Operating South Chatham Village Apartments

Video Surveillance Systems

Policy Statement

Approved by the Board of Directors, September 17, 2009

1. Purpose

(a) It is the policy of South Chatham Village to utilize video surveillance as necessary in accordance with this Corporate Policy - Video Surveillance Systems (the “Policy”).

(b) Video security surveillance systems are a resource used by South Chatham Village at selected sites within the management jurisdiction of South Chatham Village for the purpose of increasing the safety and security of tenants, staff and members of the public, to protect public safety, our corporate assets and property and to detect and deter criminal activity and vandalism.

(c) South Chatham Village is authorized to conduct video surveillance under Section 28(2) of the Municipal Freedom of Information and Protection of Privacy Act (MFOIPPA) or Section 38(2) of the Freedom of Information and Protection of Privacy Act (FOIPPA), as applicable. The Board of Directors of the Christian Senior Citizens Home of Chatham operating South Chatham Village recognizes that video surveillance technology has the potential for infringing upon an individual’s right to privacy and although video surveillance technology may be required for legitimate operational purposes, its use must be in accordance with the provisions of MFOIPPA or FOIPPA, as applicable, and any other applicable privacy laws.

(d) This Policy does not require or guarantee that a camera or recording equipment will be recording or monitored in real time at all times.

(e) All South Chatham Village employees involved in the operation of this video surveillance program have been trained on this Policy and their statutory obligations in performing their duties and functions related to the operation of the video surveillance system and South Chatham Village’s video surveillance program.

(f) South Chatham Village employees may be subject to discipline if they breach this Policy or applicable privacy laws.

2. Collection, Use and Disclosure

“Personal Information” as collected by South Chatham Village pursuant to this Policy means recorded information about an identifiable individual, including, but not limited to, information relating to an individual’s race, colour, national or ethnic origin, sex, age. If a video surveillance system displays such characteristics of an identifiable individual or the activities in which he or she is engaged, its contents will be considered “personal information”.

(a) Personal Information collected by South Chatham Village pursuant to this Policy will be recorded and will only be used for the purposes set out herein, or as may otherwise be permitted or required by law. For example, Personal Information may be disclosed to the police or other law enforcement agencies in Canada to aid an investigation. 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.

(b) Disclosure of storage devices should be made to authorities only upon the presentation by the authorities of a warrant or court order for the same and upon completion of a form setting out the name of the individual(s) who took the storage device, under what legal authority, the date and whether the storage device will be returned or destroyed after its use by the authorities.

(c) Storage devices containing Personal Information may be shared with third party service providers who have a need to access such information and only upon them entering into an agreement to keep such information confidential and handling the Personal Information in accordance with the terms of this Policy and applicable law.

3. Protecting your Personal Information

(a) Personal Information collected by South Chatham Village is protected to avoid unauthorized access. Access to the storage devices where recorded Personal Information is retained is only permitted by personnel authorized in accordance with this Policy. Systems are password protected.

4. Access

The Personal Information recorded by video surveillance is subject to freedom of information and privacy laws. You have the right to access the Personal Information we hold relating to you, including on video recordings. You may request access by contacting Jean Noordam at 519-352-0053. Requests for Access may be denied in certain circumstances as set out in MFOIPPA and FOIPPA, including where disclosure would interfere with a law enforcement matter or investigation or unjustifiably invade another person’s privacy.

5. Retention

(a) Personal Information will only be retained as long as necessary to fulfill the purposes for which it was collected pursuant to this Policy, or as otherwise permitted or required by law.

(b) Personal Information that has not been viewed for law enforcement or public safety purposes should be erased no more than 72 hours after recording. Personal that has been viewed for law enforcement and public safety purposes must be retained for a certain period thereafter (the requirement is one year in accordance with Section 5 of Ontario Regulation 823 under MFOIPPA unless a shorter retention period is specified by law).

6. Disposal

Old storage devices will be securely disposed of in a way that the personal information cannot be reconstructed or retrieved. They may include shredding, burning or magnetically erasing the personal information. Disposal of records will be recorded in writing.

7. Breach

In the event of a collection, use, disclosure or retention in violation of applicable privacy laws, South Chatham Village will comply with all recommendations of the Office of the Information and Privacy Commissioner of Ontario in responding to breaches. The General Manager will respond to any inadvertent disclosures of Personal Information. Any breach of the Acts will be reported to the Board of Directors.

8. Training

(a) This policy and any related processes or guidelines must be incorporated into training and orientation programs of South Chatham Village. Training programs addressing staff obligations under the relevant legislation shall be conducted as necessary.

(b) South Chatham Village staff and service providers are required to review and comply with this Policy and applicable privacy laws in performing their obligations related to the video surveillance system.

(c) South Chatham Village staff that violates this Policy or applicable privacy laws may be subject to discipline.

9. Designated Responsibilities

(a) South Chatham Village will maintain control of and responsibility for the video surveillance system on its premises at all times.

(b) The Christian Senior Citizen Home of Chatham Board of Directors is responsible for South Chatham Village’s compliance with applicable privacy laws and this Policy.

(c) The Christian Senior Citizen Home of Chatham is responsible for ensuring the establishment of procedures for video surveillance equipment, in accordance with this Policy and any legal requirements.

(d) The Christian Senior Citizen Home of Chatham is further 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:

(i) Documenting the reason for implementation of a video surveillance system at the designated area.

(ii) Maintaining a policy regarding the locations of the reception equipment.

(iii) Maintaining a list of personnel who are authorized to operate the systems and access any recordings, including the circumstances under which access is permitted. Logs must be kept of any access to such recordings.

(iv) Maintaining a record of the times when video surveillance will be in effect.

(v) Assigning a person responsible for the day-to-day operation of the system in accordance with policies, procedures and direction/guidance that may be issued from time-to-time.

10. Installation and Placement

When using video surveillance equipment, South Chatham Village will comply with 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 to protect public safety, corporate assets and property, including detecting and deterring criminal activity and vandalism.

(b) Privacy intrusion should be minimized to that which is absolutely necessary to achieve South Chatham Village’s required, lawful goals.

(c) Equipment to monitor video surveillance will be installed in a strictly controlled access area. Only personnel authorized under this Policy may access to the access area and the equipment. Monitors showing personal information captured by the video surveillance equipment will not be located in a way that that enables the public to view it.

(d) Equipment will be installed in such a way that it only monitors those spaces that have been identified as requiring video surveillance. Video surveillance equipment will never monitor the inside of areas where the public or employees have a higher expectation of privacy such as change rooms and washrooms. Equipment should not be focused on individuals’ doors or through windows or through windows of neighbouring buildings.

(e) Adjustment of the camera position will be restricted, if possible, to ensure only designated areas are being monitored.

11. Service Providers

(a) South Chatham Village will ensure that any agreements between South Chatham Village and its service providers state that records under the video surveillance program remain under South Chatham Village’s control and subject to applicable privacy laws.

(b) Violation of this Policy or applicable privacy laws by service providers will be considered a breach of the contract.

(c) Agreements with Service Providers should ensure that employees of service providers sign written confidentiality agreements, including complying with this Policy and applicable privacy laws in respect of personal information collected under the video surveillance program.

12. Audit of Surveillance Policy and Practices

(a) South Chatham Village will ensure that the use and security of its video surveillance program and equipment is subject to regular audits, at least once a year, to address compliance with this policy and applicable laws. The audit will also include a review of whether ongoing video surveillance is justified based on the requirements set out in this policy. Any deficiencies or concerns identified by the audit will be addressed immediately.

(b) South Chatham Village staff and service providers will be made aware that their activities are subject to the audit and that they may be called upon to justify their surveillance.

(c) Any questions or concerns related to South Chatham Village’s handling of personal information collected through video surveillance can be directed to:

Martin Vanderzwan, Board President
97-40 Elm Street, Chatham, ON. N7M 6A5
519-352-0053

13. Notification

The public must be notified of the existence of video surveillance equipment by clearly written signs prominently displayed at the entrances, exterior walls, and interior of buildings and/or perimeter of the video surveillance areas. Signage must inform individuals of the legal authority for the collection of personal information; the principal purpose(s) for which the personal information is intended to be used and the title, business address and telephone number of the appropriate contact (Privacy Officer) at South Chatham Village in order to answer questions about its personal information management practices.