Video Surveillance

Number
Approved On
Review By

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    Purpose

    The Video Surveillance Policy establishes guidelines and procedures for operating a Video Surveillance System on any property and in any building owned or operated by the FFPL Board, as deemed necessary by the CEO.

    The Video Surveillance Policy was developed in close consultation with the document Guidelines for the Use of Video Surveillance issued by the Information and Privacy Commissioner of Ontario in October of 2015.

    The Video Surveillance Policy is based on the Innisfil Public Library - Video Surveillance Policy approved by the Innisfil Public Library Board on April 18, 2011.

    1. Safety

      1. The FFPLTC uses a Video Surveillance System to promote the safety of patrons, FFPLTC Staff and the community.
      2. The Video Surveillance System also helps to protect FFPLTC property against theft or vandalism, and can assist in identifying intruders and persons breaking the law.
      3. Both the FFPL Board and FFPLTC Staff are committed to the goal of a safe library. This policy outlines one of the processes in place to ensure that the FFPLTC is kept as safe as possible. The Video Surveillance System will compliment other measures taken by the FFPL Board to ensure a safe and secure environment.
    2. Compliance

      1. FFPLTC Staff and Service Providers must review and comply with FFPL Board policy, including the Video Surveillance Policy, the Privacy Policy, MFIPPA, and any other relevant statutes in performing any duties or functions related to Operating and Monitoring the Video Surveillance System.
      2. FFPLTC Staff who knowingly or deliberately breach FFPL Board policy or the provisions of MFIPPA or other relevant statutes may be subject to discipline.
      3. Service Providers that knowingly or deliberately breach FFPL Board policy or the provisions of MFIPPA or other relevant statutes may be found to be in breach of contract, leading to penalties up to and including contract termination.
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    Responsibilities

    1. FFPL Board

      The FFPL Board is responsible for the development and review of the Video Surveillance Policy and signage.

    2. CEO

      1. The CEO is responsible for the Video Surveillance System.
      2. The CEO is a Systems Manager, and may designate another Systems Manager.
    3. Systems Manager

      The Systems Manager:

      1. Operates the Video Surveillance System
      2. Is responsible for all technical aspects of the equipment, including:

        • Installation
        • Maintenance
        • Retention of Records
        • Disposal of Records
      3. Coordinates Audits of the Video Surveillance System
      4. Is an IT Staff member, and may designate FFPLTC Staff and Service Providers as IT Staff members
    4. IT Staff

      IT Staff members carry out technical activities as instructed by the Systems Manager.

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    Collection of Personal Information

    The FFPLTC has determined that it has the authority to collect Personal Information in accordance with section 28(2) of MFIPPA:

    No person shall collect personal information on behalf of the Library unless the collection is expressly authorized by statute, used for the purposes of law enforcement or necessary to the proper administration of a lawfully authorized activity. The Library must be able to demonstrate that any proposed or existing collection of personal information by a video surveillance system is authorized under this provision under the Act.

    Please refer to Section 5 of the Privacy Policy for further information.

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    Release of Personal Information

    Any patron, FFPLTC Staff member or member of the public who has been Recorded by the Video Surveillance System has a general right of access to his or her Personal Information under section 36 of MFIPPA.

    Please refer to Section 6 of the Privacy Policy for further information.

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    Operation of the Video Surveillance System

    1. Transparency

      1. The FFPLTC will endeavour to be as open as possible about the Video Surveillance System in operation.

        This may be achieved via the production of a pamphlet, or documentation distributed through the FFPLTC web site.

      2. Upon request, the FFPLTC will make the following information available to the public:

        • The rationale for the Video Surveillance System
        • The objectives of the Video Surveillance System
        • The Video Surveillance Policy
        • The Privacy Policy
    2. Security

      1. The FFPLTC will maintain control of and responsibility for the Video Surveillance System at all times.
      2. The Video Surveillance System should operate in a strictly controlled area.
      3. Only personnel authorized in writing by the CEO or Systems Manager should have access to this area, the Video Surveillance System and Reception Equipment.
      4. Video monitors should not be in a position that enables public viewing.
    3. Installation of Reception Equipment

      Reception Equipment should be installed only in:

      • Identified public areas where video surveillance is a necessary and viable detection or deterrence activity
      • Spaces that have been identified as requiring video surveillance
    4. Operation of Reception Equipment

      1. Reception Equipment will operate up to 24 hours a day, and seven days a week, within the limitations of system capabilities, power disruptions, serviceability and maintenance.
      2. If Reception Equipment is adjustable by users Monitoring the Video Surveillance System, this adjustment should be restricted, if possible, so that Reception Equipment cannot be manipulated to monitor areas that are not intended to be monitored by the Video Surveillance System.
      3. Reception Equipment should never monitor the inside of areas where patrons, FFPTLC Staff and the public have a higher expectation of privacy. This includes, but is not limited to:

        • Change Rooms
        • Washrooms
        • Windows of adjacent buildings
    5. Maintenance

      1. The Video Surveillance System and Reception Equipment will receive regularly scheduled maintenance, including:

        • Optimizing Record quality
        • Lens cleaning
        • Verification of proper operation
        • Verification of adherence to manufacturer’s specifications
      2. FFPLTC Staff will endeavour to promptly follow-up on issues or concerns regarding the performance of the equipment.
    6. Signage

      As a minimum, there should be a sign in place that notifies individuals of the recording, and informs them that they may contact the CEO with any questions.

      Signage will:

      • Be clearly written
      • Be prominently displayed at entrances, exterior walls, and the interior of buildings where Reception Equipment is installed
      • Provide patrons, FFPLTC Staff and the public reasonable and adequate warning that a Video Surveillance System is in operation
      • Satisfy notification requirements under section 29(2) of MFIPPA, which include:

        • Informing individuals of the legal authority for the collection of Personal Information
        • The principal purpose for which the Personal Information is intended to be used
        • The title, business address and telephone number of someone who can answer questions about the collection

      The remainder of the notification requirements under MFIPPA can be satisfied through information pamphlets available at the FFPLTC, and through the FFPLTC web site.

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    Using Video Surveillance System Records

    1. Acceptable Use

      1. Video Surveillance System Records may only be used for the purposes set out in the Video Surveillance Policy, and must either:

        • Relate to the protection of patrons, FFPLTC Staff and the public
        • Assist in the detection and deterrence of criminal activity and vandalism, including the discipline or consequences that arise from those activities
      2. The Video Surveillance System should not be used for monitoring FFPLTC Staff performance.
      3. Records should not be retained or used for any purposes other than those described in the Video Surveillance Policy.
    2. Review

      1. Only a Systems Manager may review Video Surveillance System Records.
      2. Circumstances, which would warrant review, will normally be limited to an incident that has been reported or observed, or to investigate a potential crime.
      3. Real-time viewing of monitors may be delegated by a Systems Manager to a limited number of FFPLTC Staff.
    3. Retention

      1. Storage of used Video Surveillance System Records will comply with Section 5-6-1 of the Privacy Policy.
      2. The retention period for Video Surveillance System Records that have not been viewed for law enforcement, FFPLTC or public safety purposes shall be:

        • A minimum of 5 days
        • A maximum of 28 calendar days

        These time-frames are based on risk assessment, privacy considerations, and equipment capabilities.

      3. Video Surveillance System Records that have not been used in this fashion and within these time-frames are routinely erased in a manner in which the Records cannot be reconstructed or retrieved.
    4. Logs

      Logs should be kept of all instances of access to, and use of, Video Surveillance System Records to enable a proper audit trail.

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    Training

    Where applicable and appropriate, the Video Surveillance Policy will be incorporated into training and orientation programs for FFPLTC Staff.

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    Auditing

    1. The FFPLTC will ensure that the use and security of the Video Surveillance System and Reception Equipment is subject to regular Audits.
    2. Audits will address the FFPLTC’s operational compliance with the Video Surveillance Policy.
    3. An external body may be retained in order to perform Audits.
    4. The FFPLTC will endeavour to address all deficiencies and concerns identified by Audits as soon as possible.
    5. FFPLTC Staff and Service Providers should be aware that their activities are subject to Audit, and that they may be called upon to justify their use of any Video Surveillance System Records.
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    Evaluation

    1. The FFPL Board will regularly review and evaluate its Video Surveillance System to ascertain whether it is still justified in accordance with the planning requirements set out in the Video Surveillance Policy.
    2. Evaluation shall occur at least once every 3 years.
    3. Evaluation will include a review of the Video Surveillance Policy.
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Terms

  • Chief Executive Officer

  • Fort Frances Public Library Board

  • Fort Frances Public Library Technology Centre

  • The Ontario Municipal Freedom of Information and Protection of Privacy Act

  • Users who Monitor the Video Surveillance System may perform visual inspections. These users have read-only access, and may not extract or modify Records.

  • Users who Operate the Video Surveillance System may modify settings, and alter the deployment of hardware and software. These users have full access, and may extract and modify Records.

  • Defined in section 2 of MFIPPA as:

    Recorded information about an identifiable individual, which includes, but is not limited to, information relating to an individual's race, colour, national or ethnic origin, sex and age. Therefore, a simple image on a video surveillance system that is clear enough to identify a person, or the activities in which he or she is engaged in, will be classified as "personal information" under the Act.

  • Any equipment or device used to receive or record Personal Information collected through a Video Surveillance System, including:

    A camera, video monitor or any other video, audio, physical or other mechanical, electronic or digital device.

  • Defined in section 2 of MFIPPA as:

    Any information, however recorded, whether in printed form, on film, by electronic means or otherwise, and includes: a photograph, a film, a microfilm, a microfiche, a videotape, a machine-readable record, and any record that is capable of being produced from a machine-readable record.

  • A tape, optical disc, computer disk, drive or chip, or any other device used to store Records of Personal Information.

  • A video, physical or other mechanical, electronic or digital surveillance system or device that enables continuous or periodic video recording, observing or monitoring of individuals in open, public spaces.

    The Information and Privacy Commissioner of Ontario includes in the term Video Surveillance System:

    An audio device, thermal imaging technology, or any other component associated with recording the image of an individual.