610: Video Surveillance Systems
Responsible Administrator: Associate Superintendent, Corporate Services
PURPOSE
Sturgeon Public Schools believes that in order for Division property and individuals on Division property to be safe and secure, the use of video surveillance systems (“cameras”) is necessary.
PROCEDURE
1. Privacy Assessment
1.1 A Privacy Impact Assessment (PIA) shall be completed to assess the effects that proposed surveillance may have on privacy in the following circumstances:
1.1.1 Intention to install a new surveillance system where one did not exist previously.
1.1.2 Before new camera positions are proposed for addition to a pre-existing surveillance system.
1.1.3 Before changes to rules regarding how surveillance video files are stored, retained and destroyed.
2. Camera Location
2.1 Subject to the provisions below, surveillance cameras may be placed both in and outside the Division building.
2.2 All cameras must not be concealed and should be clearly visible.
2.3 Cameras shall not be placed in change rooms, washrooms and areas where students, staff and others have a reasonable expectation of privacy.
2.4 Cameras located internally shall not be directed to look through windows to areas outside the building, unless necessary to protect external assets, provide for the personal safety of individuals on Division premises, or to deter criminal activity from occurring.
2.5 Cameras shall in no event be directed to look at or in adjacent buildings that are not the property of the Division.
3. Notification
3.1 Signs advising the presence of an operational video surveillance system along with a contact name and phone number should be prominently displayed on divisional property that is under surveillance.
3.2 Students and parents shall be informed in writing by the school administration at the beginning of each school year and as necessary during the school year that the school will be monitoring certain activities, and as the purpose of such monitoring practices. The design and operation of the system creates no greater privacy intrusion than is absolutely necessary to achieve its purpose.
3.3 All staff and contractors shall be advised of this policy.
4. Use of Record Information
4.1 The Superintendent or designate may use recorded information for purposes as outlined in this administrative practice and for purposes expressly stated by or under the Freedom of Information and Protection of Privacy.
5. Access to Recorded Information
5.1 The Superintendent, or designate, will identify employees who shall have access to the electronic surveillance system while it is in operation.
5.2 Members of the RCMP shall be granted access to the electronic surveillance system in the course of an active police investigation.
5.3 The Superintendent or designate must authorize access to all recorded information by external parties outside of the Division.
5.4 Recorded information must be viewed in such a manner as to avoid public viewing.
5.5 A log shall be maintained by a school Principal of all episodes of access to or use of recorded information on school property.
5.6 A log shall be maintained by the Director of Facilities of all episodes of access to or use of recorded information that occurs on Central Service property.
6. Disclosure of Recorded Information
6.1 Recorded information may be disclosed to applications in accordance with the provisions contained in the Freedom of Information and Protection of Privacy Act in such other cases as required by law.
6.2 A school Principal shall ensure that a Recorded Information Release form is completed before disclosing recorded information from school property to appropriate authorities or third party. Any such disclosure shall only be made in accordance with applicable legislation.
6.3 The Director of Facilities shall ensure that a Recorded Information Release form is completed before disclosing recorded information to appropriate authorities or third party. Any such disclosure shall only be made in accordance with applicable legislation.
6.4 A Recorded Information Release form shall indicate the individual or organization who took the recorded information, the date of occurrence or when and if the recorded information will be returned or destroyed by the authority or individual after use.
7. Audit
7.1 The school Principal or the Director of Technology Services and Logistics shall be responsible to periodically audit the use and security of surveillance equipment including cameras, monitors, storage devices and recorded information.
8. Retention and Disposal of Collected Information
8.1 All recorded information not in use shall be securely stored in a locked receptacle or area.
8.2 Recorded information may never be sold, publicly viewed or distributed in any other fashion except as provided for by this administrative procedure.
8.3 All recorded information used for the purpose of this administrative procedure shall be numbered and dated and retained according to the camera site.
8.4 All recorded information used to make a decision that directly affects an individual shall be retained for a minimum of one year and all other material for a period of 6 months, except in cases where recorded information is required for evidentiary purposes the recorded information should be retained and stored according to standard procedures until law enforcement authorities request them.
8.5 All recorded information shall be disposed of in a secure manner.
9. Miscellaneous
9.1 These guidelines do not apply to covert or overt surveillance cameras being used by or on behalf of a public body as a case specific investigation tool for law enforcement purposes where there is statutory authority and/or the authority of a search warrant to conduct the surveillance
10. Prerogative of the Executive
10.1 Nothing in this administrative procedure shall in any way be construed to limit the Division outside the provisions of this administrative procedure and associated policy.
History
2020 Jan 29 Initial Approval
2020 Apr 22 Amended
Administrative Procedures VI. Facilities