Administrative Procedure 525: Video Surveillance

Education Act: Part XIII Behaviour, Discipline and Safety; Guideline - Ontario Schools Code of Conduct; Freedom of Information and Protection of Privacy Act; Municipal Freedom of Information and Protection of Privacy Act.

Administrative Procedure (AP) 103 Management of Personal Information - Student; AP 351 Code of Conduct; AP 352 Progressive Discipline and Promoting Positive Student Behaviour; AP 357 Violence Threat and Risk Assessment; AP 589 Transportation

1.1 It is the policy of the Avon Maitland District School Board that video surveillance equipment shall be used in public areas of its schools and facilities, or other areas as deemed necessary. Third party service provider facilities (for example, school buses) will also have video surveillance equipment when it is deemed necessary to: enhance the safety and well-being of students, staff, and the community; protect Board property and equipment against theft or vandalism; aid in identifying intruders and of persons breaking the law.

1.2 The Board recognizes that any recorded data or visual, audio, or other images of an identifiable individual falls within the definition of “personal information” under the Municipal Freedom of Information and Protection of Privacy Act (“the Act”) with respect to notice, access, use, disclosure, retention, security, and disposal of records containing personal information. The collection of personal information shall be used only for the purposes of maintaining a safe environment, protecting school property, or as required or permitted by law.

1.3 Video surveillance involves the collection, retention, use and disclosure of personal information. Under the authority of the Director of Education, designated Avon Maitland District School Board on-site personnel (principal or designate) will maintain control of and responsibility for the video surveillance system at all times.

2.1 Signs will be prominently displayed at all entrances, accessible exterior walls or fencing and/or the interior of buildings and on buses having video security surveillance systems. This signage will provide students, staff and the public reasonable and adequate warning that video surveillance is in effect. The signs will be in compliance with the notification requirements of section 29(2) of the Municipal Freedom of Information and Protection of Privacy Act, which includes informing individuals of the legal authority for the collection of personal information; the core purpose(s) for which the personal information is intended to be used, and to whom questions about this collection can be directed.

 

 

“THE USE OF VIDEO SURVEILLANCE IS IN EFFECT” The personal information is collected under the authority of the Education Act and will be used to reduce/prevent property vandalism, theft and violence and to ensure the safety of students. Questions about this collection should be directed to the principal of the school

 

“THE USE OF VIDEO SURVEILLANCE MAY BE IN EFFECT" Questions regarding this practice should be directed to the principal of the school

3. Design, Installation and Operation of Video Surveillance Equipment

In designing, installing and operating a video security surveillance system, the district and schools will consider the following:

3.1 Reception equipment will be installed only in identified public areas where video surveillance is necessary to ensure the safety of staff, students and school property. The equipment will operate up to 24 hours/7 days a week, within the limitations of system.

3.2 The equipment will monitor only those spaces that have been identified as requiring video surveillance.

3.3 Equipment will not be installed in areas where the students, staff and the public have a higher expectation of privacy (e.g. change rooms and washrooms).

3.4 Video monitors will not be in a position that enables public viewing.

3.5 Innovations in video surveillance have introduced IP based security cameras using secured cloud storage for video recordings. As existing security cameras and DVR systems reach end of life or new video surveillance technologies are required, the board will install IP based/cloud technologies.

3.6 IP-based cloud-managed security cameras require an annual license renewal. Budgeting for IP security systems will be as follows:

3.6.1 In alignment with the Facilities Department budget, Facilities will provide external security cameras and the initial licensing at secondary school sites, Facilities will provide one (1) "front of the school" security camera and an additional one (1) location in consultation with School Administration. At elementary school sites, Facilities will provide one (1) “front of the school” security camera and initial licensing in consultation with School Administration.

3.6.2 Schools are responsible for the costs accrued for all internal IP-based video cameras and the associated annual secured cloud-managed licenses.

3.6.3 Switching, installation, support, and maintenance will be provided by the Information Technology Services Department.

 

3.7 Principals should contact the Administrator of Information Technology Services for new video surveillance technologies or existing renewals. The principal must get approval from their Superintendent, the Administrator of Information Technology Services, and the Facilities Administrator before proceeding.

 

3.8 The School Principal, Information Technology Services department, or Facilities department are responsible for ensuring that all surveillance equipment is maintained and serviced regularly. Any issues or concerns regarding the performance of DVR equipment should be reported to the Facilities Department as soon as possible through the Maintenance request system. Any issues or concerns regarding the performance of IP based video equipment should be reported to the Information Technology Services Department as soon as possible through an IT work order. 

4.1 Any information obtained by way of video surveillance systems may only be viewed and subsequently used only for the purpose of ensuring the on-going safety of students, promoting a safe environment, controlling vandalism and theft of school property. There shall be no access to video surveillance by third party service providers except when authorized by the School Principal or Superintendent of the School.

4.2 All recorded images are the property of the school board and are used, disclosed, retained, secured and disposed of in accordance with this procedure.

4.3 Circumstances that warrant a review of the recorded images shall be limited to instances where an incident has been reported or observed or to investigate a potential safety or theft or a vandalism issue.

4.4 Reception equipment will be installed only in identified public areas where video surveillance is necessary to ensure the safety of staff, students, and school property. Similarly, where cloud-managed security equipment is used, care shall be taken to access the content in a private secure setting. The equipment will operate up to 24 hours/7 days a week, within the limitations of the system.

4.5 The School Principal and the Information Technology Department shall be responsible to manage and supervise the use and security of cameras, monitors, computers, or cloud storage capacity used to store images all other video records related to the site.

4.6 Access to the storage devices should be limited to authorized personnel.

4.7 Video security surveillance systems create a record by recording personal information and to protect that information the following processes will be followed:

4.7.1 All video files or other storage devices that are not in use will be stored in a locked and secure location.

4.7.2 The retention period for information that has not been viewed for law enforcement, school or public safety purposes shall be 30 calendar days. Recorded information that has not been used in this fashion is to be routinely erased every 30 days in a manner in which it cannot be reconstructed or retrieved.

 

4.7.3 The retention period for information that has been viewed and used for law enforcement or student safety purposes will be 1 year from the date of viewing or one year from the date of resolution of the incident. If personal information is used for this purpose, section 5(1) of Ontario Regulation 460 under the Municipal Freedom of Information and Protection of Privacy Act requires the recorded information to be retained for one year. Video files that have been viewed will be burned to DVD, appropriately labeled and stored in a secure location.

4.7.4 The schools will store and retain video files required for evidentiary purposes until the law enforcement authorities request them. A storage device release form (Form 525A Video Surveillance Recorded Material Release Form) will be completed before any storage device is disclosed to appropriate authorities. The form will indicate who took the device, under what authority, when this occurred, and if it will be returned or destroyed after use. Form 525B will be kept in the Video Surveillance Binder. No third party other than law enforcement has the authority to request or receive any storage device.

4.7.5 Once the one-year retention of previously viewed media files has ended, those media files must be securely disposed of in such a way that the personal information cannot be reconstructed or retrieved.

4.7.6 Vendors and/or service providers of Avon Maitland District School Board’s video surveillance equipment shall not have access to recorded information.

5.1 An individual whose personal information has been collected by a video surveillance system has the right of access to his or her personal information under section 36 of the Municipal Freedom of Information and Protection of Privacy Act, unless an exemption applies under Section 38 of said Act. Access to an individual's own personal information in these circumstances may depend upon whether any exempt information can be reasonably severed from the record. (i.e. other individuals in the video would have to be severed from the record). Access to an individual’s personal information in whole or in part may be refused where disclosure would constitute an unjustified invasion of another individual’s privacy.

5.2 Parents, guardians, or employees requesting to view a segment of a video record involving their child(ren) or themselves may do so under the Municipal Freedom of Information and Protection of Privacy Act. However, the confidentiality of others must be considered and if the record cannot be severed; access will not be granted.

5.3 Principals and the Administrator of Information Technology Services should consult with their superintendent and/or Freedom of Information Coordinator regarding requests for access.

5.4 Any inadvertent disclosures or unauthorized viewing of personal information shall be reported immediately to the Superintendent of Schools and/or Freedom of Information Coordinator.

6.1 Covert surveillance occurs when surveillance devices are used without notification to the individuals.
6.2 Covert surveillance shall be used only in specific limited circumstances as an investigative tool related to criminal or illegal activity.

6.3 Covert surveillance will be used only with the approval of the superintendent. Documented rationale for the use of covert surveillance must be retained by the school principal.

7.1 Video surveillance on School buses is used to promote proper behaviour and the safety of pupils, school staff and bus drivers. 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. Retention, access, and disclosure of these videos are outlined in Section 4 of this Administrative Procedure. Videos not viewed will be destroyed when the bus is serviced, which may be longer than 30 days. The detailed procedure outlining video surveillance on the school buses is Procedure V-1 located on the Huron Perth Student Transportation Service website.

 

Form 525A Instance of Access and Viewing of Recorded Material

Form 525B Video Surveillance Recorded Material

Form 525C Storage Device Disposal Record

 

Revised 2021