The Cambridge Public Library Board (operating as Idea Exchange) strives to maintain a safe and secure environment for customers and staff while protecting the individual’s right to privacy.
The Board recognizes the use of security cameras at library and gallery facilities as part of the organization’s overall strategy to ensure the safety of persons and property. This policy and accompanying procedures will adhere to privacy requirements set out in the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA). In addition, this policy has been developed to follow the guidelines set out by the Information and Privacy Commissioner of Ontario.
This Policy applies to all types of camera surveillance systems, surveillance monitors and camera recording devices that are used for security purposes at Idea Exchange managed facilities. This policy does not address instances where staff record a specific event (such as a program, or presentation).
Security camera systems are a resource used by the Cambridge Public Library Board within the Board's jurisdiction to promote the safety of visitors, staff and community members. Where deployed for that purpose, these systems also help to protect library and gallery property against theft or vandalism and can assist in the identification of intruders and of persons breaking the law.
In the event of a reported or observed incident, the review of recorded information may be used to assist in the investigation of the incident. Idea Exchange will maintain control of and responsibility for the security camera system at all times. Employees and service providers are expected to review and comply with this Policy, the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA), and other relevant statutes in performing any duties and functions that are related to the operation of the security camera program.
Collection of Personal Information Using a Security Camera Coverage System
Any recorded data of an identifiable individual qualifies as "personal information" under MFIPPA. Security cameras can be used to collect personal information about identifiable individuals. Idea Exchange has determined that it has the authority to collect this personal information in accordance with the MFIPPA. Pursuant to section 28(2) of the Ontario MFIPPA, no person shall collect personal information on behalf of the organization unless the collection is expressly authorized, used for the purposes of law enforcement or necessary to the proper administration of a lawfully authorized activity.
Planning Considerations for Security Cameras
Before deciding if a facility warrants security cameras, Idea Exchange will:
- Conduct consultations with relevant stakeholders as to the necessity of the proposed security camera program at the facility.
- Endeavour to ensure that the proposed design and operation of the video security surveillance system reasonably minimizes privacy intrusion.
Design, Installation and Operation of Security Cameras
When designing a security camera system and installing equipment, the following must be considered:
- Given the open and public nature of the organization's facilities and the need to provide for the safety and security of employees and visitors who may be present at all hours of the day, Idea Exchange's security camera coverage systems may operate at any time in a 24-hour period.
- The ability of authorized personnel to adjust cameras shall be restricted so that authorized personnel cannot adjust or manipulate cameras to overlook spaces that are not intended to be covered by the security camera coverage program.
- Equipment shall never monitor the inside of areas where the public and employees have a higher expectation of privacy (e.g. change rooms and washrooms).
- Recording equipment must be located in a strictly controlled access area. Only authorized personnel shall have access to the controlled access area and the recording equipment.
- The regular maintenance program for recording equipment will ensure that the equipment is operating properly. Staff will endeavour to promptly follow-up issues or concerns regarding the performance of equipment.
Notice of Use of Video Systems
In order to provide notice to individuals that video is in use:
- Idea Exchange shall post signs, visible to members of the public, at all entrances and/or prominently displayed on the perimeter of the grounds under security camera coverage. On at least one sign at each location with security camera coverage the following information will included:
- the legal authority for the collection of personal information;
- the principle purpose(s) for which the personal information is intended to be used;
- and the title, business address, and telephone number of someone who can answer questions about the collection.
2. Additional signs will be used to support awareness of the security camera program.
3. Information about the security camera program will be included on the organization’s website.
Security Camera Monitors and Records
- Staff at each location may be authorized to monitor real-time camera feeds as is reasonably necessary to implement this Policy. Every reasonable attempt will be made to ensure security camera monitors are not in a position that enables the public to view them.
- Only the Chief Executive Officer, Director Finance and Facilities, Director of Public Service, Cambridge Art Galleries Director, location managers or other authorized delegates may review recorded information from the system.
- Security camera footage will not be used to monitor employee performance. Circumstances, which warrant review, will be limited to security incidents that have been reported or in the investigation of a potential crime or identifying individuals associated or potentially involved with a crime.
- All storage devices will be located in a controlled-access area. Access to the storage devices will be limited to authorized personnel. Logs will be kept of all instances of access to, and use of, recorded material to enable a proper audit trail.
- The organization will take all reasonable efforts to ensure the security of records in its control/custody and ensure their safe and secure disposal.
- Security camera systems will be set-up to ensure regular recordings are cleared or overwritten on a regular basis. Normally, systems will be set-up to maintain records for up to 30 days. In some cases, system capacity may limit the time records are maintained. In cases where the surveillance system records activities that relate to an insurance, liability, law enforcement or other similar issue, the appropriate section of the recording will be copied to suitable media and stored in a separate secure location for a period of no less than one (1) year or a longer appropriate length of time.
- When records are released to law enforcement officials, where possible, authorized staff will limit the release of information about individuals deemed not to be involved in the investigation. This includes, but is not limited to, zooming images in on suspects in question, obscuring identifiable features of other individuals and limiting the time frame of video coverage provided.
Each location must maintain a log that records all activities related to security cameras and records. Activities include all information regarding the use, maintenance, and storage of records and all instances of access to, and use of, recorded material, including the name of the person accessing the system. All logbook entries will detail staff name, date, time and activity.
Access Requests Process
All requests to view security camera coverage will be recorded in the Log and will be directed to the Chief Executive Officer or designate. Requests will be reviewed based on Idea Exchange policy and relevant legislation including MFIPPA.
Law Enforcement Access Request
If access to a security camera coverage record is required for the purpose of a law enforcement investigation, the requesting Officer must complete the Disclosure of Personal Information Form and forward it to the Chief Executive Officer, or designate. The Chief Executive Officer or designate will provide the recording for the specified date and time of the incident requested by the Law Enforcement Officer, subject to MFIPPA exemptions.
When recorded images from the cameras must be viewed for law enforcement for investigative reasons, this must only be undertaken by authorized personnel, in a private, controlled area that is not accessible to other staff and/or visitors.
Inquiries from the Public Related to the Security Camera Coverage Policy
A staff member receiving an inquiry from the public regarding the Security camera coverage Policy shall direct the inquiry to the Chief Executive Officer.
Adopted: November 22, 2017 (Board Motion 17.71)
Revised: April 28, 2021 (Board Motion 21.20)