205 CMR 141.05
Requirements of the Surveillance System Plan
A surveillance plan must, at a minimum, incorporate the following:
(1) A training and qualifications program that shows surveillance operations personnel are
properly trained or certified to recognize abnormalities and violations in procedures, including
documentation of on-going training;
(2) An adequate emergency power system at all times sufficient to prevent required monitoring
from being unreasonably delayed, and a contingency plan to be utilized whenever a power failure
occurs that can be used to operate the CCTV system in the event of a power failure. Such power
system shall be tested in the presence of the Commission at 12-month intervals subject to more
frequent retesting upon failure of a test;
(3) A preventive maintenance program, implemented by technicians assigned to the surveillance
department or, if assigned to another department, subject to the direction and control of the
director of surveillance, which ensures that the entire CCTV system is maintained in proper
working order and that transparent covers over CCTV system cameras are cleaned in accordance
with a routine maintenance schedule. In the event that preventive maintenance to be performed
by a technician assigned to another department is required on an emergency basis, the
surveillance department shall have priority with respect to personnel resources of such other
department to ensure the efficacy of the CCTV system;
(4) Connection to all gaming establishment alarm systems enabling instant notification of any
such alarm and monitoring of any area to which the alarm applies and which provides a visible,
audible or combination signal; provided, however, that any robbery or other emergency-type
alarm shall be perceptually distinguishable from all non-emergency alarm types in a manner
approved by the Commission (for example, robbery alarm is the only audible alarm);
(5) An updated photo library, consisting of photographs that are no more than four years old,
of all current employees of the gaming establishment, which photo library shall be available to
the Commission upon request;
(6) Provision for an updated operational blueprint depicting all areas of the gaming
establishment, and elsewhere where CCTV coverage is available, that is readily accessible to all
monitoring room personnel and representatives of the Commission. In a PDF or other such
common electronic format.
(7) A surveillance log securely maintained that includes detailed reports of all surveillances
conducted. The log shall be maintained by monitoring room personnel and shall be stored
securely, in a manner approved by the Commission, within the surveillance department. The
surveillance log shall be available for inspection at any time by the Commission. At a minimum,
the following information shall be recorded in a surveillance log:
(a) Date and time each surveillance commenced;
(b) The name and license credential number of each person who initiates, performs or
supervises the surveillance;
(c) Reason for surveillance, including the name, if known, alias or description of each
individual being monitored, and a brief description of the activity in which the person being
monitored is engaging;
(d) The times at which each video or audio recording is commenced and terminated;
(e) The time at which each suspected criminal offense is observed, along with a notation
of the reading on the meter, counter or device that identifies the point on the video recording
at which such offense was recorded;
(f) Time of termination of surveillance; and
(g) Summary of results of the surveillance.
(8) Signals from all cameras required, in accordance with 205 CMR 141.04, shall be recorded
and retained for a minimum of 30 days unless notified by the Commission or the division within
that period that any such recordings must be retained for any longer period so designated by the
Commission or the division and shall be made available for review upon request by the
Commission. In addition, any such recordings which are determined by the Commission to be
of potential evidentiary value shall be retained and stored pursuant to Commission directives.
Upon written request by a gaming licensee, the Commission may allow a gaming licensee to
retain surveillance recordings of certain areas of the gaming establishment for less than 30 days;
141.05: continued
(9) Continuous lighting of all areas, including gaming tables, offices, cages, equipment storage
rooms, card and dice destruction rooms and pits, where CCTV system camera coverage is
required by 205 CMR 141.04, that is of sufficient quality to produce clear recordings and still
picture reproductions.
(10) No use of multiplexing and quad recording devices for required surveillance recordings
in accordance with 205 CMR 141.04.
(11) That surveillance room entrances are not visible from the gambling floor; and