Video Recording Policy
Policy Objective
The purpose of the Video Recording Policy (the “Policy”) is to describe Precise Parklink Inc.’s (“Precise”) installation and use of video recording equipment in the vicinity of gated parking equipment at client sites in the interests of privacy, customer service and protection of private property.
Underlying Principles
Precise will achieve its Policy Objective through a modern, cohesive system that strives to minimize intrusions upon the personal privacy of drivers, parkers, staff, and service providers.
Policy Statement
Video recording deployment is guided by the principle of minimal intrusion into the daily operation of parking facilities. Precise’s client premises are monitored in the interest of asset protection and quick and efficient customer service.
Scope
This Policy applies to all recording camera systems deployed across all Customer gated parking facilities using Precise-installed gated parking equipment. This Policy does not apply to video surveillance used at Precise owned properties.
Application
This Policy applies to all Precise staff and contracted workers. All parties will be made aware of this Policy, their obligation to comply with it, and given instructions in meeting the Policy's requirements.
Specific Directives
Given the open and public nature of the Precise’s client parking facilities and of the gated parking equipment which permits entry and exit therefrom, and the need to provide for remote assistance to drivers who are having issues entering or entering gated parking garages, Precise’s video recording systems operate at all times.
The video equipment shall monitor only areas that requires video surveillance – all parking gate entrances and exits.
The ability of authorized personnel to adjust cameras shall be restricted so that authorized personnel cannot adjust or manipulate cameras to overlook spaces that are not intended to be covered by the video recording program.
Equipment shall never monitor the areas where the public have a higher expectation of privacy.
Reception of recording equipment shall be located in a strictly controlled access area. Only authorized personnel shall have access to the controlled access area and the reception equipment.
Every reasonable attempt should be made by authorized personnel to ensure video monitors are not in a position that enables the public and/or unauthorized staff to view the monitors.
Types of Recording Device
Precise shall use recording mechanisms that record information directly to Precise’s video system.
Access
Access to the video recordings shall be restricted to authorized personnel, and only in order to comply with their roles and responsibilities as outlined in this Policy.
Access Request Process
With the exception of requests by law enforcement agencies, all requests for video records should be directed to info@preciseparklink.com. Requests are subject to the requirements of the Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c. F.31 (“FIPPA”) and Precise’s Privacy Policy.
Authorized Precise staff are to provide law enforcement with a secure means of accessing video footage, in the circumstances.
Viewing Images
When recorded images or videos from the cameras must be viewed for law enforcement or investigative reasons, this must only be undertaken by authorized personnel, in a private, controlled area that is not accessible to other staff and/or visitors.
Custody, Control, Retention and Disposal of Video Records/ Recordings
Precise retains custody and control of all original video records not provided to law enforcement. Video records are subject to the access and privacy requirements of FIPPA, which include but are not limited to the prohibition of all Precise employees from access or use of information from the video surveillance system, its components, files, or database for personal reasons.
Precise will take all reasonable efforts to ensure the security of records in its control/custody and ensure their safe and secure disposal. Disposal methods may include erasing, depending on the type of storage device.
Records and information collected from the video recording system are subject to varying retention periods, depending on the storage capacity of the recording system deployed at a particular site, however generally:
i) Information will be retained for a maximum of one year from the date of the original collection by the video recording system, except as described in (ii); or
ii) Information collected from the video recording system used by Precise or a law enforcement agency as part of a criminal, safety, or security investigation or for evidentiary purposes will be retained for a minimum of two (2) years from the conclusion of the matter for which it has been used.
Unauthorized Access and/or Disclosure (Privacy Breach)
Any Precise employee who suspects a privacy breach should refer to the Privacy Breach Policy.
Any Precise employee who becomes aware of any unauthorized disclosure of a video record in contravention of this Policy, and/or a potential privacy breach has a responsibility to ensure that info@preciseparklink.com is immediately informed of the breach.
Inquiries from a Public Related to the Video Surveillance Policy
A staff member receiving an inquiry from the public regarding the Video Surveillance Policy shall direct the inquiry to info@preciseparklink.com.
Responsibility
Precise shall ensure that video recording equipment is used in as follows:
Documenting, implementing, and enforcing Precise’s Privacy Policy;
Complying with and adhering to all aspects of this Policy;
Responding to formal requests to access records, including law enforcement inquiries;
Reviewing this Policy on a regular basis, and recommending updates as appropriate; and
Investigating privacy complaints related to video surveillance records, and security/privacy breaches.
Overseeing the day-to-day operation of video surveillance cameras, providing supervision to approved authorized personnel, and ensuring their compliance with all aspects of this Policy;
Ensuring monitoring and recording devices, and all items related to surveillance are stored in a safe and secure location;
Ensuring that all aspects of the video recording system are functioning properly;
Forwarding all external requests for access to video records to the appropriate authorized staff member;
Ensuring that no video surveillance imagery/records are disclosed without the approval of authorized management/in-charge staff;
Ensuring that no copies of data/images in any format (hard copy, electronic, etc.) are taken from the video recording system without approval from authorized management/in-charge staff;
Immediately reporting breaches of security/privacy to Authorized Staff; and
Forwarding all inquiries from the public about the use of video surveillance or about Precise’s Security Video Surveillance Policy to Authorized Staff.
Definitions
Authorized staff: Employees of Precise or a Precise contractor who are specifically authorized by Precise to operate the video surveillance system for a particular facility and to perform the duty, responsibility or action described in this Policy.
Client: the owner, tenant or property manager of a property, who permits Precise to install and activate gated parking equipment at the client site.
Video surveillance operation: Operation of the video surveillance system may include:
Requesting access to video surveillance records;
Accessing/viewing/retrieving video surveillance records;
Disposing of video surveillance records;
Installing/maintaining video surveillance systems and infrastructure.
Updated March 23, 2023