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KCS Electronic Surveillance Policy

PURPOSE

The purpose of this policy is to provide transparency to the Kingsway College School (KCS) community (and the public) about how electronic surveillance is used on KCS campuses.

This policy may change from time to time, and KCS will post the policy (and any updates) on our website in a location that will be accessible to the public.

POLICY

KCS has implemented electronic surveillance to promote the safety and security of students, staff, parents, guests, visitors, and school property, and to aid in the deterrence and prevention of criminal activities or activities which violate school policies. All electronic surveillance is digital and does not record audio.

The purpose of the electronic surveillance by KCS is to:

  • Enhance the safety and security of students, staff, parents, guests, and visitors to the school.
  • Deter theft and vandalism and assist in the identification of individuals who commit damage to property within the school.
  • Promote a safe environment by deterring acts of violence, harassment, assault, or other criminal activities within the school.
  • Assist the School in meeting its legal or regulatory obligations.
  • Assist law enforcement agencies with regards to the investigation of any crime and aid in identifying intruders or persons breaking the law while in the school.

KCS shall not use video monitoring for purposes other than the purposes expressed in this policy or as authorized by law.

Use of the Surveillance System

Surveillance camera equipment has been set up to record activity at Specified Locations (as defined below) on KCS campuses. The live images are viewed by designated Individuals (as defined below). Historical recordings are viewed by a designated individual (or delegate) if an incident requiring investigation occurs.

a.  Surveillance Camera Specified Locations

Surveillance cameras may be located anywhere in the School, other than the exclusions outlined below, but are often located in the following School areas:

  • Building entrance(s) and exit(s)
  • Hallways, lobbies, or stairwells
  • Common multiuse gathering spaces such as an assembly hall

Exclusions: Restrooms, changing rooms, meeting rooms, and private offices.

b. Recording Operations

Recording of images (“recordings”) are continuous (24 hours a day, 7 days a week). All images are retained in a self-contained hard drive that is hard- wired to our internal secure data network. Once the hard drive is full, the earliest Recordings will be overwritten, resulting in Recordings being retained for approximately 30 days.

Responsibility for, Retention of, and Disclosure of Video Records

a.  Responsibility for Recordings

The Director of IT Infrastructure (the “Recording Manager”) is responsible for the use and security of the electronic surveillance cameras, monitors, recordings, and systems used to store video recordings, as well as all other electronic surveillance equipment & records. The Recording Manager shall:

  • ensure the school’s adherence to applicable privacy legislation, including the federal Personal Information Protection and Electronic Documents Act (PIPEDA)
  •  assess the deployment of new cameras and periodically assess the school’s use of surveillance to minimize the privacy impact of surveillance while meeting the purposes of this policy
  • secure the cameras and related hardware devices and install them in locations that are difficult to access by the public
  • implement and maintain appropriate physical, organizational and technological safeguards to protect the confidentiality and integrity of the recordings.
  • Safeguards shall include the restriction on access to the recordings, auditing, retention and secure destruction of storage devices and recordings, all in accordance with this policy
  • The Recording Manager may engage personnel and security services providers to operate and maintain the surveillance systems as prescribed in this policy.
     

Only the following individuals are permitted to access controls and Recordings, and only as authorized by the Recording Manager for the purposes set out in this policy. These individuals include:

  • The Head of School
  • Members of the IT Infrastructure Team, in the context of an investigation
  • other such individuals as appointed by the school from time to time (collectively, the “designated individuals”).

The Recording Manager shall be responsible for administering and enforcing all designated individual access privileges. When a person no longer holds a designated individual position that requires access to video records, access will be promptly removed from that individual.

b.  Retention and Disposal of Recordings

Recordings will be overwritten after approximately 30 days, unless used in accordance with this policy, and securely destroyed in compliance with applicable laws. All old or non-functioning storage devices will be disposed of in a secure manner so that any Recordings they hold cannot be retrieved or reconstructed.

c.  Disclosure of Recordings

The Recording Manager is responsible for authorizing all disclosures of Recordings to third parties (including law enforcement). The Recording Manager must keep a record of every such disclosure. The record shall include information that identifies the occurrence (including by date), that identifies the third-party, that includes the reason for the request, and that appends any consents obtained in authorizing the disclosure.

d.  Access by Individuals to Personal Information on Recordings

An individual who is the subject of video monitoring may request access to the Recording in accordance with applicable privacy laws. The Recording Manager shall consider such requests and access in full or in part may be granted or refused.

e.    Violation of Policy

Any violation of this policy will be investigated by the school and will be addressed through appropriate action, which may include the identification of individuals involved in the violation to affected individuals, disciplinary consequences, termination of contractual relationships with the school, the filing of a criminal complaint, or civil action, as appropriate.

Notification of Electronic/Digital Surveillance

a.  General Signage

The school shall post signs advising that the specified locations are monitored by surveillance equipment, which signs shall be prominently displayed at the perimeter of the surveillance areas and at the entrances to the school, in order to provide reasonable and adequate warning that recordings are being undertaken.

The signage will include:

  • Notice that video surveillance is occurring
  • Who within the organization is responsible for conducting the surveillance, and how to contact them
  • Who to contact for access to surveillance footage