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Video Surveillance Policy
Section
Administration &
Finance
Date
February 2026
By-Law Number
51-2026
Page
1
Of
9
Subsection
Video Surveillance
Repeals By-Law Number
29-2018
Policy
Number
AF-1-3
1.0
Policy Statement
The Corporation of the City of Kenora may use video surveillance on City properties and
within City facilities only where such use is justified, necessary, proportionate, and
connected to a lawfully authorized municipal purpose, including the safety of individuals,
the security of municipal property, and the protection of City assets.
Video surveillance shall be implemented, operated, accessed, disclosed, retained, and
disposed of in accordance with the Municipal Freedom of Information and Protection of
Privacy Act, applicable records management requirements, and this Policy.
2.0
Purpose
2.1
Video security surveillance systems are a resource used by The Corporation of
the City of Kenora at selected City sites within the jurisdiction of the Corporation.
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.
2.2
The City recognizes that video surveillance involves the collection of personal
information and may affect individual privacy. Accordingly, this Policy establishes
requirements for the lawful collection, use, disclosure, retention, security, and
disposal of video surveillance records, as well as requirements respecting notice,
privacy review, service provider management, access requests, and incident
response.
2.3
This policy will provide guidelines designed to assist City Departments that have
identified an appropriate use for video surveillance technology, to manage
records that may be created using this technology in a manner that complies
with the Act and records management requirements.
2.4
This policy also establishes minimum information technology (IT) controls to
ensure the secure operation, storage, transmission, and lifecycle management
of digital video surveillance systems.
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3.0
Scope
3.1
These Guidelines do not apply to covert surveillance used for law enforcement
purposes. In those circumstances, either a statutory authority exists and/or the
authority for the surveillance is lawfully obtained through a search warrant.
3.2
Covert surveillance is conducted through the use of hidden devices. If covert
surveillance is not implemented pursuant to the conditions in the preceding
paragraph, extra diligence in considering the use of this technology is required.
However, covert surveillance is beyond the scope of this policy.
3.3
This policy applies to all City-owned or City-managed video surveillance
systems, including network-connected, IP-based, virtualized, or centrally
managed systems, whether hosted on-premises or by an approved third-party
service provider.
4.0
Definitions
The Act means the Municipal Freedom of Information and Protection of Privacy Act,
as amended.
Personal Information has the meaning set out in the Act and includes recorded
visual images of an identifiable individual captured by a video surveillance system.
Consistent Purpose means a use of personal information that the individual to whom
the information relates might reasonably have expected at the time of collection, within
the meaning of the Act.
Record means any record of 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.
Video Surveillance System refers to any fixed, mobile, or network-connected
electronic system or device that enables the collection, recording, viewing, or
storage of visual images of identifiable individuals in public or City-controlled
spaces.
Reception Equipment refers to cameras, encoders, servers, network infrastructure,
viewing stations, and administrative systems used to capture, transmit, process, or
view video surveillance data.
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Storage Device refers to any physical or electronic medium, including servers or
secure digital storage systems, used to store recorded images.
Requirements
The following requirements apply to all City departments, employees, and service
providers involved in the approval, operation, administration, maintenance, access,
disclosure, retention, or disposal of video surveillance systems and records.
5.0
Designated Responsibilities
5.1
The Manager of Information Technology is responsible for the overall Corporate
Video Security Surveillance Program.
5.2
The Manager of each Department is responsible for ensuring the establishment of
departmental procedures of video surveillance equipment, in accordance with
this policy, and documenting the reason for implementation of a video
surveillance system at a designated area.
5.3
The Information Technology Manager is responsible for the life-cycle management
of authorized video security surveillance systems [specifications, equipment
standards, installation, maintenance, replacement, disposal and related
requirements (e.g. signage)] including:
(a) Maintaining a record of the locations of the reception equipment, including
noting the justification and purpose of the location.
(b) Maintaining a list of personnel who are authorized to access and operate
the system(s).
(c) Maintaining a record of the times when video surveillance will be in effect
(d) Posting of a NOTICE OF COLLECTION OF PERSONAL INFORMATION (Refer
to Section 5).
(e) Assigning a person responsible for the day-to-day operation of the system
in accordance with the policy, procedures and direction/guidance that may be
issued from time-to-time.
5.4
The Information Technology Department is responsible for:
-
establishing and maintaining technical security standards for video
surveillance systems;
-
managing network connectivity, authentication controls, and system
access;
-
supporting secure system maintenance, upgrades, and decommissioning.
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5.5
Employees and service providers with responsibilities under this Policy shall
comply with the Act, this Policy, applicable procedures, and all confidentiality
and security obligations.
5.6
City employees may be subject to discipline where they knowingly or
negligently breach this Policy, the Act, or related legal obligations.
5.7
Any contract with a service provider that installs, hosts, supports, accesses,
maintains, or stores video surveillance data shall require, at minimum:
1. recognition that records remain in custody or control of the City for the
purposes of the Act;
2. confidentiality and no secondary use of information;
3. access restrictions based on need-to-know;
4. prompt notification to the City of any actual or suspected privacy or security
incident;
5. secure retention, return, and deletion requirements;
6. cooperation with City access requests, investigations, and audits; and
7. restrictions on subcontracting without City approval.
6.0
Considerations
Prior to installation of video surveillance equipment, the City Department must
consider the following:
(a) The use of each video surveillance camera should be justified on the basis
of verifiable, specific reports of incidents of crime or significant safety
concerns or for crime prevention. Video cameras should only be installed
in identified public areas where video surveillance is a necessary and viable
detection or deterrence activity.
(b) A privacy review or privacy impact assessment must be completed before:
i. any new video surveillance installation;
ii. any material expansion of an existing system;
iii. any material repositioning or change in field of view;
iv. any material change in purpose, hours of operation, or functionality;
or
v. any migration to a new hosting, storage, analytics, or managed
service environment.
(c) A requirement that any agreements between the City and service
providers state that the records dealt with or created while delivering a
video surveillance program are under the City's control and subject to
privacy legislation (MFIPPA).
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(d) A requirement that employees and service providers (in the written
agreement) review and comply with the policy and the Act in performing
their duties and functions related to the operation of the video surveillance
system.
7.0
Installation and Placement
7.1
Video surveillance equipment should never monitor the inside of areas where
the public and employees have a higher expectation of privacy such as changing
rooms and washrooms.
7.2
Monitoring stations, recording equipment, servers, administrative consoles,
and other backend components of the video surveillance system shall be
located in controlled-access environments and accessible only to authorized
personnel. Video surveillance equipment shall be positioned and configured so
that it captures only those areas necessary to achieve the approved purpose
and avoids unnecessary collection from adjacent private property, private
residences, workspaces, or other areas not relevant to the approved purpose,
unless such collection is unavoidable and specifically documented. Adjustment
of the camera position should be restricted, if possible, to ensure only
designated areas that are monitored.
7.3
Video surveillance should be restricted to periods when there is demonstrably a
higher likelihood of crime being committed and detected in the area under
surveillance and may also be used to act as a deterrent to prevent further property
loss.
7.4
Signs should be clear, language-neutral graphical depiction of the use of video
surveillance and prominently displayed at the perimeter of the monitored areas
and at key locations within the areas. The signs should include basic information
to clarify that video surveillance is being used in the area.
7.5
Video surveillance systems shall be logically segmented from public networks and
protected through firewalls or equivalent network security controls.
7.6
Remote access to video systems shall be restricted, authenticated, logged, and
enabled only where operationally required.
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8.0
Lawful Collection
8.1
Section 28(2) of MFIPPA establishes the conditions under which personal
information may be collected. This section provides that no person shall collect
personal information on behalf of an institution, unless the collection is:
a) expressly authorized by statute
b) used for the purposes of law enforcement or
c) necessary to the proper administration of a lawfully authorized activity
8.2
The Corporation of the City of Kenora "Municipality" is lawfully authorized to
operate municipal facilities and in doing so, are required to take steps to ensure
the safety of the individuals who visit such facilities.
8.3
Section 31(1) of MFIPPA restricts how personal information may be used once it
has been lawfully collected. As a general rule, the act prohibits the use of personal
information unless the municipality obtains consent from the individual to whom
the information relates or the personal information is used for the purpose for
which it was obtained or compiled or for a consistent purpose.
8.4
The City of Kenora collects video surveillance for the purpose of the video
surveillance program only or for a consistent purpose.
9.0
Notification
9.1
The public should be notified of the existence of video surveillance equipment by
clearly written signs prominently displayed at the entrances, exterior walls,
interior of buildings and/or perimeter of the video surveillance areas.
9.2
Signage must satisfy the notification requirements under section 29(2) of the
Act, which include:
a) informing individuals of the legal authority for the collection of personal
information;
b) the principal purpose(s) for which the personal information is intended
to be used; and
c) the title, business address and telephone number of someone who can
answer questions about the collection;
The following is suggested wording for use in building signage, based on a
minimum requirement of the Information and Privacy Commissioner of Ontario:
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"This area is monitored by video surveillance cameras. Please direct
inquires to: (title, business address and phone number of someone who can be
contacted during business hours to answer questions about the collection of personal
information)"
10.0 Access, Use and Disclosure
10.1 Section 3 of Regulation 823 of MFIPPA requires the municipality to define,
document and put in place reasonable measures to prevent unauthorized access
as well as inadvertent destruction or damage of records. Information collected
by video surveillance systems may only be used for the purposes of the stated
rationale and objectives set out to protect public safety or to detect and deter
criminal activity and vandalism. Information should not be retained or used for
any other purposes.
(a) All video recordings, whether stored on physical media or digital storage
systems (including on-premises, cloud-hosted, or Software-as-a-Service
platforms), that are not actively in use shall be securely stored in a controlled
access environment. Storage media shall be logically and/or physically protected,
appropriately labeled where applicable, and safeguarded against unauthorized
access, loss, or tampering.
(b) Access to video surveillance recordings and storage systems shall be
restricted to authorized personnel only and protected through appropriate
technical and administrative controls, including role-based access and
authentication measures. All access to, and use of, recorded information shall
be logged in a manner sufficient to create a reliable audit trail.
(c) The personal information recorded by video surveillance is subject to
access and privacy legislation. An individual whose personal information has
been collected by a video surveillance system has a right of access under
Section 36 of the Municipal Freedom of Information and Protection of Privacy
Act. Access will depend upon whether an exemption applies and if exempt
information can be reasonably severed from the record.
(d) Only the CAO, City Solicitor, Division Director, Manager of Human
Resources, or a delegated alternate, or law enforcement may review the
information. Circumstances, which would warrant review, will normally be
limited to an incident that has been reported/observed or to investigate a
potential crime.
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10.2 General access to City video surveillance for their own purpose is only
permitted under general circumstances under section 4 of MFIPPA. Individuals
may have access to their own personal information; however, another person's
personal information may not be included unless consent is provided by that
party. A Freedom of Information request must be filed with the Freedom of
Information Officer to obtain this information and appropriate procedures and
fees under that application followed.
11.0 Lawful Disclosure
11.1 MFIPPA prohibits the disclosure of personal information, except in the
circumstances identified in section 32 of MFIPPA. Personal information may be
lawfully disclosed in limited circumstances to appropriate authorities for
limited purposes.
11.2 All general requests for disclosure must be placed by filing a Freedom of
Information request (FOI) with the Freedom of Information Officer with the
City of Kenora.
11.3 Requests from enforcement agencies for the sole purpose of a police
investigation may be filed directly with the City's IT department and
appropriate logs for such requests will be retained. These logs will include the
name of officer, enforcement agency requesting and the general nature of the
investigation.
12.0 Retention
12.0 The retention period for information that has not been viewed for law
enforcement, public safety purposes, or security of public property shall be
thirty (30 calendar days for digital systems. Once the retention period is met,
all recordings are overridden by new video data.
12.1 When recorded information has been viewed for law enforcement or public
safety purposes, the retention period shall be a minimum of one (1) year from
the date of viewing. Unless involved in an active police investigation.
12.2 The City will store and retain storage devices required for evidentiary purposes
according to standard procedures until the law enforcement authorities request
them.
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13.0 Training
Where applicable and appropriate, the policy and guidelines will be incorporated into
training and orientation programs of the Corporation and service provider(s). Training
programs addressing staff obligations under the Act shall be conducted as necessary.
14.0 Reference
The Municipal Freedom of Information and Protection of Privacy Act (MFIPPA);
Information and Privacy Commissioner of Ontario (IPC) Guidelines for Using Video
Security Surveillance Cameras in Public Spaces; The Municipal Act 2001, S.O. 2001,
c. 25.