Procedures Related to Policy 10.3 Responsible Use of Video Surveillance Systems

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This online version is for convenience; the official version of this policy is housed in the University Secretariat. In case of discrepancy between the online version and the official version held by the Secretariat, the official version shall prevail.

Approving Authority: Vice President: Finance and Administration

Original Approval Date: June 24, 2015

Date of Most Recent Review/Revision: N/A

Office of Accountability: AVP: Campus Administration and Special Constable Service

Administrative Responsibility: Manager, Special Constable Service

Purpose

1.00 These procedures set out the guidelines for the operation of closed-circuit television (“CCTV”) cameras and related Surveillance Technologies located on the University campuses.

2.00 The purpose of these procedures is to provide specific procedural regulations regarding the use of all Surveillance Technologies located on University property, ensure that the use of Surveillance Technologies is in accordance with University policy, and to meet legislative obligations.

3.00 CCTVs serve a dual function for law enforcement personnel by assisting in both the deterrence and investigation of crimes. CCTV cameras are one tool to support safety and security and aid in investigations.

Definitions

4.00 In addition to the Definitions in the Policy, the following terms are used throughout this Procedure:

i. DVR: Digital Video Recorder; a computer that collects the signal from cameras, compresses and stores the data; can record for long periods and permits the ability to review footage immediately while continuing to record.

ii. Investigative Purposes: include: undertaking examinations, inquiries and observations pertaining a range of matters, including responding to complaints, disciplinary hearings and police investigations.

iii. SCS Manager: the Special Constable Service senior functional leader at each campus; depending on the size of the campus, this may be an Associate Director, Manager or Supervisor.

iv. SCS Head: all supervisors and managers of Wilfrid Laurier University’s Special Constable Service.

v. SCS Staff: any person employed by the Wilfrid Laurier University Special Constable Service.

vi. Privacy Breach: an incident in which Personal Information is collected, retained, used or disclosed in ways that are not in accordance with the provisions of the Acts.

Jurisdiction/Scope

5.00 These procedures apply to all use of Surveillance Technology by Special Constable Service (SCS) and the Information and Communication Technology (ICT) staff at all campuses of Wilfrid Laurier University. These procedures do not apply to other technologies, including digital learning technologies, employee surveillance, covert surveillance, and Surveillance Technologies controlled by other third-parties.

Procedures

6.00 Installation

i. Any surveillance device must only be installed for the purposes of meeting public safety objectives as set out in the Policy.

ii. Any agreements between the University and service providers must state that the records accessed or created while delivering a video surveillance system are under the control of the University and subject to all applicable legislation and University policies, including the Policy.

iii. Requests from the campus community to install Surveillance Technologies may be made to the SCS by the budget manager for the department.

iv. All surveillance technology installations must be approved by the SCS Manager.

a. The SCS Manager reserves the right to approve or deny any request for Surveillance Technologies. This decision is contingent upon many factors, including but not limited to:

i. Supporting the objectives and guidelines in the Policy;

ii. The basis of verifiable, specific reports of incidents of crime, significant safety concerns or potential concern for thefts;

iii. Suitability of location;

iv. Identified benefit and necessity of such installation in meeting public safety objectives;

v. Results of consultations with relevant stakeholders;

vi. Fiscal restraints.

v. All surveillance technologies must be installed in accordance with the Policy.

6.01 Signage

i. Signage must be prominently displayed at the perimeter of video surveillance areas to provide reasonable and adequate warning that surveillance is in operation before entering any area under surveillance.

ii. Signage must include information regarding the legal authority for the collection of Personal Information and the principal purpose(s) for which Personal Information is intended to be used.

iii. Signage must include the title, business address and telephone number of the SCS for the appropriate campus.

6.02 Monitoring

i. Viewing and monitoring of images or live camera feeds will be completed in accordance with the Policy. No remote monitoring of live surveillance is permitted outside of Special Constable Service and Police Service requirements, such as, but not limited to Emergency Response scenarios.

ii. Outside of any “blackout” periods, including downtime resulting from equipment upgrades, IT service, or technical malfunctions, video surveillance will be actively recording at all times.

iii. Due to a large number of cameras, real-time (live) video monitoring by SCS personnel will only be conducted on an as needed basis to support an incident, during scheduled hours of operation of the SCS and as part of daily operations.

a. While real-time monitoring will occur, this neither implies nor guarantees that monitors will be viewed on a continuous basis.

iv. All camera monitoring locations must be approved by the SCS Manager at the respective Campus location.

v. All personnel responsible for monitoring cameras must abide by the terms of confidentiality, professionalism, and ethics outlined in their employment contracts, university policies and this Procedure.

6.03 Image Review and Access

i. SCS Staff is fully responsible for the collection, use, retention, and disclosure of images collected via Surveillance Technologies.

ii. SCS Staff serve as “gatekeepers” to surveillance footage and verbal or written authorization must be provided to any third parties reviewing.

iii. Except as may be otherwise permitted, only SCS Staff may access surveillance image storage devices (e.g., DVRs) or review surveillance footage.

iv. Footage review should only be commenced for Investigative Purposes and permitted only in accordance with the Policy.

v. All instances of the creation of copies of recorded material will be logged to preserve an audit trail.

6.04 Image Retention

i. Recorded footage that has not been reviewed or required for the purposes of the investigation will be automatically erased after approximately 4-6 weeks. This retention period will vary depending on the maximum data storage capability of surveillance equipment. Copies of any recordings made by SCS Staff, will only be made for Investigative Purposes, and treated as confidential.

ii. Copies will be confidentially retained on password protected or encrypted external data storage devices (e.g., external hard drive, CD-ROM, PC hard drive, USB).

iii. Copies of footage made for Investigative Purposes will be retained for at least one (1) year.

a. This time period may be extended in the event of an ongoing investigation or any related court proceedings.

6.05 Disclosure of Images

i. All requests for surveillance footage must be made in writing to the appropriate SCS service by completing the Request for Video Surveillance Footage form.

ii. Images obtained through Surveillance Technologies are classified as confidential and shall not be shared outside of SCS personnel, with the following exceptions:

a. For law enforcement purposes, including security agencies, police services or legal advisors for Investigative Purposes (e.g., identification of an individual in relation to a criminal incident);

b. University employees or contractors who need to view the images in the performance of their professional duties;

c. Eligible disciplinary committee members, including (but not limited to) Student Code of Conduct committees, during the course of an investigation into allegations of an offence;

d. Members of an ad hoc committee formed by a department head to address particular public safety concerns, including threat assessment committees;

e. Compliance with an access request under FIPPA.

Responsibilities

7.00 The SCS maintains control of and responsibility for Surveillance Technologies at all times and will:

i. Meet obligations under applicable legislation and university policies and this Procedure;

ii. Monitor camera feeds and maintain monitoring stations in locked, controlled-access areas;

iii. Secure all recordings in locked, controlled-access areas;

iv. Place visible and appropriate signage at locations monitored by CCTV cameras;

v. With ICT staff, (and, if necessary, externally contracted technology providers and other University staff), conduct an Accordance Audit of the SOP annually;

vi. Transmit data between cameras, monitoring stations, data storage devices, and all relevant law enforcement agencies for Investigative Purposes;

vii. Maintain surveillance equipment so that it is functioning properly;

viii. Report any equipment malfunctions or concerns to ICT staff;

ix. Monitor and review surveillance footage in a professional and ethical manner;

x. Report any breach of the Policy, provisions of Acts or other relevant statutes to their Supervisor and/or Manager.

7.01 ICT staff will perform technical assistance and support for University Surveillance Technologies and will:

i. Assist in the installation of approved Surveillance Technologies;

ii. Provide ongoing technical assistance;

iii. Contribute to an Accordance Audit of campus Surveillance Technologies annually;

iv. Secure recordings in locked, controlled-access areas;

v. Assist in performing other technical duties as mutually agreed upon with the SCS.

7.02 SCS Heads will:

i. Ensure that all personnel monitoring Surveillance Technologies have signed a Confidentiality Agreement prior to accessing any surveillance footage or monitoring Surveillance Technologies;

ii. Verify that all SCS personnel are familiar with proper and responsible use of all surveillance equipment;

iii. Oversee the department’s compliance with all applicable legislation and university policies and this procedures;

iv. Engage in a fiscal assessment prior to guaranteeing or implementing any new surveillance technology.

Relevant Legislation

• Freedom of Information and Privacy Protection Act, RSO 1990, c. F.31

Related Policies, Procedures and Documents

• SCS Procedure 2-06: Armed Person
• Request for Surveillance Footage form