Video Surveillance Policy

Policy number: CS-1102-2016
Policy Title: Video Surveillance Policy
Policy Owner: Vice President, Corporate Services
Effective Date: February 26, 2016
Last Revised: September 18, 2019

1. Purpose

The College is committed to maintaining a safe and secure environment for all members of our community. This requires striking a balance between our responsibility to promote a safe and secure environment and also protect individual privacy. Video Surveillance Cameras are used as a means of detecting and assisting in the investigation of criminal activity and breaches of relevant College Policies and behavioural codes of conduct while promoting the safety of individuals and the security of assets and property. The College’s installation, monitoring and recording of Video Surveillance Cameras is in accordance with this Policy, the Freedom of Information and Protection of Privacy Act (FIPPA), FIPPA Regulation 460 and other applicable Federal and Provincial legislation and related College policies.

2. Application and Scope

This policy applies to all video surveillance, camera monitoring and camera recordings on all College owned, rented or leased property, including parking lots, excluding the IAHS campus.

3. Definitions

“Camera” is a device that converts images into electronic signals for television transmission, video recordings or digital storage.

“Covert” means concealed or hidden.

“Overt” means open and observable, not hidden, concealed or secret.

“Video Monitoring Location” refers to live camera viewing locations.

“Video Surveillance System” is a digital system capable of capturing images and videos that can be compressed, stored or sent over communication networks as specified in the Purpose of this policy.

“Video Surveillance Operative” are personnel who have been designated by the Director Security Services to view Video Surveillance systems. This approval will be reviewed annually.

4. Principles

The College conducts video surveillance under the authority of the Ontario Colleges of Applied Arts and Technology Act as necessary for safety and security purposes.

The College is committed to the protection of images captured using a video surveillance system through confidentiality, integrity and restricting availability of these images.

Mohawk Security Services shall be the sole entity of the College that is responsible for the implementation and use of Video Surveillance for the College.

5. Accountability and Compliance

5.1 Accountability Framework

This policy has been approved by the Senior Leadership Team.

5.2 Compliance

The Vice President, Corporate Services will ensure that the information within this Policy is applied and that all actions comply with applicable legislation.

6. Rules

6.1 Installation

The College implements surveillance as necessary for safety and security purposes and in a manner that considers the relevant risks, the ability of surveillance to address the risks and the impact of surveillance on personal privacy.

All Video Surveillance cameras and locations are to be approved by the Director, Security Services prior to installation.

The College will make every reasonable effort to position cameras so that they only monitor the College environment or occupied spaces. Cameras should not be directed to look through the windows of adjacent non-College buildings or onto adjacent property. Cameras will not record audio and will not be installed in washrooms, change rooms and in other areas in which the expectation of privacy is high.

The College will place appropriate signage to ensure that employees, students, visitors and members of the College community are aware that Video Surveillance is in use with the exception of approved covert cameras.

6.2 Covert Cameras and Recording

The use of covert surveillance is exceptional and may only be used for safety and security purposes on the express written direction of the Chief Building and Facilities Officer, Vice President, Corporate Services or President, as appropriate.

6.3 Monitoring and Review of Surveillance Images

Authorized personnel will monitor and review surveillance images for safety and security purposes and as otherwise permitted by FIPPA.

Video monitoring shall be conducted in a professional, ethical and legal manner by Video Surveillance Operatives who are appropriately trained in the lawful and responsible use of Video Surveillance Technology and have signed a Confidentiality Agreement.

All Video Monitoring Locations are to be approved by the Director, Security Services.

The College does not guarantee that Video Surveillance systems will be monitored in real time.

6.4 Image Retention and Security

The Video Surveillance system will continually capture and record images. These images will be stored in a secure manner agreed upon and approved by Director of Security Services and Manager of IT Security to ensure the confidentiality and integrity of stored images is not compromised.

Recordings that have not been viewed for investigation or public safety purposes will automatically be overwritten after 30 calendar days.

Any surveillance images that are used by the College will be retained for a minimum of one year from the date of use.

Copies of recordings shall be controlled by Mohawk Security Services. Any copy of a recording will be tracked in a log book in Security Services, and shall only be made for investigative and/or evidence purposes.

6.5 Disclosure of Images

The College will disclose video surveillance footage as necessary for its safety and security purposes and otherwise in accordance with FIPPA. This may involve disclosing surveillance footage to law enforcement to aid in an investigation.

7. Policy Revision Date

7.1 Revision Date

September 2024

7.2 Responsibility

The Vice President, Corporate Services will review this policy every five years or earlier when required.

8. Attachments

Appendix A - Video Surveillance Procedure

9. Specific Links

Appendix A: Video Surveillance Procedure

1. Responsibilities

1.1 Director Security Services will:

Monitor and/or record all Video Surveillance Cameras and maintain a suitable monitoring station in a controlled, high-security area with access restricted to Security Services;
Ensure that the implementation and operation of all Video Surveillance systems comply with this policy;
Ensure there is appropriate signage in place at all entrances to the College advising of the use of Video Surveillance cameras and providing contact information for the person responsible for the program;
Be responsible for the management and administration of the College Security Video Surveillance systems reporting annually to the Vice President Corporate Services;
Be responsible for the disclosure of all images;
Review list of approved Video Surveillance Operatives annually; and
Audit the Security Video Surveillance Recording Log to ensure all activities relating to such access are documented, including the time add purpose of accessing such recording.

1.2 The Security Operations Supervisor will:

Conduct a documented operational audit of the Video Surveillance system annually and ensure installation is in compliance with this policy;
Will manage the copied data recordings required for investigative/evidence purposes;
Will manage the secure storage of all recorded images stored outside the College data centres.
Ensure that all Video Surveillance Operatives are appropriately trained and supervised in the responsible use of Video Surveillance equipment;
Arrange to install systems only under the direction of the Director Security Services;
Ensure that all Video Surveillance cameras are recording all monitored activity;
Provide a copy and track recordings when requested by the Director Security Services to aid in an investigation;
Take all reasonable efforts to ensure the safety of recordings under his/her control or custody and ensure their safe and secure disposal; and
Old storage devices shall be disposed of in accordance with the applicable College asset disposal processes having first ensured that all personal information is erased prior to disposal and cannot be retrieved or reconstructed.

1.3 Information Technology (IT) will:

Manage the secure storage of all recorded images stored in the College data centres.
Ensure the Video Surveillance system will be able to continually capture images of all properly installed cameras.

2. Approval of Video Monitoring Locations

The Director of Security Services will only approve Video Monitoring Locations if the following circumstances are fully met:
- Request is obtained from the respective Senior Leadership Team member;
- Request is for cameras associated with their roles and responsibilities;
- Access to images is restricted to Video Surveillance Operatives;
- Images cannot be easily accessible to the public; and
- Images are viewed on an approved device with necessary software installed by Security.
Security Services will audit the Video Monitoring location annually and ensure all above criteria is still relevant.

3. Disclosure of Images

When permitted under FIPPA, video surveillance recordings will be done in a manner that protects the privacy and security of the personal information.
When disclosing video surveillance recordings, the College will:
- Maintain an auditable log of each disclosure that includes the date, time, and location of the footage, and, where applicable, the case file number of the law enforcement agency’;
- Ensure the log includes a description of circumstances justifying the disclosure, the amount of footage involved, the name title and agency to whom the footage is being disclosed, the legal authority for the disclosure, the means used to disclose the footage and whether the footage will be returned or securely destroyed after use; and,
- Ensure that if digitized, the footage is securely encrypted.

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