Video Surveillance and Recording Policy

To regulate recording, storing and accessing audio and video footage collected from surveillance cameras and body-worn cameras (BWCs) at Seneca Polytechnic.

This policy applies to Seneca students, employees, third-party Security Services personnel, contractors and visitors.

A forward-facing camera that is carried or attached to the uniform of security personnel that is capable of capturing audio and video information.

The expectation that an individual’s personal information will be collected, used, stored and disclosed only as permitted by law and in a way that respects the individual’s dignity and right to privacy.

Real property that is owned, operated or managed by Seneca, as well as equipment provided by Seneca to students and employees.

An external organization that develops assessments and grants qualifications based on students’ skills and knowledge.

A person who performs work for remuneration that consists primarily of guarding or patrolling for the purpose of protecting individuals or property.

A coordinated set of cameras, recording devices, software and related infrastructure used to collect, view, record, store and manage visual images of people, activities or property for the primary purpose of maintaining safety, security and loss prevention, and in some cases academic integrity related to third-party examinations.

1. Security Services administrators are responsible for:
   • administering Seneca’s surveillance and recording activities
   • approving requests to install video surveillance devices and releasing recordings in accordance with this policy and applicable legislation
   • authorizing access to live footage and recordings 
   • training individuals who monitor or access live footage or recordings in the lawful and responsible use of the recordings
2. ITS and Security Services are jointly responsible for overseeing and managing Seneca’s video surveillance infrastructure.

3. The Privacy Office is responsible for:

   • ensuring authorized personnel are aware of their privacy-related obligations under applicable legislation
   • consulting on the release of video recordings related to the academic integrity of third‑party examination or awarding body assessments
   • responding to inquiries and requests to the Privacy Office under the Freedom of Information and Protection of Privacy Act

1. Every effort will be made to position video surveillance cameras to cover Seneca property and adjacent public spaces, avoiding private property whenever possible.
2. Video surveillance cameras may be installed in public areas on campus, such as front-line service areas, hallways, labs, common areas, parking lots and walkways.
3. Notice will be displayed on Seneca’s campuses that each campus is under video surveillance and that individuals’ images may be collected.
4. Video surveillance systems will record activities with no audio on a 24-hour basis.
5. Captured video recordings and/or still images may be used for the investigation of violations of Seneca policies and provincial or federal legislation.

1. Third-party Security Services personnel will be equipped with BWCs to:
   • assist with the prevention and deterrence of unlawful behaviour and behaviour that contravenes Seneca policies
   • enhance campus safety
   • capture an accurate record of Security Services interactions with the public
   • provide evidence for investigative, judicial and oversight purposes
   • collect information about the effectiveness of security procedures and training
2. BWC recordings support observations by third-party Security Services personnel supplement notes, reports and photographic and video evidence.
3. BWCs will only be activated when third-party Security Services personnel respond to an incident.
4. When a BWC is activated, it will record audio and video.

1. Seneca will maintain video surveillance cameras in its test centres to support academic integrity and ensure exam security requirements required by third‑party examination or awarding bodies and/or appliable credentialing organizations.  
2. Video surveillance cameras in test centres will record activities on an ongoing basis.
3. Surveillance camera footage in test centres may be monitored periodically to ensure the integrity of the testing environment. 
4. Video recorded on test centre surveillance cameras may only be used to:
   • protect the integrity of examinations and/or assessment materials
   • verify exam conditions, where required by a third-party examination or awarding body
   • investigate alleged misconduct or breaches of academic integrity 
5. Video recorded on test centre surveillance cameras may be reviewed after a specific incident or allegation has been identified or a documented request has been received from a third‑party examination or awarding body consistent with Seneca’s contractual obligations. 
6. Surveillance cameras in test centres will be positioned to avoid capturing detailed views of specific individuals, exam content, digital screens or written responses.

1. Generally, recordings from video surveillance and BWCs will be disclosed:
   • to law enforcement agencies for the purpose of investigating an unlawful act, incident
   • to prosecution agencies, and/or relevant legal representatives as part of legal proceedings or arbitrations
2. Recordings from video surveillance and BWCs will be disclosed to comply with a Freedom of Information request by an individual whose identity has been recorded and retained, unless a legislated exemption applies.
3. Requests from within Seneca to access recordings will be made in writing to Security Services.
4. Security Services administrators will assess requests from within Seneca to access recordings on a case-by-case basis.
5. Appeals of a denied request from within Seneca to access recordings from video surveillance and BWCs will be made in writing to the Privacy Office.
6. Access to recordings of an incident that directly involves Security Services administrators will be referred to Human Resources.

1. Recordings from video surveillance and BWCs will be stored on Seneca servers in a secure environment.
2. Recordings required for an internal Seneca investigation will be retained for a minimum of two years from completion of use.
3. Recordings required for use in court or other legal proceedings will be retained for a minimum of five years following final disposition of the matter, including any court reviews and appeals.

• Appendix: Procedures for storage, management and access to recordings

• Access Control Policy
• Campus Access Policy
• Emergency Management Policy
• Freedom of Information and Protection of Privacy Policy
• Information Technology Acceptable Use Policy
• Personal Health Information Protection Policy
• Personal Safety/Security Threats Policy
• 
  

• Criminal Code of Canada
• Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c. F.31
• Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5
• Trespass to Property Act

1. Recordings will be stored on designated Seneca servers or other acceptable digital media in accordance with appropriate information security standards and Seneca policies.
2. Access to designated servers that store recordings will be logged to ensure content integrity.
3. Designated ITS personnel will have access for the purposes of retrieving recordings and system maintenance.
4. Recordings will only be transmitted through secure lines of communication (e.g., registered mail, hand delivery and secure file transfer).
5. If recordings need to be transmitted by email, they will be secured with AES-128 encryption, at minimum, or with a File Transfer Protocol/File Transfer Security secure authorized webpage.

1. ITS will keep seven days of video surveillance and BWC recordings on each designated server to be made available to Security Services administrators, as required.
2. After seven days, recordings will be moved to storage and retained for 30 days. These recordings will remain available to Security Services administrators through Seneca’s Video Management System. 
3. After 30 days, recordings will be transferred to a data tape and stored in the data tape library for 12 months, at which time the data tape is overwritten. 
4. ITS will restore the recording to a digital format when authorized requests are made by Security Services administrators.

1. If Security Services administrators approve a request to access recordings from video surveillance and BWCs, Security Services will provide either a written synopsis of the recording or access to the segment of the recording showing the incident in question in accordance with applicable Seneca policies and legislation.
2. A physical or electronic copy of the recording will generally not be provided to the requestor.
3. If a request to access a recording is denied, Security Services administrators will provide written notice to the requestor explaining the reason for denial.
4. Appeals of denied requests to access recordings can be made by writing to the Office of the Vice-President, Finance & Administration.