Procedure for Managing Video Surveillance – March 26, 2026
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PROCEDURE
FOR
MANAGING
VIDEO
SURVEILLANCE
Procedure
Type:
Management
Initially
Approved:
August 27,
2019
Procedure
Sponsor:
General Counsel
and University
Secretary
Last Revised:
March 26,
2026
Administrative
Responsibility:
Security Services
Review
Scheduled:
March 26,
2031
Approver:
Executive Leadership Team
A.
PROCEDURES
1.
PURPOSE FOR SURVEILLANCE
1.1
The use of Video Surveillance is intended to:
a. be used for Public Security Purposes;
b. protect the University Community by discouraging unlawful or disruptive
behaviour;
c. maintain a safe and secure environment; or
d. support in the immediate response of an observed or reported incident.
1.2
The collection, use, disclosure, protection and destruction of Video Surveillance
records adheres to all applicable municipal, provincial and federal legislation, and
University policies.
1.3
These procedures do not apply to surveillance used for Law Enforcement as an
investigative tool where such activity is authorized by legal enforcement authorities,
legislation or court order.
2.
VIDEO SURVEILLANCE EQUIPMENT SET-UP AND MAINTENANCE
2.1
The Director of Security Services, or designate, approves the installation and use,
and disabling or disconnection of all Video Surveillance equipment.
2.2
Facilities Management in consultation with Information Technology Services
supervises installations of all Video Surveillance equipment.
2.3
Security Services coordinates all testing of and repairs to the Video Surveillance
system. Security Services tests the operation of all cameras and related equipment
monthly or as Security Services deems reasonable and reports any malfunctions or
concerns to Information Technology Services.
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3.
USE AND MONITORING OF RECORDS OBTAINED THROUGH VIDEO SURVEILLANCE
3.1
The Director of Security Services is the records custodian responsible for the
supervision of Video Surveillance records, in accordance with the Records and
Information Management Program policy.
3.2
All Video Surveillance records are stored and accessed in a restricted-access area
within Information Technology Services. Access to this space is restricted to
authorized members of the University’s Security Services and Information
Technology Services personnel. Video Surveillance equipment, or any records
therefrom, may only be removed from the restricted-access area upon the written
authorization of the Director of Security Services or their designate.
3.3
Monitoring of Video Surveillance is conducted by authorized members of Security
Services, in accordance with the Security Services Conduct policy. The Director of
Security Services, or designate, ensures that authorized individuals are provided
appropriate training. Misuse of the Video Surveillance equipment or records will
result in disciplinary action.
4.
INCIDENT REPORTING
4.1
All Video Surveillance records are retained through the completion of a Security
Services incident report. Video Surveillance records are added to the report as an
attachment.
4.2
Where alleged misconduct is viewed in the regular monitoring of Video Surveillance,
the Director, Security Services, will notify the appropriate Senior Leader of the
incident and existence of the footage.
4.3
Video Surveillance records may be used in support of an investigation and
subsequent proceedings of alleged misconduct.
a. Where a Video Surveillance record is requested as part of an investigation of
alleged misconduct, it may only be disclosed when approved by the Chief Safety,
Risk, and Employee Wellness Officer or designate.
b. If a request to use Video Surveillance records creates a real or apparent conflict
of interest for the Chief Safety, Risk, and Employee Wellness Officer, the
General Counsel and University Secretary will approve the request. In the event
the General Counsel and University Secretary has a conflict of interest, the
President will approve the request.
c. If a request to use Video Surveillance records creates a real or apparent conflict
of interest for the President, the Chair of the Board of Governors will approve the
request.
d. Upon approval by the Chief Safety, Risk, and Employee Wellness Officer or
designate, the records custodian or delegate releases the Video Surveillance
records to the requester, or advises that the requested record does not exist.
e. The approver may place any restrictions on the use, storage and viewing of the
Video Surveillance records as deemed appropriate and in accordance with
Privacy legislation.
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4.4
Video Surveillance records that are required for evidentiary purposes or disclosure
to Law Enforcement will be retained in a Security Services Incident Report.
4.5
The disclosure of Video Surveillance records to applicable law enforcement agencies
is in accordance with Privacy legislation.
4.6
Security Incident Reports are retained for a period of seven (7) years as outlined in
the Records and Information Management Program Policy.
5.
RETENTION PERIOD
5.1
All Video Surveillance records are retained and disposed of in accordance with the
Records and Information Management Program policy.
5.2
If a Video Surveillance record is not viewed for Law Enforcement purposes or for the
purposes set out in these procedures, the record is retained for a period of thirty
calendar days and then deleted or otherwise securely disposed of by Security
Services.
6.
PROTECTION OF PRIVACY
6.1
All public areas of the University, as well as on or in University-owned or operated
property, are subject to Video Surveillance. Surveillance cameras and equipment will
not be positioned towards property or windows adjacent to University-owned or
operated property, nor will
Video Surveillance be placed in or on areas in which
individuals have a reasonable expectation of privacy, including but not limited to
locker rooms and washrooms.
6.2
Video Surveillance equipment may be installed in private offices where there is a
security concern pending the Director of Security Services has received written
notice of consent from the office’s occupant(s).
6.3
Video Surveillance monitors are located in a secure, restricted-access location, away
from public view.
6.4
The Director of Security Services as the Records Custodian responsible for the
Video Surveillance records must do the following:
6.4.1 ensure that Video Surveillance Records are protected by making
reasonable security arrangements to mitigate against such risks as the
unauthorized access, collection, use, disclosure and destruction of these
records.
6.4.2
notify the Access and Privacy Office in accordance with the Procedure of
Managing a Privacy Breach.
7.
NOTICE
7.1
Signage is prominently displayed throughout the University at appropriate locations,
including all general entrances, to provide individuals with notice that:
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a. there may be Video Surveillance cameras in all public areas of campus, as well
as on or in University-owned or operated property, that may be used to record
and monitor activity;
b. Personal Information collected through the Video Surveillance system may be
used or disclosed for Public Security Purposes;
c. individuals may contact Security Services should they require additional
information or have concerns regarding Video Surveillance; and
d. the collection of Personal Information is authorized in accordance with applicable
laws.
8.
ACCESS TO RECORDS
8.1
Requests to access the Video Surveillance records may be submitted in writing to
the Chief Safety, Risk, and Employee Wellness Officer or designate. The record may
be routinely disclosed only if the information contained in the record being requested
only captures the individual seeking access to that record in accordance with Privacy
legislation.
8.2
If the Video Surveillance record being requested captures additional, or other, third
parties, the requester has the right to submit a formal access to information request
to the Access and Privacy Office in accordance with the Alberta Access to
Information Act.
8.3
If a Video Surveillance record has been requested as part of an access to information
request through the Access and Privacy Office, Security Services will release the
record of the Video Surveillance to the Access and Privacy Office to support
responding to the request.
B.
DEFINITIONS
(1)
Access and Privacy
Office:
means the Information Management & Privacy Advisor and/or
Senior Leaders of the Access & Privacy Office as delegated by
the President in writing.
(2)
Act:
means the Access to Information Act of Alberta. Also referred
to as “ATIA”.
(3)
Employees:
means individuals who are engaged to work for the University
under an employment contract, including but not limited to
faculty, staff, exempt, casual and management employees.
(4)
Formal Access to
Information
Request:
means a request for access to information/Records made to the
University through the Access and Privacy Office under the
formal processes under the Act.
(5)
Law Enforcement:
means policing, including but not limited to, criminal
investigations or proceedings having the potential of leading to
penalties or sanctions.
(6)
Personal
Information:
means recorded information about an identifiable individual,
including:
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a. the individual’s name, home or business address or
home or business telephone number,
b. the individual’s race, national or ethnic origin, colour or
religious or political beliefs or associations,
c. the individual’s age, marital status or family status,
d.
the individual’s gender identity, sex or sexual
orientation,
e. an identifying number, symbol or other particular
assigned to the individual,
f. the
individual’s
fingerprints,
other
biometric
information, blood type, genetic information or
inheritable characteristics,
g. information about the individual’s health and health
care history, including information about a physical or
mental health,
h. information about the individual’s educational,
financial, employment or criminal history, including
criminal records where a pardon has been given,
i. anyone else’s opinions about the individual, and
j. the individual’s personal views or opinions, except if
they are about someone else.
(7)
Public Security
Purpose:
means a use or disclosure relating to disciplinary, legal or public
safety and security purposes or in accordance with any court
order subject to the University’s policies or procedures or
applicable legislation.
(8)
Senior Leader:
includes ELT and any other leader who either (i) reports to a
Vice-President or the President and leads a department and (ii)
any other person designated as a Senior Leader by ELT.
(9)
University:
means Mount Royal University.
(10)
University
Community:
includes Mount Royal University Board of Governors,
employees, students, contractors, consultants, volunteers and
persons visiting the University campus.
(11)
Video Surveillance: the use of cameras and related technologies to continuously
monitor and record activity in specific locations for public safety
purposes.
C.
RELATED POLICIES
● Acceptable Use of Computing and Communication Resources policy
● Code of Conduct – Employees
Procedure for Managing Video Surveillance – March 26, 2026
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● Records and Information Management Program policy
● Security Services Code of Conduct
D.
RELATED LEGISLATION
●
Access to Information Act, SA, 2024, c A-1.4
● Protection of Privacy Act, SA, 2024, c P-28.5
E.
RELATED DOCUMENTS
F.
REVISION HISTORY
Date
(mm/dd/yyyy)
Description of
Change
Sections
Person who
Entered Revision
(Position Title)
Person who
Authorized Revision
(Position Title)
01/19/2022
Editorial
Related Policies
Policy Advisor
General Counsel and
University Secretary
12/20/2022
Editorial
Title Changes
Director, Security
Services
04/20/2023
Editorial
Definitions
Policy Advisor
General Counsel and
University Secretary
01/11/2024
Editorial
Position Title
Update
Manager, Security
Services
12/17/2024
Minor
Position titles and
Section 4
Manager, Security
Services
Deans’ Council
03/26/2026
Major
All
Information
Management &
Privacy Advisor
Executive Leadership
Team