Video Surveillance Policy

1. OBJECTIVE AND PURPOSE

Vanier College is a gathering place where students, employees, visitors and workers move freely, as members of a dynamic College community.

In order to protect the people, buildings and equipment that are part of the College, various security tools including a video surveillance system with recording are in place.

As per the Act respecting Access to documents held by public bodies and the Protection of personal information, images collected by video surveillance are defined as personal information which, as such, must be treated confidentially.

The primary objective of this Policy is to define the requirements and responsibilities relating to the management and use of video surveillance devices at Vanier College. More specifically, the Policy seeks to:

Outline the compliant use of Closed-Circuit Television (CCTV) in alignment with federal and provincial laws;
Clearly define the objectives of video surveillance;
Ensure the safety of students, staff, and visitors;
Prevent reprehensible acts, theft, vandalism, and other misdeeds; and
Ensure the confidentiality of recorded information, allowing access only to authorized individuals.

Legal and Administrative Framework

Civil Code of Quebec c. CCQ-1991;
Labour Code, C-27;
Charter of human rights and freedoms (L.R.Q, chapter C-12);
Act respecting Access to documents held by public bodies and the Protection of personal information, L.R.Q.; c. A-2.1;
Act to establish a legal framework for information technology, C-1.1;
Act respecting occupational health and safety, S-2.1;
Tobacco control Act, L.R.Q.; L-6.2; and
Act to prevent and fight sexual violence in higher education institutions (L.R.Q., P-22.1).
Regulation respecting the distribution of information and the protection of personal information (RLRQ, A-2.1, r.2)

2. DEFINITIONS

Archived videos: Images recorded by video surveillance cameras stored on computer media for the short, medium or long term.

College: Vanier College of general and vocational education.

College community: All students, staff members, visitors, partners, users of Vanier College services and subcontractors attending the College on a regular or occasional basis.

Covert surveillance: A covert camera is designed to be discreet, hidden from normal view.

Personal information: Information relating to a natural person and allowing them to be identified. The information captured is confidential, that personal information cannot be communicated without the consent of the person concerned. Source : Commission d’accès à l’information (site Web).

Video surveillance: Refers to a variety of video surveillance technologies. More specifically, video surveillance refers to a system in which one or more video cameras are connected in a closed circuit or loop, with the images produced being sent to a central television monitor or recorded. As used in this document, the term video surveillance applies to video monitoring and recording.

3. SCOPE

This Policy applies to the College community in any Vanier College buildings or on Vanier College property.

Video monitoring for the following purposes is not subject to the provisions set out in this policy when it is being used:

as part of the teaching or research responsibilities of a member of the academic staff of the College;
for video conferencing; and
for parking operations to assist customers at gates and pay stations.

4. GUIDING PRINCPLES

The following fundamental principles guide the College’s actions in terms of video surveillance:

The College must ensure a living, studying, and working environment that is healthy and safe;
Members of the College community have the right to privacy and to the protection of their personal information at the College as everywhere else;
Video surveillance may not be used to monitor the actions or behavior of members of the College community, unless such actions or behavior constitute a threat to the integrity or safety of persons or property, or non-compliance with regulations and College policies; and
The College recognizes the deterrent effect of video surveillance on crime, harassment, intimidation or violence, and the reinforcement of the community’s sense of security.

5. APPLICATION

5.1. Use of Video Surveillance

5.1.1. Vanier Safety and Security Services administers the College’s central security system, which includes the security camera network. Therefore, it is the only department authorized to implement, oversee, and coordinate the use of video recording for safety and security purposes. The procurement and installation of video cameras and monitoring equipment is strictly controlled, and all installations must be approved by Safety and Security Services in accordance with established protocols.

5.1.2. Safety and Security Services utilize video surveillance to enhance personal safety, deter and investigate crime, and protect College property. The use of video surveillance complies with all existing federal and provincial laws and is conducted in a manner consistent with the values of the College so as to minimize the intrusion on the privacy of faculty, staff, students, and visitors in their personal and professional activities. Video surveillance may be used for legitimate safety and security purposes only, which include but are not limited to the following:

Monitoring building perimeters, entrances and exits, lobbies and corridors, receiving docks, special storage areas, and laboratories;
Monitoring streets, sidewalks, parking lots, courtyards, and intersections on or providing access to College property;
Monitoring restricted access transactions at entrances to buildings and other areas;
Monitoring locations protected by intrusion alarms, exit door controls, security tabs, panic, and hold-up alarms;
Monitoring ATM machines and other areas where funds are exchanged such as a business office, campus store, and other cashier locations;
Monitoring public areas where video surveillance in place of a security patrol;
Reviewing recorded images as part of a criminal or security breach investigation; and
Conducting surveillance in areas prone to on-going criminal activity.

5.1.3. Video surveillance shall not be utilized to monitor employee or student performance except where employee or student conduct constitutes criminal or illegal behavior, negligent behavior where it places others at risk or behavior that is a breach of College policies or bylaws.

5.1.4. Cameras might be used in areas where there is an expectation of privacy only after a privacy impact assessment (See section 8) is conducted and the need for surveillance by video is established.

5.1.5. Hidden or covert cameras will not to be installed unless there is a demonstrated need to assist authorities in collecting evidence in a criminal investigation. Such installations will be authorized only by the Director, Physical Plant and Facilities on recommendation from the senior staff responsible for Safety and Security Services and with the approval of the Director responsible for the protection of personal information.

5.1.6. Safety and Security Services shall ensure that members of the College community are aware of the presence and purpose of video surveillance systems through appropriate signage visible in areas where cameras are located and information on the department’s website.

5.2. Access to footage and recordings

5.2.1. Video surveillance monitoring by Safety and Security Services will be conducted in a professional, ethical, and legal manner, and in accordance with all College policies. Personnel involved in video monitoring shall be appropriately trained and continuously supervised in the responsible use of this technology.

5.2.2. Personnel who monitor cameras must receive a copy of this policy and resulting procedures developed under it and provide written acknowledgment that they have read and understood their contents.

5.2.3. Where appropriate and in exceptional circumstances, Safety and Security Services may award live viewing rights to specific members of the community where it serves to enhance the safety and security of the local area.

These individuals will be subject to the same standards of training and conduct as Safety and Security Services personnel. Violations of the established procedures for video monitoring referenced in this document will result in having their viewing rights revoked.

Whenever viewing rights are granted, an agreement is created and signed between Safety and Security Services and the requesting department. This agreement will include who has access rights, schedule of access as well as other restrictions or requirements for maintaining the access.

The privilege of live viewing rights shall be subject to periodic review to ensure compliance with training and conduct requirements and to assess the continued relevance and efficacy of this provision.

A Privacy Impact Assessment (PIA) shall be conducted prior to awarding any new live viewing rights, especially in areas with an increased expectation of privacy. The PIA shall be submitted to the committee on Access to Information and the Protection of Personal Information for review.

Live viewing rights can be revoked at any time by Safety and Security Services or the Director responsible for the protection of personal information based on recommendations from the committee on Access to Information and the Protection of Personal Information.

5.3. Use and distribution of recorded videos

5.3.1. Safety and Security Services are responsible for ensuring that access to recorded images is severely restricted and the secure storage of data recordings is consistent with College policies and procedures concerning data protection and records management. Recorded images are kept for a limited period in accordance with the College’s retention schedule, policies, procedures and all applicable laws.

5.3.2. The use of recorded images to conduct investigations of possible misconduct or illegal activity is limited to Safety and Security Services personnel.

5.3.3. Information Technology Services are permitted to view recorded images only for the purposes of repair and maintenance once access is granted by Safety & Security Services.

5.3.4. Safety and Security Services may provide information, including any surveillance camera recordings to a person or body responsible by law for the prevention, detection or suppression of crime or statutory offences, if the information is necessary to prosecute an offence against an Act applicable in Québec.

5.3.5. Members of the Vanier Community may request that images be reviewed by Safety and Security Services. These requests will be approved on a case-by-case basis. Situations where such approval may be provided include, but are not limited to:

Student Services Director or delegated Code of Conduct Officer in case of an ongoing investigation into a code of conduct or criminal violation;
Human Resources Services in case of employee discipline or arbitration hearings;
Health, Safety & Sustainability as part of an investigation of an incident and risk assessment;
Corporate Affairs to obtain information related to complaints, claims or lawsuits; and
Employees or students wishing to use video as exculpatory evidence in legal or campus judicial proceedings.

5.3.6. Nothing in article 5.3.5 can be interpreted as contravening the Access act, which stipulates that a person is entitled to access documents concerning their personal information, including access to recordings made of themselves. Nonetheless, the Access Act does specify restrictions on the right of access, and any denial of access shall be in accordance with those specifications.

5.3.7. Any request for access from an individual or an agency for purposes not specifically addressed in this policy will require a search warrant or subpoena.

5.3.8. Requests to view or receive recorded images must be submitted in writing. Authorization to release recorded video footage or to permit viewing thereof is restricted to the following personnel:

The Coordinator for Safety and Security Services; and the designated delegate of the coordinator in their absence.

5.3.9. All individuals who are granted access to recorded images must have read and signed the “Vanier College Access to the video surveillance agreement” stating they agree to respect and abide by the Video surveillance policy. The agreement will need to be signed on an annual basis.

6. VIEWING REGISTRY

6.1. Each viewing of live or recorded images, by any person, shall be documented in a viewing registry that is held and maintained by the Director responsible for the protection of private information/Vanier College Safety and Security Services. This registry shall log the date, time and duration of the viewing, the information that was viewed, the purpose of the viewing, the name and the occupation of the people that viewed said content.

7. STORAGE AND DESTRUCTION OF RECORDED IMAGES AND ARCHIVED VIDEOS

7.1. All images recorded by means of video surveillance shall be archived for thirty (30) calendar days from their recorded date. If no request is made to view the recorded images or archived videos within this timeframe, any and all recorded images shall be destroyed using the appropriate means for data destruction by the College. No recorded images or archived videos shall be kept for a period longer than thirty (30) days unless required by law.

8. PRIVACY IMPACT ASSESSMENT (PIA)

8.1. Purpose

8.1.1. The Privacy Impact Assessment (PIA) for Security Surveillance acknowledges the sensitive nature of certain areas where individuals might expect privacy. The PIA process is used for spaces and situations where individuals reasonably anticipate a higher degree of personal privacy. These are areas where one would expect a greater level of privacy or freedom from observation, as compared to public or commonly accessed areas. Examples may include but are not limited to:

Restrooms;
Changing rooms;
Individual offices;
Employee break rooms; and
Areas designated for religious practices.

Given the evolving nature of surveillance technology and growing concerns over privacy, the College is committed to ensuring our systems respect individuals’ rights and do not lead to unnecessary invasions of privacy.

This assessment also examines how data captured in privacy-sensitive areas are managed, stored, accessed, and shared, guaranteeing a strict adherence to privacy norms at every step.

8.2. Approval process

8.2.1. The Safety and Security Services Department is responsible for initiating and completing the PIA. This PIA will be submitted for review to the College’s Committee on Access to Information and the Protection of Personal Information in accordance with applicable procedures.

8.3. Enhanced data protection

The sanctity and protection of surveillance data are paramount. The PIA enforces the following protocols to ensure the judicious use of surveillance footage:

Restrictions on live viewing: Live surveillance footage viewing is prohibited during regular security operations. This measure ensures that surveillance tools are not used for unwarranted monitoring or observation. Instead, live viewing is exclusively reserved for investigative scenarios.

Controlled access to footage: Any access to recorded footage necessitates specific permission. If a crime or incident is reported and there is a need to review the surveillance data, the Coordinator of Security Services holds the exclusive authority to grant viewing rights. This is done on a case-by-case basis, ensuring that only relevant footage is accessed for legitimate investigative purposes, thus minimizing potential misuse.

8.4. Review

Every PIA is reviewed for two years following its approval to ensure that the video surveillance continues to be the best way to fulfill its original purpose.

A review may also be triggered due to, but not limited to: legislative modifications, significant system modifications, technological advancements, identification of new risks, modifications to the targeted risk or feedback from audits.

9. ROLES AND RESPONSIBILITIES

9.1. Board of Directors

Shall approve this policy.

9.2. Director responsible for the protection of personal information

Shall have final authority to authorize Privacy Impact Assessments.

9.3. Vanier College Safety and Security Services

Shall be responsible for the application and administration of this policy; and
Shall develop procedures that will govern the approval, installation, operation and management of video monitoring equipment, and for the proper training of Vanier College staff and security personnel in the handling of such equipment. The procedures shall be consistent with the provisions of this policy.

10. HISTORY

The policy was adopted by the Board of Directors on 21 January 2025 and is effective as of this date. This policy supersedes and replaces all previous policies related to camera surveillance. Any and all prior policies, guidelines, or provisions pertaining to this subject are hereby null and void upon the effective date of this policy.