HomeMy WebLinkAboutPR 615 FAC - Video Surveillance
-1- PR.615.FAC
PROCEDURE PR.615.FAC
TITLE: VIDEO SURVEILLANCE
Date Issued: June 2007
Last Revised:
Authorization: Senior Staff: 26 June 2007
1.0 OBJECTIVE
To outline a process for the use of video surveillance equipment on Board property including
the use and retention of recorded information. The procedure will identify each of the steps to
be followed as well as clearly defining the role of staff members and the rights of the students,
parents, and guardians.
2.0 DEFINITIONS
In this procedure,
2.1 Board property includes school buildings, grounds, and facilities under the jurisdiction
of the Board.
2.2 Video surveillance equipment refers to a video, physical or other mechanical,
electronic or digital surveillance system or device that enables continuous or periodic
video recording, observing, monitoring of individuals in school buildings and on school
premises.
2.3 Storage device and recorded media refers to a videotape, computer disk or drive,
CD-ROM, computer chip, or other device used to store the recorded data or visual,
audio, or other images captured by a video surveillance system.
2.4 Reception equipment refers to the equipment or device used to receive or record the
personal information collected through a video surveillance system, including a camera
or video monitor or any other video, audio, physical or other mechanical, electronic or
digital device.
2.5 Personal information is defined as being 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.
2.6 Covert surveillance is defined as the secret, continuous, or periodic observations of
persons, vehicles, places, or objects to obtain information concerning the activities of
individuals, which is then recorded in material form, including notes and photographs.
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3.0 RESPONSIBILITY
Executive Superintendent, Superintendent of Facilities, Superintendent of Human Resources ,
Superintendent of Instruction, Principal, Manager of Facilities, Manager of Safe Schools and
Community Agency Liaison, Manager of Communications and Information Services, Manager
of Planning and Transportation, Security Coordinator, Freedom of Information and Privacy
Coordinator
4.0 PROCEDURES
4.1 Authorization to use Surveillance Equipment
a) The principal or designate is responsible for the proper implementation and
control of the video surveillance equipment in a school and shall establish written
procedures to address the use of equipment.
b) Video surveillance equipment will only be adopted where circumstances have
shown that it is necessary for the purposes of enhancing safety or for the
deterrence of destructive acts, such as vandalism. Before implementing a video
surveillance program, a school or facility should be able to demonstrate:
(i) a history of incidents (e.g intrusion, personal safety issues) occurring in
the specific school/facility;
(ii) the effect of the physical circumstances of the school/facility – does it
permit ready access to unauthorized individuals; and
(iii) whether a video security surveillance program would be effective in
dealing with or preventing future incidents of the type that have already
occurred.
c) The principal will conduct an assessment, including input from students, staff,
and the school council, into the effects that the surveillance system will have on
personal privacy in the school and the ways in which such adverse affects may
be mitigated.
d) A report will be provided by the principal to the Superintendent of Instruction
describing the circumstances that indicate the necessity of having surveillance at
that site, including a review of less invasive alternatives.
e) Video surveillance equipment locations will be authorized by the Superintendent
of Instruction, upon the recommendations of the principal and Security
Coordinator. Any change in camera location must be authorized in the same
manner. Video surveillance equipment shall not monitor the inside of areas
where students, staff, and the public have a higher expectation of privacy (e.g.,
change rooms and washrooms). Video surveillance will only be used in other
areas where the public has a higher expectation of privacy such as meeting
rooms or offices, with the approval of the Director of Education or designate.
f) Public notification signs (Attachment 1), clearly written and prominently
displayed, notifying individuals of the recording and school office contact
information for any questions, must be in place in areas that are subject to video
surveillance.
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g) Remote access will only be used by the Security Coordinator to assist and
support investigation of serious incidents.
h) The Manager of Planning and Transportation will be responsible to ensure that
service providers are aware of and comply with this procedure when video
surveillance is required on school vehicles.
4.2 Installation of Video Surveillance Equipment
a) Video surveillance equipment will be installed only by a designated employee or
service provider of the Board.
b) Video monitors will not be located in an area that allows for public viewing.
c) Video surveillance equipment will be installed in a way that it only monitors areas
that have been identified as requiring video surveillance. Cameras will not be
directed to look through the windows of adjacent buildings, or onto adjacent
property. Cameras will be operated continuously.
d) If the video surveillance equipment is adjustable by the operators, this practice
will be restricted so that the operators will not be able to adjust or manipulate the
equipment to overlook areas not intended to be covered.
e) Maintenance of the cameras and the video surveillance equipment is the
responsibility of the designated principal with support from Facilities.
f) The annual preventive maintenance program for recorders and cameras will
include image refocusing and lens cleaning while ensuring that the equipment is
operating properly and in accordance with the manufacturer’s specifications. Any
issues or concerns regarding the performance of such equipment will be followed
up promptly by Facilities staff.
g) The installation of video surveillance equipment by third parties (such as food
services contractors or tenants on Board property) must follow this procedure.
h) The installation of fake or dummy cameras is prohibited.
i) Any agreements between the Board and the service providers will state that the
records dealt with or created while delivering video surveillance will be subject to
the Board’s policies, procedures and to the Acts.
4.3 Viewing of the Storage Device
a) Storage Device Release Forms will be completed for all instances of access to,
and use of the storage device, to provide for proper audit trail. (Attachment 2)
b) The storage device will be viewed only by the school principal or designate, the
Security Coordinator, the Police Services, by parents, and students (subject to
(e) below), or other staff with a direct involvement with the recorded contents of
the specific storage device, or employees of service providers responsible for the
technical operations of the system (for technical purposes only).
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c) Search and reviewing capabilities on digital systems must be protected by
password access.
d) The student shall be allowed to view at his/her request, any of the student’s
personal information which has been recorded and retained by the Board subject
only to exemptions under the Act.
e) Student or parent or guardian viewing must be done in the presence of the
principal or designate.
f) Viewing may be refused or limited where viewing would be an unreasonable
invasion of a third party's personal privacy, would give rise to a concern for a
third party's safety, or on any other grounds recognized in the Municipal Freedom
of Information and Protection of Privacy Act.
4.4 Handling of the Storage Device and Recorded Media
a) The storage device and recorded media will be stored in a secure room in a
controlled access area.
b) Each storage device will be dated and labeled with a sequential number. A log
will be kept of all instances of access to, and use of recorded material to enable a
proper audit trail.
c) The storage device and recorded media may never be sold, publicly viewed or
distributed in any other fashion except as provided for by Policy (P.047.FAC) and
appropriate legislation.
d) The storage device and recorded media will be erased within one month unless
they are being retained at the request of the Board, employee, parent, or student
for documentation related to a specific incident, or are being transferred to the
Board's insurers or the Police Services. Digital systems shall be configured so
that they archive for a maximum of one month.
e) The storage device retained under 4.4 (d) will be erased as soon as the incident
in question has been resolved.
f) Where recorded information has been used for a law enforcement, school or
public safety purpose, the retention period shall be one year after it has last been
used, and/or all appeals relating to a particular incident have been exhausted.
g) Old storage devices will be disposed of in such a way (i.e. shredding, burning or
magnetically erasing) that the personal information cannot be reconstructed or
retrieved. The disposal of the record shall be noted in the log.
4.5 Governance
a) The principal or designate is responsible for the proper implementation and
control of the video surveillance equipment.
b) The Security Coordinator shall conduct a review at least annually to ensure that
these procedures are being adhered to. Any deficiencies and required
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maintenance will be reported to the principal responsible for the video
surveillance equipment.
c) The Security Coordinator in consultation with the principal will conduct a review
regarding the removal or relocation of the video surveillance equipment every
three years.
4.6 Misuse and Consequences of Misuse
a) Video monitoring must be carried out in accordance with these procedures.
b) The improper use of video surveillance will not be tolerated and will result in
appropriate administrative or disciplinary action in any cases of wrongful use.
c) In the event of a breach of privacy the school principal will:
(i) Identify the scope of the potential breach and take steps to contain it.
(ii) Identify those individuals whose privacy was breached and, barring
exceptional circumstances, notify these individuals accordingly.
(iii) Notify the Superintendent of Instruction, the Security Coordinator and the
Freedom of Information and Privacy Coordinator of the privacy breach.
4.7 Covert Surveillance
a) Prior to the use of covert surveillance a case must be presented by the Security
Coordinator and the responsible principal/manager to the Superintendent of
Human Resources or Executive Superintendent, for approval on the grounds
covert surveillance is essential to the success of a possible criminal investigation
and the need outweighs the privacy of the persons likely to be observed .
b) The case and supporting documentation must identify the benefits which will be
derived from the investigation.
c) The covert surveillance must be time limited and case specific.
5.0 APPENDICES
Attachment 1: Notice of Signs Re Security Camera Surveillance
Attachment 2: Access to Video Surveillance Storage Device and Recorded Media
6.0 REFERENCE DOCUMENTS
The Education Act, 2000, 315(1)
Municipal Freedom of Information and Protection of Privacy Act, 1989
Guidelines for Using Video Surveillance Cameras in Schools, 2003
Guidelines for Government Organizations: What to do if a privacy breach occurs, 2006
Board Policy P.047.FAC: Video Surveillance
Board Policy P.101.FAC: Building Security and Safety
Board Policy P.106.SCO: Access to School/Board Premises
Board Policy P.032.SCO: Safe Schools
Board Policy P.068.TRA: Student Transportation
Board Policy P.060.FIN: Vandalism, Theft, Damage or Loss to Board Property
Board Procedure PR.521.SCO: Safe Schools
Board Procedure PR.522.FIN: Vandalism, Theft, Damage or Loss to Board Property
Board Procedure PR.524.SCO: Access to School/Board Premises
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Board Procedure PR.533.SCO: Police Involvement in Schools
Board Procedure PR.556.TRA: Student Transportation
British Columbia District Trustees Association
-7- Attachment 1 of PR.615.FAC
NOTICE OF SIGNS RE SECURITY CAMERA SURVEILLANCE
Notice Posted Outside Main Front Entrance:
NOTICE
Security cameras are in operation for the safety of students, staff, and others and to
protect Ottawa-Carleton District School Board property.
Information is collected by the Ottawa-Carleton District School Board under the authority of the
Municipal Freedom of Information and Protection of Privacy Act. For information, c ontact the
school office or the Manager of Communications and Information Services, (613) 721-1820,
133 Greenbank Road, Ottawa, Ont. K2H 6L3
Notice Posted Outside all other Main Entrances:
WARNING
Persons on these premises are subject to video recording.
OCDSB Form 615.001 -8- Attachment 2 of PR.615.FAC
ACCESS TO VIDEO SURVEILLANCE
STORAGE DEVICE AND RECORDED MEDIA
Name of School:
Date:
Name of Person under which the Data
Storage Device was Released:
Name of Person Who Took the Data Storage
Device or Accessed the Data:
Reason for Access in Accordance with Board Policy and Procedure and the Information and
Privacy Commissioner/Ontario Guidelines for Using Video Surveillance Cameras in Schools:
NOTE: THE DATA STORAGE DEVICE MUST BE EITHER RETURNED OR DESTROYED
Date Returned:
Date Destroyed:
________________________________
Principal