Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 368 Government institutions should ask if the surveillance system is necessary or if there is a less privacy-invasive option that achieves the same goal. Secondly, since surveillance systems collect personal information, government institutions should ensure it has the authority under FOIP to collect personal information or The Health Information Protection Act to collect personal health information. It should also consider if it has authority to use and/or disclose the personal information that is collected. Thirdly, government institutions must ensure it is meeting is obligations under FOIP. This includes notifying the public of the collection of personal information (subsection 26(2) of FOIP) the duty to protect (section 24.1 of FOIP) as well as having the ability to provide access to surveillance footage in response to access to information requests.868 Government institutions should ensure they are using surveillance systems in the most privacy protective manner as possible. This includes considering the location of surveillance systems. Areas where there are heightened expectations of privacy such as washrooms should not have surveillance systems. Before implementing the use of video surveillance, some considerations are: • Is the use of video surveillance lawful. • Is the video surveillance necessary. • Are there stakeholders to consult with.869 Once the decision is made to implement video surveillance, some considerations are: • Is the duty to protect being met. • What measures can be taken to minimize the impact to personal privacy. • What safeguards should be put in place to properly protect the personal information. • How will access to information requests for footage be handled.870 After the implementation, consideration should be made for the: 868 SK OIPC resource, Video Surveillance Guidelines for Public Bodies, January 2018. Available at Video Surveillance Guidelines for Public Bodies (oipc.sk.ca). 869 For more see SK OIPC resource, Video Surveillance Guidelines for Public Bodies, January 2018. Available at Video Surveillance Guidelines for Public Bodies (oipc.sk.ca). 870 For more see SK OIPC resource, Video Surveillance Guidelines for Public Bodies, January 2018. Available at Video Surveillance Guidelines for Public Bodies (oipc.sk.ca).
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