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Lloydminister Public School Division

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5017 46 Street
Lloydminster, Alberta T9V 1R4

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Administrative Procedures

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Administrative Procedure 181

Video Surveillance

Background

The Lloydminster Public School Division has the responsibility to provide a safe and secure, learning and work environment and protect division property and property of others, from theft or vandalism.

For reasons of safety for students, employees, and others, as well as deterring destructive acts, the Lloydminster Public School Division authorizes the use of video surveillance equipment on division property, where circumstances have shown that it is necessary for these purposes and the benefit outweighs the impact on the privacy of those observed.  Use is to be limited and only authorized after a thorough analysis of the considerations involved.  Such use shall comply with all federal and provincial legislation, and with this Administrative Procedure.

The Lloydminster Public School Division recognizes both its legal obligation to provide appropriate levels of supervision in the interests of student safety and the fact that students have privacy rights that may be affected but not eliminated while under the supervision of the school. A recorded tape or digital recording is recognized to be subject to the provisions of the Local Authority Freedom of Information and Protection of Privacy Act.

Procedures

  1. Use of video Surveillance systems may occur when:
    1. No other supervision option is feasible;
    2. The need is pressing;
    3. The need outweighs the privacy interest of the student or other person likely to be
      observed;
    4. Video surveillance systems may be used to monitor and/or record activity that occurs
      on property that is owned or leased by the Lloydminster Public School Division;
    5. Video surveillance systems may be placed only in areas where surveillance has
      proven to be necessary as a result of prior property damages or related security
      incidents, or in areas where upon reasonable grounds the surveillance is deemed to
      be a deterrent;
    6. Before video surveillance is introduced at a site, a report must be provided to the
      Director of Education or designate describing the circumstances that indicate the
      necessity of having surveillance at the site, including consideration of less invasive
      alternatives.;
    7. Video surveillance cameras shall not be directed to look through the windows of adjacent buildings;
    8. Public notification signs must be prominently displayed indicating areas subject to video surveillance. Notice must include information designating the staff person who is responsible for answering questions about the surveillance system and the hours during which surveillance is conducted;
    9. Video surveillance is not to be used in locations where confidential or private activities/functions are routinely carried out.  Such areas shall include, but shall not be limited to, change rooms, washrooms, and private conference/meeting rooms.  Any exception to this must be authorized by the Director of Education.
  2. Security 
    1. Video surveillance systems will be installed and maintained only by a designated
      staff member or agent of the Lloydminster Public School Division.  Only these
      staff members shall handle the cameras or digital recordings.
    2. Digital recordings shall be securely stored in a locked receptacle in an area to
      which students, unauthorized persons, and the public do not normally have
      access.  When stored on a computer digital recordings shall be stored on
      machines with restricted access.
    3. Digital recordings may never be publicly viewed or distributed in any other
      fashion except as provided by this Administrative Procedure and applicable
      legislation.
    4. A live feed of building entrances may be permitted to be
      monitored by the office staff in order to determine who is entering and leaving
      the building.
  3. Viewing of Digital Recordings 
    1. Video monitors or computers used to view videos or digital recordings shall not
      be located in a position that enables public viewing.  Recordings may only be
      viewed by:
      1. The Principal, secretary, or individual authorizing 
        camera installation;
      2. Parents/caregivers and students (subject to 3.3 below);
      3. Lloydminster Public School Division staff with a direct involvement with specific recording and authorized by the Director of Education; and,
      4. Staff members or agents responsible for the technical operations of the system (for technical purposes only).
    2. If an employee or student is facing any disciplinary action, they may
      authorize their union representative or other advocate to also view the
      recording.
    3. Parents/caregivers requesting to view a segment of a recording that includes their
      child/children, may do so if it does not unduly interfere with the student’s
      privacy rights.
      1. Students may view segments of a recording relating to themselves if they are capable of exercising their own access to information rights under the Local Authority Freedom of Information and Protection of Privacy Act.
      2. Student/ and parent/caregiver viewing must be done in the presence of the Principal.  A student, or parent/caregiver has the right to request an advocate to be present.
      3. At the Principal’s discretion viewing may be refused or limited where viewing would be an unreasonable invasion of a third party’s personal privacy, would give rise to concern for a third party’s safety, or on any other grounds recognized in the Local Authority Freedom of Information and Protection of Privacy Act.
    4. The Principal will keep a log of all copies made of an original recording.  All
        logs will include the name of the individual who accessed the recording, the
        reason they were accessed, the date, and time.
    5. Any requests for copies by third parties including the police will be made
      through the Privacy Officer who must ensure that the Surveillance Video Release
      Form (Form 181-1) is completed before the copy of surveillance video is
      released, and in accordance with the Administrative Procedure on Local
      Authority Freedom of Information and Protection of Privacy.
    6. A log shall be maintained of all episodes of access to, or use of video
      recordings.
  4. Retention of Videotapes and Digital Recordings
    1. Where an incident raises a prospect of an insurance or legal claim against the
      Lloydminster Public School Division, the recording or a copy of it, shall be sent 
      to the Lloydminster Public School Division’s insurer or legal counsel through the
      Lloydminster Public School Division’s Local Authority Freedom of Information
      and Protection of Privacy Coordinator.
    2. Videos and digital recordings shall be erased within thirty (30) days unless they
      are being retained at the request of the Principal, Director of Education, staff member, parent/caregiver or student for documentation related to
      a specific incident, or are being transferred to the Lloydminster Public School
      Division’s insurers.
    3. Digital recordings retained under 4.2 shall be erased as soon as the incident in
      question has been resolved. If the recording has been used in the
      making of a decision about an individual, the tape must be kept for a minimum of
      one year unless earlier erasure is authorized by or on behalf of the individual.
    4. Individuals who view digital recordings without proper authorization will be
      subject to disciplinary action.
  5. Review
    1. Each Principal is responsible for the proper implementation and control of the
      video surveillance system.
    2. The Director of Education, or designate shall conduct a review at least annually
      to ensure that this Administrative Procedure is being adhered to and to make a
      report on the use of video surveillance in the Lloydminster Public School
      Division.
    3. All surveillance operations are subject to audit and principals and site
      supervisors may be called upon to justify any aspect of their use of video
      surveillance.
    4. All Lloydminster Public School Division video monitoring shall be carried out in
      accordance with this Administrative Procedure.  The Lloydminster Public School
      Division will not accept the improper use of video surveillance and will take
      appropriate action in any cases of wrongful use of this Administrative Procedure.

Reference
Section 85, 87 Education Act, 1995
Local Authority Freedom of Information and Protection of Privacy Act

Created
April 14, 2009

Revised:
June 2009
November 2013
August 2023