Using Video Surveillance

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Adapted from guidance published by the Office of the Information and Privacy Commissioner for British Columbia

Installing surveillance equipment may seem like a logical decision for your organization, but collection and use of personal information through video surveillance may violate privacy law and could lead to other costly liabilities.

  • Identify and document the purpose that may be served by surveillance
  • Limit the time your surveillance is active, for example:
    • turning on the cameras for certain times of the day or night rather than 24 hours a day
  • Avoid unintended subjects
    • Position cameras to capture the least amount of information that is needed. For example, a store security camera should not capture images of passersby on the street.
    • Avoid areas where people have a heightened expectation of privacy, such as change rooms, washrooms, or into windows.
  • Draft and adopt an organizational policy that addresses:
    • the rationale and purpose of the surveillance
    • when and how monitoring and/or recording will be in effect
    • how recordings will be used
    • for how long they will be kept
    • how they will be securely deleted
    • process to follow if there is unauthorized access or disclosure
  • Limit access
    • identify individuals who are authorized to access the recordings.
    • Authorized individuals should only review the recorded images to investigate a significant security or safety incident, such as criminal activity.
    • Minimize the number of individuals who have access to the monitoring system or recordings, and
    • Provide ongoing privacy training so operators are clear about their obligations
    • Any disclosure of video surveillance recordings outside your organization should be limited to that authorized by the applicable privacy law, and be documented.
    • Be prepared to provide a copy of the relevant surveillance recording upon request.
    • When disclosing recordings, use masking technology to ensure that identifying information about other individuals on the recording is not disclosed.
  • Storage and destruction
    • To reduce the possibility of loss and theft, keep video recordings under your control - either on trusted premises or on a trusted cloud platform.
    • Develop and follow a secure storage protocol.
    • Prepare a retention and destruction schedule to specify the length of time that surveillance records will be kept (we recommend a maximum of 7 days).
    • Decide when and how records will be destroyed.
    • Safely and securely destroy recorded images when they are no longer required for business purposes.
    • Document the destruction in your logs.
  • Camera Accountability
    • Post a clear, understandable, and visible notice about the use of cameras on the premises before individuals enter the premises.
    • The sign should plainly indicate which areas are under video surveillance and for what purpose, for example: "This property is monitored by video surveillance for theft prevention."
    • Provide contact information of someone in your organization for individuals to contact if they have questions about the surveillance.
    • Consider making your written surveillance policy available to the public.
    • Regularly review your policy to ensure that using video surveillance is still justifiable and needed for your original purpose (we recommend a biennial review).