or commission agent, the casino operator shall retain recordings for a period identified by such law enforcement agent or commission agent.
(E) Each casino operator shall include a retention schedule in its surveillance plan and comply with a procedure for the storage, index and identification of all recordings it is required to retain.
(F) A casino operator shall provide all images and recordings to the commission or its agent upon request. All other law enforcement agencies may obtain images or recordings from a casino operator only upon issuance of a subpoena.
(G) Transfers of photos and recordings from the casino surveillance room shall be tracked, either through electronic or other means, in a manner as approved by the commission.
Cite as Ohio Admin. Code 3772-19-08
(A) The casino operator shall keep surveillance logs that are continuously maintained by casino surveillance employees. Surveillance logs shall note each shift change of surveillance employees and present activities chronologically. Surveillance logs must contain (at minimum) the date and time of each entry, the identity of the employee making the entry, a summary of the activity recorded, a detail of the result of any surveillance monitoring, and a detail of any copies made of recordings of the activity.
(B) Surveillance logs shall include entries for the following events and notifications received by surveillance employees about the following events, when they are known by the surveillance department:
(1) The identity of surveillance employees on duty;
(2) Any maintenance or repair of any gaming device or money handling equipment;
(3) Live table drop box exchanges;
(4) Electronic gaming device and redemption kiosk canister exchanges;
(5) Movements or transfers of cash, cash equivalents, chips, cards or dice, at a threshold approved by the executive director and under procedures documented in the casino operator's internal controls;
(6) Any detention or questioning of patrons or employees by the security department, including the identity of the patrons or employees and the security department personnel involved;
(7) The beginning, end and any interruptions of the count;
(8) Any observed procedural or control errors or criminal activity;
(9) Any pertinent telephone calls or radio transmissions;
(10) Any malfunctions or repair of surveillance equipment;
(11) Any emergencies;
(12) Any surveillance conducted on anyone or any activity that appears unusual, irregular, illegal, or to violate Chapter 3772. of the Revised Code, the rules promulgated thereunder, and the casino operator licensee's internal controls and surveillance plan.
(13) Any surveillance specifically conducted at the request of a casino operator, casino operator employee, commission agent or other law enforcement agent; and
(14) Any other notations deemed necessary by surveillance employees or the commission or its agent to ensure compliance with Chapter 3772. of the Revised Code, the rules promulgated thereunder, and the casino operator's internal controls and surveillance plan.
(C) The casino operator shall maintain incident reports that detail any incident observed that involves unusual or criminal activity. Incident reports must be made by the person responsible for monitoring the activity.
(D) The casino operator shall maintain a visitor's log that records access to the casino surveillance room by persons other than casino surveillance employees and commission agents. The visitor's log must identify the visitor, identify the department or agency the visitor represents, state the reason for access to the room and provide the date and time of arrival and departure from the room.
(E) Surveillance logs, incident reports and visitor's logs must be retained for at least five years. Surveillance logs, incident reports and visitor's logs may be retained electronically, but must be retained in a manner that allows them to be easily retrieved by time, date, the location of activity and the type of activity. All logs must be provided to the commission or its agent immediately upon request.
(F) The casino operator's surveillance department shall not directly monitor, track, or record the activities of any commission agent or employee, unless the direct monitoring is requested by the executive director or the executive director's designee.
(G) Surveillance logs, incident reports and visitor's logs must be stored in a format which prevents alteration.
Cite as Ohio Admin. Code 3772-19-09
Five Year Review (FYR) Dates: 03/10/2017 and 05/27/2022
Promulgated Under: 119.03
Statutory Authority: 3772.03
Rule Amplifies: 3772.03 , 3772.10, 3772.111
Prior Effective Dates: 6/1/2014
If surveillance equipment that is critical to the casino operator's ability to meet any of the requirements of this chapter becomes out of service due to malfunction, it must be reported to the commission within fifteen minutes of initial discovery. If, as a result of this malfunction, the commission deems the live monitoring by surveillance department is inadequate, casino gaming in the affected area(s) shall cease until the casino operator provides adequate monitoring. Routine maintenance of surveillance equipment must be completed without compromising any of the surveillance coverage provided by the surveillance system.
Cite as Ohio Admin. Code 3772-19-10