Video Surveillance Policy

St. Francis Xavier University

Video Surveillance Policy

1.0 Preamble

• 1.1 Closed circuit television (CCTV) surveillance systems are employed by the University to record breaches of the Community Code and other University policies, and other unlawful conduct, as well as to prevent such occurrences by deterrence.
• 1.2 The use of CCTV surveillance results in the collection of personal information, in the form of images and records of the conduct and communications of identifiable individuals.
• 1.3 Use of CCTV surveillance shall be in accordance with this policy, the Nova Scotia Freedom of Information and Protection of Privacy (FOIPOP) Act, applicable Federal legislation, and related University policies.

2.0 Purposes

• 2.1 The University collects personal information by CCTV surveillance systems for the purposes of recording breaches of the Community Code and other University policies, and other unlawful conduct.
• 2.2 These purposes are designed to serve the following goals:
  • 1) to improve personal safety on the University campus;
  • 2) to assist in the preservation of University property and the property of others located on campus;
  • 3) to deter breaches of the Community Code and other University policies, and any other unlawful act;
  • 4) to assist campus security and law enforcement agencies with regard to the investigation of any breach of the CommunityCode or other University policies, or any other unlawful act that may occur on campus.

3.0 Authority

• 3.1 The Vice-President Recruitment and Student Experience shall be responsible for authorizing the use of video surveillance from time to time. The authorization shall indicate the location and field of view of any CCTV surveillance system, whether and when the system may be monitored and/or recorded, and where signals and data from the system will be monitored and/or recorded. Day-to-day authority for the continuing use, maintenance and record-keeping of authorized CCTV surveillance systems may be delegated to a Dean, Chair, Director or manager of the applicable department or facility.

4.0 Public Notice

• 4.1 Signs or other forms of notice will be posted so as to provide reasonable notice to persons entering an area subject to CCTV surveillance, either at the entrance to the area under surveillance (e.g., at the entryway to a computer laboratory), and may be posted at such other location as to provide equal or better notice.
• 4.2 If data from the CCTV surveillance system will be or may be recorded, the following sign will be displayed: This area is being recorded by closed circuit television.
• 4.3 If the signal from the CCTV surveillance system will not be recorded, the following sign will be displayed: This area is being monitored by closed circuit television.
• 4.4 Each sign will include the following additional notice: Further information may be obtained from the office of the Vice-President Recruitment and Student Experience.

5.0 Limiting Access, Retention, Use, and Disclosure of Personal Information

• 5.1 At no time will persons other than those authorized by the Dean, Chair, Director or manager having authority for a CCTV surveillance system have access to the system or data monitored or recorded by it.
• 5.2 The University will take reasonable security precautions to prevent unauthorized access to, use or disclosure of data monitored or recorded by CCTV surveillance systems.
• 5.3 Data from a CCTV surveillance system shall only be recorded if and when the system is not being continuously monitored. Data from a monitored CCTV surveillance system may be recorded in the event of a suspected breach of the Community Code or other University policy, or other unlawful act.
• 5.4 A permanent log shall be kept in relation to each CCTV surveillance system which will be or may be recorded, which log shall record the details of any access to, use or disclosure of data recorded from the CCTV surveillance system.
• 5.5 Data recorded from a CCTV surveillance system will only be accessed in order to periodically verify the integrity or normal operation of a CCTV surveillance system, or otherwise in accordance with this policy.
• 5.6 Personal information monitored or recorded pursuant to this Policy shall not be used or disclosed for purposes other than those for which it was collected, or a purpose compatible with those purposes, except with the consent of the individual or as required by law.
• 5.7 Data recorded from CCTV surveillance systems will be kept for a maximum of two weeks unless otherwise required for the purposes outlined in this policy. Data stored on tape, hard drives or other data storage media shall be overwritten or otherwise made permanently unreadable on or before the fifteenth day after the recording was made
• 5.8 If data recorded from a CCTV surveillance system has been used to make a decision about an individual, the data must be retained for a minimum of one year after the decision.
• 5.9 A person who has been the subject of CCTV surveillance has the right to view any recorded information about that person, except in circumstances where access in full or part may be refused in accordance with the Nova Scotia FOIPOP Act. A request must identify the date, time and location of the recording. The log for the relevant CCTV surveillance system(s) shall record any access pursuant to this section.
• 5.10 A person who believes there is an error or omission in the personal information about him or her recorded by a CCTV surveillance system may request that the information be corrected. In the event that the information is not corrected, the log shall record the particulars of the requested correction.

6.0 Incidents

• 6.1 Data recorded from a CCTV surveillance system may be accessed, used and/or disclosed, in accordance with this policy, when there are reasonable grounds to suspect that a breach of the Community Code or other University policy, or some other unlawful act (“an incident”) has occurred.
• 6.2 In the event there are reasonable grounds to suspect that an incident has occurred, a person authorized by the Vice-President Recruitment and Student Experience may obtain and preserve any relevant CCTV surveillance system recording. The recording may be copied, but the recording and any copies shall be secured against unauthorized access, use or disclosure.
• 6.3 The log for the relevant CCTV surveillance system(s) shall record any access, use, disclosure or copy pursuant to this section.

7.0 Accountability and Compliance

• 7.1 The Vice-President Recruitment and Student Experience may at any time direct that an audit of the operation, integrity and security of any CCTV surveillance system(s) be conducted. Such audit may include access to and use of data recorded by the CCTV surveillance system(s), but personal information contained in such recordings shall not be disclosed unless otherwise in accordance with this policy.
• 7.2 Persons authorized to operate and/or monitor a CCTV surveillance system, as well as persons authorized to access and use recorded data pursuant to this policy shall be provided with a copy of this policy, and shall indicate in writing that they have read, understand and agree to be bound by its terms.
• 7.3 A copy of this policy shall be made available to any person through the office of the Vice-President Recruitment and Student Experience.
• 7.4 Any suspected infraction of this policy may be reported to the University FOIPOP Officer. The University FOIPOP Officer may request that the Vice-President Recruitment and Student Experience direct an audit of the relevant CCTV surveillance system(s) pursuant to the above section 7.1