CLERK-014 - Video Surveillance Policy_2019
VIDEO SURVEILLANCE POLICY
Title: Video Surveillance Policy
Subject: Video Surveillance Category: Policy
Policy No.: COS-CC-014 M&C Report No.: N/A
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Effective Date: August 27, 2012 Next Review Date: (3 years)
Area(s) this policy applies to: All City Service Areas Office Responsible for review of this Policy:
The Office of the Common Clerk
Related Instruments: Policy Sponsors: Common Clerk
Revision History: Document Pages: This document consists of 7
-revised April 2, 2019 pages.
Common Clerk's Annotation for Official Record
I certify that the Video Surveillance Policy was approved by Common Council
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on August 27, 2012
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____ ____April 2, 2019_______
Common Clerk Date
Contact: Common Clerk
Telephone: 658-2862
Email: commonclerk@saintjohn.ca
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VIDEO SURVEILLANCE POLICY
TABLE OF CONTENTS
1. PURPOSE ............................................................................................................................................. 3
2. POLICY STATEMENT ............................................................................................................................. 3
3. SCOPE .................................................................................................................................................. 3
4. POLICY CONTEXT ................................................................................................................................. 3
5. LEGISLATION AND STANDARDS ............................................................................................................ 4
6. ROLES AND RESPONSIBILITIES .............................................................................................................. 5
7. COMPLIANCE ....................................................................................................................................... 6
8. MONITOR AND REVIEW ....................................................................................................................... 6
9. IMPLEMENTATION ............................................................................................................................... 6
10. AUTHORIZATION................................................................................................................................ 6
11. GLOSSARY .......................................................................................................................................... 6
12. INQUIRIES .......................................................................................................................................... 7
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VIDEO SURVEILLANCE POLICY
1. PURPOSE
The purpose of the Video Surveillance Policy (the “Policy”) for The City of Saint John (the “City”) is to
ensure the proper conduct of video surveillance within spaces under City management, following public
sector best practices and compliance with applicable legislation including the Right to Information and
Protection of Personal Information Act (RTIPPA).
2. POLICY STATEMENT
Video surveillance, when utilized with other security measures, is an effective means of ensuring the
security and safety of City facilities, the individuals who use them, and the assets housed within them.
However, the need to ensure security and safety must be balanced with an individual’s right to privacy.
Detailed requirements and responsibilities regarding the collection, notification, use, security and
retention of personal information can be located in related procedures.
3. SCOPE
This policy applies to all City facilities and to all employees, elected officials, patrons, visitors and tenants
of City facilities.
4. POLICY CONTEXT
The privacy principles applying to video surveillance include:
Accountability
The City is responsible for personal information under its control and has assigned ultimate
accountability for compliance to the Common Clerk by designating the Common Clerk “Head” for the
purposes of RTIPPA.
Identifying Purposes
The public will be informed of the purpose for the collection of personal information by surveillance
equipment.
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Notification
The public will be notified of the presence of video surveillance equipment. Signage as required under
RTIPPA will be posted in plain language.
Limiting Collection
Information collected will be limited to that which is necessary for the stated purpose. If possible,
collection will be restricted to the time in which suspect activities are most likely to occur.
Limiting Use, Disclosure and Retention
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While related to the consent principle of the Canadian Standards Association’s Model Code for the Protection of Personal
Information, this notification principle is from the Canadian Institute of Chartered Accountants’ Generally Accepted Privacy
Principles. This is a legislated requirement under RTIPPA.
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VIDEO SURVEILLANCE POLICY
Personal information will not be used or disclosed for purposes other than those for which the City
collected it, except with the consent of the individual or as required by the law. Personal information
will be retained only as long as necessary for the fulfilment of those purposes or as required by law.
Personal information will be securely disposed of in accordance with approved records retention
schedules, information disposal practices and all applicable information security policies and
procedures.
Accuracy
Accurate, complete and time stamped records and information will be maintained.
Safeguards
Security of City equipment and recorded information will be assured and only authorized employees will
be provided access to a tightly controlled video surveillance system. A combination of physical,
technological and organizational controls will be employed.
Openness
Information about the Policy and related procedures will be available to the public.
Individual Access
Individuals whose images are recorded will be able to request access to their recorded personal
information. All access requests will be directed to the Office of the Common Clerk.
Challenging Compliance
Video surveillance shall be conducted in accordance with all applicable laws and individuals will be able
to challenge compliance.
5. LEGISLATION AND STANDARDS
The City acknowledges the following laws that relate to records and information management:
Charter of The City of Saint John, 1785 (U.K.) Geo. III as amended
Archives Act, S.N.B. 1977, c.A-11.1 as amended
Community Planning Act, R.S.N.B. 2017, c. 19as amended
Electronic Transactions Act, S.N.B. 2011, c.145 as amended
Evidence Act, R.S.N.B. 1973, c.E-11 as amended
Local Governance Act.S.N.B. 2017, c. 18 as amended
Official Languages Act, S.N.B. 2002, c.O.0.5 as amended
Personal Information Protection and Electronic Documents Act, R.S.C. 2000, c.5 as amended
Public Records Act, S.N.B. 2011, c.212 as amended
Right to Information and Protection of Privacy Act, S.N.B, 2009, c.R-10.6 as amended.
The City acknowledges the following standards, guidelines and best practices that relate to video
surveillance:
CAN/CSA-Q830 Model Code for the Protection of Personal Information
CAN/CSA-PLUS-8300 Workbook on Applying the CSA Model Code
CAN/CSA-PLUS-8830 Implementing Privacy Codes of Practice
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VIDEO SURVEILLANCE POLICY
MC10-2 - Information and Privacy Commissioner of Ontario - Privacy Complaint Report
Information and Privacy Commissioner of Ontario - Guidelines for the Use of Video Surveillance
Cameras in Public Places
Office for the Information and Privacy Commissioner of British Columbia - Public Surveillance
System Guidelines
Office of the Privacy Commissioner of Canada - Guidelines for the Use of Video Surveillance of
Public Places by Police and Law Enforcement Authorities.
6. ROLES AND RESPONSIBILITIES
The Common Clerk is accountable for the Policy. Ultimate accountability for holding employees
responsible for complying with City policy rests with the City Manager.
The Common Clerk is responsible for overseeing the design, implementation, and maintenance of the
Policy; monitoring and compliance; conducting privacy impact assessments of existing or proposed
video surveillance systems; processing inquiries; investigating privacy complaints; and authorizing
employees who are permitted to operate the surveillance system.
The Common Clerk and Chief Information Officer are jointly responsible for identifying the personal
information holdings within the City’s electronic information repositories.
The Common Clerk is responsible for ensuring that personal information in any format is retained for a
reasonable period of time and for authorizing the secure disposition of personal information according
to the Right to Information and Protection of Privacy Act and the City’s Information Security Policy and
procedures.
The Chief Information Officer is responsible for securely maintaining the City’s electronic information
repositories, according to the City’s Information Security Policy and procedures, such that the integrity
and authenticity of the City’s information is assured.
Service Area Managers are responsible for determining the requirement for a video surveillance system
and are responsible for ensuring employees comply with the Policy, procedures and applicable
legislation. Program Area Commissioners provide management support and leadership.
City employees are responsible for following this Policy. Video surveillance systems, including any
components or records, may not be used without prior authorization. A City employee receiving an
inquiry from the public regarding the Video Surveillance Policy will direct the inquiry to the Office of the
Common Clerk.
7. COMPLIANCE
Violations or non-compliance with the Policy, regardless of size or scope, may carry potentially
significant consequences for the City. Violations may constitute theft, fraud, destruction or alterations
of corporate information; privacy breach; unauthorized disclosure of information assets; and/or loss of
intellectual property. Violations of the Policy may cause employee disciplinary action, up to and
including dismissal.
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VIDEO SURVEILLANCE POLICY
8. MONITOR AND REVIEW
The Policy is subject to review within two years from approval date. The review will be conducted by a
committee established by the Office of the Common Clerk. The committee may be comprised of a cross-
functional internal membership or an independent third party.
9. IMPLEMENTATION
The Policy will be implemented upon approval by Common Council.
10. AUTHORIZATION
This Policy has been approved by Common Council on August 27, 2012.
11. GLOSSARY
Employee
An employee is an individual or corporation hired by the City to perform work under either a contract
for services or a contract of service.
Information
Data presented in readily comprehensible form to which meaning has been attributed within the
context of its use. Unless the context otherwise requires, this means information contained in a record.
Information Security
The protection of information and information systems from a wide range of risks including
unauthorized access, use, disclosure, disruption, modification or destruction in order to provide
authenticity, integrity, confidentiality and availability.
Personal Information
Recorded information about an identifiable individual, including but not limited to, (a) the individual’s
name, (b) the individual’s home address or electronic mail address or home telephone or facsimile
number, (c) information about the individual’s age, gender, sexual orientation, marital status or family
status, (d) information about the individual’s ancestry, race, colour, nationality or national or ethnic
origin, (e) information about the individual’s religion or creed or religious belief, association or activity,
(f) personal health information about the individual, (g) the individual’s blood type, fingerprints or other
hereditary characteristics, (h) information about the individual’s political belief, association or activity,
(i) information about the individual’s education, employment or occupation or educational,
employment or occupational history, (j) information about the individual’s source of income or
financial circumstances, activities or history, (k) information about the individual’s criminal history,
including regulatory offences, (l) the individual’s own personal views or opinions, except if they are
about another person, (m) the views or opinions expressed about the individual by another person, and
(n) an identifying number, symbol or other particular assigned to the individual.
Privacy Breach
An unauthorized access to, or collection, use or disclosure of personal information.
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Privacy Impact Assessment
A policy process for identifying, assessing and mitigating privacy risks.
Record
Recorded information, regardless of medium or characteristics, made or received by an organization
that is evidence of its operations, and has value requiring its retention for a specific period of time.
Records Retention and Disposition Schedule
A schedule which gives the City the authority to dispose of (transfer or destroy) records it no longer
requires. This schedule identifies the period of time that personal information in the custody of the City
is to be retained.
Video Surveillance System
Any system or device that enables continuous or periodic recording, observing or monitoring of facilities
and/or individuals.
12. INQUIRIES
For more information on the Policy, please contact the Office of the Common Clerk.
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