Scope
This procedure forms part of JIBC’s Video Surveillance Policy (the “Policy”) and should be followed and applied in relation to the use of video surveillance under the Policy. Terms not otherwise defined in this procedure are as defined in the Policy.
Procedural Guiding Principles
For the safety and security of all persons and property on its campuses, JIBC utilizes video surveillance systems at select locations. The purpose of the procedure is to define the parameters for use of video surveillance by means of closed circuit television (CCTV) camera systems at Justice Institute of British Columbia campuses.
Privacy Impact Assessment
The Director, Campus Planning & Facilities Operations (“Director, CPFO”) will conduct or, as applicable, update a Privacy Impact Assessment (“PIA”) in relation to the installation of existing and new CCTV cameras. The Director, CPFO is responsible for submitting completed PIAs to the Vice-President, Finance and Operations for review and approval. The PIA shall include consideration of the following issues in compliance with the requirements of the Freedom of Information and Protection of Privacy Act (British Columbia) (“FIPPA”):
- Is the camera surveillance and recording necessary to meet a specific and legitimate business need or interest of the Institute, i.e. personal safety, protection of property?
- Is it likely that camera surveillance and recording will be effective in meeting the legitimate need or interest?
- Is the employees’ loss of privacy proportional to the benefit gained by the Institute’s use of surveillance equipment?
Signage
JIBC will prominently display clearly written public notification signs in areas that are subject to video surveillance. Signage will indicate the Institute’s legal authority for using surveillance, the purpose for the surveillance and contact information for making inquiries about the use of surveillance.
Locations
The Director, CPFO is responsible for approving the location of existing and new CCTV cameras.
Video surveillance will not be used in locations where private activities or functions are routinely carried out (e.g. changing rooms or washrooms).
Security
CCTV cameras will be installed by a designated employee or agent of the Institute.
Note: Designated employees and agents of the Institute are personnel assigned and authorized by the Director, CPFO.
Only Institute designated employees or agents shall handle cameras or recordings. All designated employees shall have privacy training and at all times be familiar with the relevant sections of FIPPA standards. All agents will have agreed to handle recordings in accordance with the relevant B.C. Provincial privacy legislation.
Only the designated Institute employee shall have access to the computer or media on which video surveillance records are stored. The computer and/or recording media shall be password protected, encrypted and stored in a secure area away from public viewing to which only the designated Institute employee has access.
Recordings may never be sold, publicly viewed or distributed in any other fashion except as provided for in this Policy and applicable legislation.
Real-Time Monitoring
Real-time monitoring is permitted to identify problems that require immediate intervention and for the safety of people on the premises during regular hours or after hours and weekends to monitor community use of campuses.
Real-time monitoring is permitted for other purposes such as monitoring weather conditions for grounds maintenance purposes (e.g. ice and snow removal).
Viewing Recordings
Monitors used to display video recording will not be located in a place or position that enables public viewing.
Access to recordings by staff will be limited to those with a legitimate need to exercise access in order to carry out their duties or responsibilities to the Institute.
Staff members may request access to recordings containing their own image in accordance with the access to information provisions of FIPPA, however the Institute may, at its discretion, limit access to viewing in order to protect the privacy of other individuals appearing in the recordings.
The Institute reserves the right to disclose or provide access to recordings to law enforcement officials or to make other disclosures required or authorized by FIPPA and other applicable laws.
Retention of Recordings
The system will be configured to loop at least monthly. Previous video recordings will automatically be securely erased prior to reuse.
JIBC may retain video recordings for a longer period (e.g. if a video recording becomes subject of an investigation).
In all cases, JIBC will securely retain and dispose of recordings in accordance with B.C.’s Administrative Records Classification System (ARCS), JIBC’s Operational Records Classification System (ORCS), and applicable law.
Review
The Director, CPFO is responsible for the proper implementation and control of the CCTV system. JIBC’s Facilities Division shall install, maintain, and repair these systems to an Institute standard.