Security Camera Policy

Policy Purpose:

The Hamilton Public Library Board strives to maintain a safe and secure environment for members and staff while protecting individual rights to privacy. The Library recognizes the use of security cameras at Library facilities as part of the Library’s overall strategy to ensure the safety of persons and property. This policy will adhere to privacy requirements set out in the Municipal Freedom of Information and Protection of Privacy Act, opens a new window. In addition, this policy has been developed to follow the guidelines set out by the Information and Privacy Commission of Ontario.  

Key Points Summary:

  • This Policy applies to all types of camera surveillance systems, surveillance monitors and camera recording devices that are used for security purposes at Library managed facilities. This policy does not address instances where library staff record a specific event (such as a program, or presentation). 
  • Security camera systems are a resource used by the Hamilton 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 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. The Library 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.  
  • The Chief Librarian will issue administrative procedures in support of this policy. 

Definitions:

Personal Information (taken from MFIPPA)- Recorded information about an identifiable individual, including, 

(a) information relating to the race, national or ethnic origin, colour, religion, age, sex, sexual orientation or marital or family status of the individual, 

(b) information relating to the education or the medical, psychiatric, psychological, criminal or employment history of the individual or information relating to financial transactions in which the individual has been involved, 

(c) any identifying number, symbol or other particular assigned to the individual, 

(d) the address, telephone number, fingerprints or blood type of the individual, 

(e) the personal opinions or views of the individual except if they relate to another individual, 

(f) correspondence sent to an institution by the individual that is implicitly or explicitly of a private or confidential nature, and replies to that correspondence that would reveal the contents of the original correspondence, 

(g) the views or opinions of another individual about the individual, and 

(h) the individual’s name if it appears with other personal information relating to the individual or where the disclosure of the name would reveal other personal information about the individual. 

IPC – Information and Privacy Commission of Ontario.  IPC oversees compliance with the privacy protection provisions of MFIPPA and conducts investigations into privacy complaints.  IPC also provides guidance regarding Ontario’s access and privacy legislation. 

MFIPPA – Municipal Freedom of Information and Protection of Privacy Act.  The purpose of the Act is to provide a right of access to information under the control of institutions and to protect the privacy of individuals with respect to personal information about themselves held by institutions. 

Policy Details:

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. The Library 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 Library 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, the Library will: 

  1. Conduct consultations with relevant stakeholders as to the necessity of the proposed security camera program at the facility. 
  2. 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: 

  1. Given the open and public nature of the Library'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, the Library's security camera coverage systems may operate at any time in a 24-hour period. 
  2. 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. 
  3. 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). 
  4. Reception/recording equipment must be located in a strictly controlled access area. Only authorized personnel shall have access to the controlled access area and the reception/recording equipment. 
  5. The annual maintenance program for reception and recording equipment will ensure that the equipment is operating properly. Library 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:

  1. The Library 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 include:
    • The legal authority for the collection of personal information. 
    • The principle purpose(s) for which the personal information is intended to be used.  
    • 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. The Security Camera Policy will be posted on the Library’s website.

Security Camera Monitors and Records 

  1. 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 and/or unauthorized staff to view them. 
  2. Only the Chief Librarian, Director of Finance & Facilities or other authorized delegates may review recorded information from the system. 
  3. Security camera footage is not actively used to monitor members’ use of Library spaces or 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. Footage may also be used to assist in identifying or resolving property-related matters. Access will be limited to cases where review of camera footage may help to identify the cause of/or help resolve a problem. 
  4. While security camera footage is not used to actively monitor employee performance, where warranted, camera footage may be reviewed and/or monitored for workplace investigation purposes such as policy violations, health and safety concerns, crime, and/or theft.  The aforementioned works in conjunction with the HPL’s Privacy Policy and Staff and Technology Use Policy which should be consulted together with the contents of this section. 
  5. 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. 
  6. The Library will take all reasonable efforts to ensure the security of records in its control/custody and ensure their safe and secure disposal.  
  7. 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 the event that authorized staff need to remove information from the system (still images, video footage) for authorized reasons, the resulting record(s) will be maintained for at least one (1) year.  
  8. 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. 

Logs

Each location must maintain a log on the Library’s Intranet 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 Librarian or designate. Requests will be reviewed based on Library 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 Librarian or designate. The Chief Librarian 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. 

The Chief Librarian, or designate, will record the following information in the facility's log: 

  1. The name of the Officer and badge number. 
  2. Investigation number and reason for the request. 
  3. The date and time of the original, recorded incident including the designated name/number of the applicable camera and DVR. 
  4. The name of the authorized personnel at the time of the incident. 
  5. The time and date the copy of the original record was sealed. 
  6. The time and date the sealed record was provided to the requesting Officer. 
  7. Whether the record will be returned or destroyed after use by the Law Enforcement Agency. 

Viewing Images

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 Policy

A staff member receiving an inquiry from the public regarding the Security Camera Policy shall direct the inquiry to the Chief Librarian's Office. 

People Counter Systems

The Library uses a People Counter System to track the number of visits to our spaces. This equipment functions separately from our Security Cameras and do not record video footage or collect any personal information as defined by MFIPPA. The counter system anonymously senses and counts when a person crosses an invisible threshold. This allows us to quantify the number of visitors we receive in a given time period. Since the information collected by this People Counter System does not contain personal information it is outside the scope of this Policy.  

Accountability - Roles & Responsibilities

Chief Librarian - The Chief Librarian is responsible for the overall Library video security surveillance program and is responsible for the Library’s privacy obligations under the Ontario Municipal Freedom of Information and Protection of Privacy Act and the Policy. Upon request, a report on the security camera program will be provided to the Board. Only the Chief Librarian and specifically designated staff will have the authority to review recorded camera coverage and authorize the release of images from the system for investigations or other purposes.

Director of Finance & Facilities - The Director of Finance & Facilities or designate is responsible for coordinating security threat assessments and advising on installations. The Director of Finance & Facilities is also responsible for ensuring installations and operations are done in accordance with this Policy. The Director of Finance & Facilities works with the Director of Digital Technology to ensure camera systems have appropriate security measures in place and the technical aspects of the system are periodically audited. The Director of Finance & Facilities ensures that authorized Facilities and Security staff are familiar with this Policy and that training is provided to all authorized personnel. The Director of Finance & Facilities oversees the day-to-day operations of security camera systems at the Central Library.

Branch Manager - The Branch Manager of a facility having security cameras is responsible for the day-to-day operation of the system in accordance with the Policy. The Branch Manager’s responsibilities include ensuring proper signage is in place, monitors are only positioned in appropriate locations, and that only authorized staff have access to the system. The Branch Manager ensures that authorized staff are familiar with this Policy and have adequate training. The Branch Manager ensures problems with the system or policy violations are promptly reported. The Branch Manager refers all requests to view recorded camera coverage to the Chief Librarian or designate. 

Personnel Authorized to Operate Video Equipment

Only authorized personnel shall be permitted to operate security camera coverage systems.

Unauthorized Access and/or Disclosure (Privacy Breach) 

Any Library employee who becomes aware of an unauthorized disclosure of a video record in contravention of this Policy, and/or a potential privacy breach has a responsibility to ensure that the Chief Librarian is immediately informed of the breach. 

The following actions will be taken immediately in accordance with HPL's procedures for managing a privacy breach:

  • Upon confirmation of the existence of a privacy breach, the Chief Librarian or designate will notify the Information and Privacy Commission of Ontario (IPC). 
  • HPL staff shall work constructively with the IPC staff to mitigate the extent of the privacy breach, and to review the adequacy of privacy protection with the existing Policy. 
  • The Chief Librarian or designate in consultation with the Director of the department in which the breach of Policy occurred, shall investigate the cause of the disclosure with the goal of eliminating potential future occurrences.  
  • The departmental Director shall inform the Chief Librarian, or designate, of events that have led up to the privacy breach. 
  • The staff member shall work with the departmental Director and the Chief Librarian or designate to take all reasonable actions to recover the record and limit the record's disclosure.  
  • The Chief Librarian, where required, shall notify affected parties whose personal information was inappropriately disclosed.  
  • A breach of this Policy may result in disciplinary action up to and including dismissal. A breach of this Policy by service providers (contractors) to the Library, may result in termination of their contract. 

Publish Date

November 2022

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