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Town of Greater Napanee
CCTV Policy
Approval Date:
March 10, 2026
Resolution #
136/26
Revised Date:
Resolution #
Review Scheduled:
2028
Department:
Legislative Services
Contact:
Clerk
Approval Authority:
Council
Policy No:
LS-2026-02
1. Introduction
The Town of Greater Napanee recognizes the need to balance an individual's
right to privacy with the need to ensure the safety and security of Town
employees, clients, visitors and property. While Closed Circuit Television
(CCTV) cameras are installed for safety and security reasons, the Town's CCTV
systems must also be designed to minimize privacy intrusion. The Town is
committed to the improvement of community safety, crime prevention, and the
desirability of the town as a place for shopping, business and leisure.
Guided by a commitment to public safety, crime prevention and stewardship of
publicly owned assets, the Town may, where warranted by law, use CCTV
systems in municipally owned buildings, or at municipally operated facilities,
parks and open spaces.
2. Purpose
This policy establishes controls for the Town's CCTV Program by governing the
use of CCTV Systems and CCTV Records owned or operated by the Town in
accordance with the relevant provisions of the Municipal Freedom of Information
and Protection of Privacy Act (MFIPPA).
3. Scope
This policy applies to:
a) All Town officers, employees and agents;
b) Contractors and service providers who may work with or operate CCTV
equipment for the Town;
c) All CCTV equipment in the care and control of the Town;
d) The collection, use, disclosure and disposal of information collected
through CCTV technology.
This policy does not apply to:
e) Video or audio recordings of council or committee meetings; or
f) Camera equipment installed on Town vehicles or other mobile assets.
4. Definitions
Authorized Users means Town employees who have been approved by the
CAO to operate CCTV equipment and who have received training consistent
with the requirements of this policy.
Consistent Purpose means use of personal information in manner that the
individual to whom the information relates might reasonably have expected
in the circumstances.
Live Feed means viewing of data captured from audio-visual devices and/or
CCTV equipment, whether or not these data are recorded in a file or not.
MFIPPA means the Municipal Freedom of Information and Protection of
Privacy Act of Ontario.
Personal Information in accordance with Section 2 of MFIPPA, means
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 identifier 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 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.
Privacy Impact Assessment means a written assessment that identifies the
type of personal information intended to be collected and used, legal authority
for its collection and use, employee positions that will have access to the
information, and protection measures that will be put in place to safeguard the
information from unauthorized use or disclosure.
Record means information, however recorded, whether in printed form, on
film, by electronic means or otherwise, and includes: a photograph, a film, a
microfilm, a videotape, a machine-readable record, and any record that is
capable of being produced from a machine-readable record.
Town means the Corporation of the Town of Greater Napanee.
CCTV Record means a video or still image created from the Town's CCTV
system.
CCTV System means a collection of hardware and software components that
enables centralized recording, observation and archiving of CCTV Records.
5. Responsibilities
5.1. Council
Council is responsible for:
a) Approval of this policy and any amendments; and
b) Approval of service levels for processing internal and law enforcement
requests for CCTV records.
5.2. Chief Administrative Officer (CAO)
Responsibility and authority is delegated to the CAO to:
a) Provide oversight and ensure compliance with this policy by all Town
employees;
b) Review and respond to alleged privacy breaches regarding the use of
the CCTV system;
c) Approve requests to establish Authorized Users, and define criteria
for Authorized Users by way of management directive; and
d) Review and approve Privacy Impact Assessments, in conjunction with
IT, the Clerk, and the affected Department Head.
5.3. Clerk
Responsibility and authority is delegated to the Clerk to:
a) Ensure the CCTV Program is compliant with MFIPPA;
b) Respond to requests for access to CCTV Records under MFIPPA; and
c) Ensure this policy is reviewed a minimum of once per Council term
and when there are changes to relevant privacy laws or guidelines.
5.4. Manager of Information Technology (IT)
Responsibility and authority is delegated to the Manager of IT to:
a) Assess equipment and system requirements and make necessary
arrangements for purchase and installation;
b) Take all reasonable precautions to ensure that CCTV equipment is
secure and that unauthorized individuals are prohibited from reviewing
or accessing information;
c) Maintain records associated with the CCTV Program, including audit
logs, device locations, and authorized users;
d) Implement appropriate training and control measures for Authorized
Users;
e) Make recommendations on improvements to this Policy and to the
CCTV Program; and
f) Train authorized users in operating the CCTV system.
5.5. Management Staff
Responsibility and authority is delegated to Management Staff to:
a) Authorize the installation of CCTV Equipment on municipal property
under their supervision;
b) Ensure mandatory public notice signage is installed which provides
reasonable and adequate warning that CCTV may be in operation in
locations under their supervision;
c) Document the rationale for the installation of CCTV equipment;
d) Submit a Privacy Impact Assessment and usage case for any
proposed live viewing of CCTV footage; and
e) Ensure internal requests for records are necessary for the
performance of the requester's duties in the discharge of their
functions.
5.6. Authorized Users
Responsibility and authority is delegated to Authorized Users to:
a) Retrieve and provide access to CCTV Records in response to
requests made under this policy and in accordance with any service
levels as may be established by the CAO.
5.7. Employees
All Town employees with access to the CCTV System or Records are
responsible to:
a) Understand and adhere to this policy; and
b) Report any observed or suspected privacy breaches in accordance
with this policy.
6. Policy
6.1. Acceptable Use
a) CCTV Systems may be used to:
i.
View live feed, in limited and specific circumstances;
ii.
Review CCTV records;
iii. Collect anonymized data to aid decision making, such as traffic
volume or parking vacancy rates; and
iv. Extract and archive CCTV records.
b) Live feed viewing by the Town shall only be permitted in the following
circumstances, subject to a privacy impact assessment:
i.
System maintenance carried out by the IT Department; and
ii.
For the protection of employee health and safety or municipal
infrastructure, in accordance with a video access business case
that has been approved by the Department Head, IT Department,
and the Clerk.
c) CCTV Records shall be reviewed, extracted, or archived only for the
purposes intended by the Town, including but not limited to:
i.
System maintenance carried out by the IT Department;
ii.
Investigation of reported incidents; and
iii. Viewing events in areas that require recordkeeping, as
established in a departmental video access business case.
d) Incidents shall be investigated only for the purposes intended by the
Town, including but not limited to:
i.
detecting, deterring, and investigating unlawful activity, which
includes possible contraventions of any federal or provincial law
or municipal by-laws;
ii.
investigating and resolving claims of personal injury or damage to
assets, and other legal claims; or
iii. investigating and resolving public complaints received by the
Town or matters that may give rise to a customer complaint being
received by the Town.
e) Logs shall be kept of all instances of access to and use of CCTV
Records.
f) Use of CCTV Systems and CCTV Records is subject to audit.
g) Access to CCTV Systems shall be restricted to authorized Users.
6.2. Notice of Collection of Personal Information
a) The Town's collection of personal information as CCTV Records is
authorized through this Policy and is intended to specifically protect:
i.
The public assets of the municipality;
ii.
The economic, social, and environmental well-being of the
municipality;
iii. The health, safety and well-being of persons;
iv. Services and things the municipality is authorized to provide; and
v.
Persons and property.
b) The Town shall provide notice of its collection of personal information in
the form of signage visible to members of the public. Signage shall be
placed to provide the community reasonable an adequate warning
about the use of CCTV by being:
i.
Clearly written;
ii.
Prominently displayed at pedestrian entrances and interior walls
of buildings where recording devices are installed; and
iii. Prominently displayed at pedestrian and vehicle entrances to
public spaces where recording devices are installed.
c) In accordance with Section 29(2) of MFIPPA, at least one sign in each
location shall include the following information:
i.
The legal authority for the collection of personal information;
ii.
The principal purpose(s) for which the personal information is
intended to be used; and
iii. Contact details for further information.
d) A map showing the approximate areas covered by CCTV is attached to
this Policy as Appendix A.
e) The current approved signage form is attached to this Policy as
Appendix B.
6.3 Procedures and Principles of CCTV Use
a) The CCTV usage procedures shall be performed based on the following
principles:
i.
CCTV use shall be conducted in accordance with all applicable
law, specifically Section 28(2) of MFIPPA;
ii.
CCTV use shall be conducted in a professional, ethical, and legal
manner;
iii. Authorized Users shall be appropriately trained and supervised in
the responsible use of the CCTV equipment;
iv. The CCTV system shall not monitor individuals in any manner
which would constitute a violation under the Ontario Human
Rights Code (OHRC); and
v.
Records obtained through the CCTV system shall be released
only according to the standards set by MFIPPA and other
applicable law. The recordings shall be handled in a manner that
provides continued security of the recorded information.
b) The benefits of CCTV to the public shall be weighed against an
individual's right to be free of unwarranted intrusion.
c) The benefits of CCTV to the organization shall be weighed against an
individual's and employee's right to be free of unwarranted intrusion.
d) A process is in place to allow the public to make a complaint about the
CCTV system through the Clerk's Office and a process is in place to
allow the employees to make a complaint about the CCTV system
through the Manager of Human Resources.
e) Access to the recorded information is only permitted in accordance with
MFIPPA, other applicable law, and this Policy.
f) Live viewing is restricted to time periods when there is a demonstrably
higher likelihood of safety and security concerns involving employees,
the public or corporate assets, and where a privacy impact assessment
has been completed and approved for the specific use.
g) Live feed monitors are turned off when not in use.
h) Live feed monitors are located in places only visible to and accessible by
Authorized Users.
6.4. Privacy Considerations - CCTV Infrastructure
CCTV Systems shall only record Town property and publicly available outdoor
spaces. In addition, in order to reduce the privacy impact to residents and
facility users, at minimum the following requirements shall be followed:
a) CCTV Systems shall not be configured to collect audio records, as
recording audio may constitute "wiretapping" in violation of the Criminal
Code of Canada.
b) The Town shall not enable the use of facial recognition software through
CCTV Systems without an amendment to this policy and completion of a
privacy impact assessment and business case justifying its use.
c) Recording Devices shall not monitor areas where customers, staff and
the community have a higher expectation of privacy, including but not
limited to the interior of washrooms, showers, and change rooms.
d) Recording Devices shall not monitor residential areas that are not
generally observable by the community from a public space.
e) Recording Devices that monitor any buildings not owned by the Town
shall digitally mask any visible interiors of those buildings, including but
not limited to doors and windows.
f) Recording Devices shall be installed only where they are expected to be
the most effective to community safety efforts and Town operating
procedures, including municipal facilities, municipal parks and public
spaces, the downtown core streets and sidewalks, and major
intersections.
g) Remotely adjustable Recording Devices shall not be manipulated to
monitor areas that are not intended to be monitored by the Town.
6.5. Records Access Procedures
The right to create or view CCTV Records is strictly limited and must be
undertaken as follows:
a) Public requests: Records related to public requests for disclosure shall
be released by the Clerk, or their designate, upon a written request
made through the freedom of information (MFIPPA) process.
i. Access to these records may depend on whether there is an
unjustified invasion of another individual's privacy and whether any
exempt information can be reasonably severed from the record.
ii. Any facial features will be blurred prior to the release of video
records made under a freedom of information request.
Records transmitted under MFIPPA will normally be sent through a
secure time limited link.
b) Law enforcement requests: Requests from Law Enforcement agencies
will be processed in accordance with Section 6.6 of this Policy.
c) Internal requests: Records related to internal investigations shall be
created by the IT Department on receipt of a written request from the
appropriate Department Head. Internal records shall only be retrieved
for the purposes of:
i.
investigations of incidents involving the safety or security of
people, facilities, or assets;
ii.
providing evidence as required to protect the Town's legal rights;
iii. investigating an incident or allegation of employee misconduct;
iv. investigating an incident involving an insurance claim; or
v.
a consistent purpose.
Copies of records retrieved for an internal purpose will be reviewed by
the requesting department head and either destroyed or retained by the
Department Head in accordance with the records management
requirements of the associated access purpose (i.e. insurance claim,
investigation, etc.).
d) Where an internal request for CCTV records is made in the context of a
workplace investigation involving Town employees, the request must be
submitted by the Manager of Human Resources or the CAO.
e) For all CCTV record retrieval, the IT Department shall log the following
information as an Access Log Record:
i.
The date and time of the original, recorded incident, including the
location/number of the applicable camera.
ii.
The identify of the person making the request.
iii. The case file number associated with the request.
iv. A description of the circumstances justifying the disclosure; and
v.
The date the record was provided and the means of disclosure.
f) The Town shall use the IT Department E11 or similar ticketing system to
record and track all internal CCTV record requests.
g) The Town shall use a separate ticketing system for tracking all law
enforcement CCTV record requests.
h) All external requests shall be directed to the MFIPPA process, with the
exception of law enforcement, which shall be directed to the law
enforcement process.
i) If a video record containing personal information is improperly disclosed
or is suspected to have been disclosed to an unauthorized person, the
employee who is aware of the disclosure must immediately inform their
manager, who will inform the Clerk and/or CAO as applicable in
accordance with the privacy breach requirements.
6.6. Law Enforcement Records Requests
a) The Town may disclose a copy of a video recording to a law
enforcement agency only in the following circumstances:
i.
Law enforcement approaches a Town agency or institution with a
warrant requiring the disclosure of the footage, as per section
32(e) of the MFIPPA, or
ii.
Law enforcement approaches a Town agency or institution
without a warrant and requests disclosure of the footage to aid in
an investigation from which a proceeding is likely to result, as per
section 32(g) of the MFIPPA. Such requests shall be submitted
using the form attached to this Policy as Appendix C, or
iii. Town employees observe an illegal activity on Town property and
disclose the potential availability of footage to law enforcement to
aid in an investigation from which a proceeding is likely to result,
as per section 32(g) of the MFIPPA.
b) Live viewing or use of any AI-assisted CCTV tools, including facial
recognition, by Law Enforcement will be permitted on receipt of a
warrant requiring such disclosure of the footage. In such cases, the
requirements of Section 6.3 (g) and (h) shall apply.
c) Records transmitted to law enforcement will normally be sent via a
secure link through an evidence submission portal.
d) Responses to law enforcement requests will be processed during
regular business hours, which are Monday - Friday, 8:30 a.m. to 4:30
p.m., with consideration of the following service standards and
constraints:
i.
Same day footage requests are subject to the technical delays of
the CCTV system where footage is not downloaded until up to 24
hours after it has been captured.
ii.
The Town will deem a CCTV retrieval completed at the time that
a file upload is initiated into a law enforcement digital evidence
system, as the volume of footage requested has a direct impact
on the time required for file transmission.
iii. Simple records requests which involved three or fewer camera
locations and a defined retrieval window will normally be
processed within two business days.
iv. Complex records requests which involve multiple camera
locations and/or multiple time windows will normally be processed
within five business days.
v.
Records requests will be prioritized based on the following
considerations:
-
The incident date in relation to the 30 day retention
period;
-
Requests to aid in the identification of an alleged
incident or offender to be prioritized over requests to aid
in providing supporting evidence where charges have
already been laid; and
-
Requests related to serious criminal offences will be
prioritized over requests related to lower level offences.
vi. Town staff will retrieve records based on a defined criteria related
to time and location, but will not perform live analysis or active
searching on behalf of law enforcement.
e) Pursuant to s. 32(g) of MFIPPA, the Town cannot disclose personal
information to a law enforcement agency when the agency cannot
provide definite and focused investigative information as to why the
disclosure is needed. This can include the type of offence that is
suspected, confirmation that the matter is expected to lead to legal
proceedings, and a specific case number.
f) The Town will not disclose information if the request parameters are so
broad as to capture large volumes of personal information unrelated to
the enforcement purpose. Such requests will be referred to the Clerk for
assessment and a decision regarding whether the records may be
released or if a warrant or legal order is required.
6.7. Records Retention and Disposition
a) CCTV information that is not subject of an authorized request for access
will be considered transitory and will be automatically erased by the
system by being overwritten every thirty (30) days.
b) CCTV Records that have been extracted as part of an investigation shall
be stored for the duration of the retention period recommended by
MFIPPA, being a minimum of 1 year.
6.8. Policy Review
a) The Manager of IT and the Clerk shall review this policy annually to
ensure effectiveness and compliance with current business processes,
or sooner if based on legislative changes.
b) This policy shall be reviewed by Council at least once per term.
7. Enforcement
Users shall comply with all Town policies, procedures and standards while
using CCTV Systems and Records, including but not limited to all
confidentiality policies. Employees who breach this policy, or the relevant
legislation, may be subject to disciplinary action and/or civil liability.
Users shall comply with all laws and regulations of applicable jurisdictions
while using CCTV Systems and Records, including but not limited to:
a) The Criminal Code of Canada
b) The Canadian Charter of Rights and Freedoms
c) The Canadian Human Rights Act
d) The Ontario Human Rights Act
e) The Ontario Municipal Freedom of Information and Protection of
Privacy Act
Users shall comply with any audit or investigation by the Town surrounding
their use of CCTV Systems and Records,
8. Related Documents
Municipal Freedom of Information and Protection of Privacy Act
IPC Guidelines for the Use of Video Surveillance
IPC Guidelines for Disclosure of Personal Information to Law Enforcement
Appendices
Appendix A - Map of CCTV System
Appendix B - Notice of CCTV Sign
Appendix C - Law Enforcement Record Request Form
Revision History
Date
Number
Description
March 2026
LS-2026-02
Expanded Policy
April 2015
N/A
Downtown CCTV Program Policies &
Procedures (Internal Document)
Appendix A-1 - CCTV Coverage Map
Appendix A-2 - List of Town Facilities with CCTV Installed
Exterior and Limited Interior
- Administration Building - 99 Advance Ave
- Arena - 16 McPherson Drive
Exterior Only
- AL Dafoe Water Plant - 75 East Street
- Water Pollution Control Plant - 300 Water Street
- Roblin Waste Disposal Site - 232 Roblin Road
- South Fredericksburgh Waste Disposal Site - 651 Road 1
- Selby Public Works Yard - 1599 County Road 41
- Napanee Public Works Yard - 8321 County Road 2
- Train Station - 301 John Street
- Town Hall - 124 John Street
Appendix B - Notice of CCTV Sign
Appendix C - Law Enforcement Record Request Form
The following information is being requested under section 32(g) of the Municipal
Freedom of Information and Protection of Privacy Act which allows for the disclosure of
records containing personal information for the purposes of aiding a law enforcement
investigation. This form is not to be used for requests for third party or confidential
information held by the Town of Greater Napanee. All such requests are to be referred
to the Town Clerk or designate.
Please be advised that CCTV video footage is only available for 30 days from date of
recording unless a request has been received to place a hold on specific footage.
Requester Information
Name of Requester:
Badge Number:
File Reference Number:
Phone:
Email:
Record Receipt Method:
Footage Information
Offence
Section & Statute:
Have Charges been Laid?
Yes No
Date of Incident
Time Frame of Incident
Location of Incident
Description of Incident
Other Details, if applicable
Acknowledgement
I certify that:
a) The information above is accurate and correct to the best of my knowledge;
b) I have the authority to collect the information requested on behalf of the agency noted for
the purpose(s) specified.
c) This information is requested in accordance with Section 32(g) of the Municipal Freedom
of Information and Protection of Privacy Act, as the information will aid in an
investigation undertaken with a view for a law enforcement proceeding or from which a
law enforcement proceeding or from which a law enforcement proceeding is likely to
result.
__________________________
______________________________
Signature
Date