Security Camera Policy

Approval Date: December 1, 2025

Purpose

The Toronto Public Library (TPL or "the Library") strives to maintain a safe and welcoming environment for Library Users, which includes Library customers, staff, volunteers and service providers, while protecting individual rights to privacy. TPL recognizes the use of security cameras at Library facilities as part of the Library's overall strategy to ensure the safety of persons and property. This Policy defines appropriate management and use of security cameras within the Library.

Scope

This Policy applies to all camera systems deployed by TPL at Library owned and/or leased properties, including the installation, operation, and maintenance of security cameras. This Policy also applies to all Library Users and all types of security camera systems, including security camera monitors and security camera recording devices at Library-managed facilities.

This Policy does not apply to video recording cameras used for employment-related or labour-related information. This Policy does not address instances where Library Users or approved third parties record a specific event or activity (such as a program, or presentation). For clarity, this Policy does not apply to non-TPL owned or operated camera systems at co-located Library facilities that share space with other community entities and have security cameras owned and operated by these other entities and not by the Library.

Underlying Principles

TPL's security camera systems are a resource used by the Library to promote the safety of TPL Users while striving to minimize intrusions upon personal privacy. Where deployed for these purposes, security camera systems also help to protect Library property against theft or vandalism and can assist in the identification of individuals violating the Library's Rules of Conduct.

In the event of a reported or observed incident, the review of recorded information may be used to assist in a Library investigation of the incident or may be requested by law enforcement for the purpose of a law enforcement investigation. The Library will always maintain control of and responsibility for its security camera system.

This Security Camera Policy helps ensure that the Library follows the guidelines set out by the Information and Privacy Commissioner of Ontario, and the privacy requirements of the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA), without compromising the safety and security of Library Users and facilities.

Policy Statement

This Policy is in place to maintain public safety and security of property through adequate planning and installation of security cameras in Library facilities. The deployment of security cameras and monitoring systems is achieved through the consistent use of an evidence-based approach to camera deployment, guided by the principle of minimal intrusion by security camera systems into Library User privacy and the daily operation of Library facilities. Library-owned facilities are monitored in the interests of public safety, protection of property, and to maintain a safe and welcoming environment for Library Users.

  1. General

    • 1.1 Library security camera systems will balance privacy considerations with contributing to a welcoming and supportive environment throughout Library spaces by deterring violations of TPL's Rules of Conduct policy, as well as providing evidence to support the investigation of violations of the Rules of Conduct policy.
    • 1.2 Only authorized Library staff and service providers are permitted to operate or have access to the Library's security camera systems.
    • 1.3 All authorized staff and service providers are expected to review and comply with this Policy, the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA), and other relevant statutes, applicable guidelines, and standards, in performing any duties and functions that are related to the operation of the security camera systems.
    • 1.4 To ensure a common understanding of how Library security camera systems operate and contribute to the overall safety and security of Library Users and the Library's facilities and property, the Library will:
      • Consult and communicate changes in security camera system functionality regularly with all authorized staff and service providers; and
      • Ensure that staff and service providers are well-informed of this Policy and its related guidelines and standards and understand their application.

  2. Design and Installation of Security Camera Systems

    • 2.1 The Library commits to developing and implementing security camera system design and privacy features in all areas identified as requiring security cameras.
    • 2.2 Where the City of Toronto or Province of Ontario has provided for relevant security equipment design and installation standards, the Library will meet or surpass those standards.
    • 2.3 Security camera systems will be designed or redesigned to ensure the safety of Library Users and facilitate equity, inclusivity, and accessibility.
    • 2.4 Where possible, security camera recording will be restricted to periods when there is a demonstrably higher likelihood of Rules of Conduct violations being committed and detected in the area under security camera recording. Given the open and public nature of the Library's facilities and property, security camera recording may operate 24 hours a day if deemed appropriate for the purposes of safety and security.
    • 2.5 Security camera equipment will never monitor the inside of areas where individuals have a higher expectation of privacy (e.g. change rooms and washrooms).
    • 2.6 Every reasonable effort will be made to ensure security camera monitors, or other equipment capable of displaying footage, are not in a position that enables unauthorized individuals to view footage.
    • 2.7 Security camera systems and footage will be safeguarded in accordance with the requirements set out in TPL's Information Security policy for systems containing personal information.

  3. Security Camera Recording Signage

    • 3.1 The Library will use clear and prominent signage to provide appropriate notice of TPL-owned security cameras in use. Signage will be visible to Library Users, at all entrances to a Library facility where security cameras are used and/or on the perimeter of the area monitored by security cameras, and will include the following information:
      • The legal authority for the collection of personal information.
      • The principal purpose(s) for which the personal information is intended to be used.
      • The title, business address, and telephone number of someone who can answer questions about the security camera footage.

  4. Security Camera System Access

    • 4.1 Only authorized Library staff or service providers will be permitted to operate security camera systems or modify system settings and/or camera angles.
    • 4.2 Only authorized Library staff or service providers will be permitted to view and/or extract camera footage within video recording systems. Camera recording extraction will be conducted in a secure area inaccessible to unauthorized individuals.
    • 4.3 All requests for security camera footage are subject to the requirements of MFIPPA and the Library's Access to Information and Protection of Privacy Policy. This includes but is not limited to the prohibition of all Library employees from access or use of information from the security camera system, its components, files, or database for personal reasons.
    • 4.4 Requests for security camera information are to be directed as per this Policy and the accompanying Security Camera Guidelines.

  5. Security Camera Footage: Law Enforcement

    • 5.1 If access to a security camera record is required for the purpose of a law enforcement investigation, the requesting Law Enforcement Officer must make the request in writing by completing the Form specified by TPL with the required information.
    • 5.2 Requests will be reviewed on a case-by-case basis. The Library will comply with such requests in accordance with MFIPPA and other applicable laws and regulations.
    • 5.3 When granting access, the Library will provide the recording for the specified date and time of the incident requested by the Law. Enforcement Officer, subject to MFIPPA exemptions. Approved recordings will be provided through a secure means of access.
    • 5.4 The Library will maintain documentation of all requests and the Library's response, for accountability and transparency.

  6. Retention and Disposal of Security Camera Footage

    • 6.1 The Library's security camera footage is subject to the following retention periods under the Library's records retention schedule:
      • Library security camera footage will be retained for a maximum of thirty (30) days from the date of the original creation and collection by the security camera system, except as described below; and
      • Library security camera footage used by the Library, including as part of a Rules of Conduct, safety, security, or law enforcement investigations, or for freedom of information or other evidentiary purposes, will be retained for a minimum of one (1) year from the conclusion of the matter for which it has been used.
    • 6.2 The Library will take all reasonable efforts to ensure the security of records in its control/custody and ensure their safe and secure disposal. Old storage devices must be disposed of in accordance with an applicable technology asset disposal process ensuring personal information is erased prior to disposal and cannot be retrieved or reconstructed. Disposal methods may include shredding, burning, or erasing depending on the type of storage device.
    • 6.3 Any Library employee who becomes aware of any unauthorized use or disclosure of footage has a responsibility to ensure that Policy, Planning and Performance Management is immediately informed of the privacy breach.

Accountability

The Director, Enterprise Projects & Facility Management, Director, Branch Operations & Customer Experience and Director, Policy, Planning & Performance Management are accountable for implementation of this Policy.

Related Legislation

  • Municipal Freedom of Information and Protection of Privacy Act (MFIPPA), RS.O. 1990, c. M. 56
  • Occupational Health and Safety Act, R.S.O. 1990 c.0.1
  • Guidelines for Using Video Surveillance, Information and Privacy Commissioner of Ontario. 2015.

Definitions

Accessibility:
Refers to the absence of barriers that prevent individuals and/or groups from fully participating in all aspects of society. The term is often linked to people with disabilities and their rights to access goods, services, employment opportunities, and facilities.
Library User: 
Includes anyone who uses the Library's spaces, e.g., Library customers, Library staff, volunteers, or service providers.
Personal Information:
Recorded information about an identifiable individual, including,
  1. information relating to the race, national or ethnic origin, colour, religion, age, sex, sexual orientation or marital or family status of the individual,
  2. information relating to the education or the medical, psychiatric, psychological, criminal or employment history of the individual or information relating to financial transactions in which the individual has been involved,
  3. any identifying number, symbol or other particular assigned to the individual,
  4. the address, telephone number, fingerprints or blood type of the individual,
  5. the personal opinions or views of the individual except if they relate to another individual,
  6. correspondence sent to an institution by the individual that is implicitly or explicitly of a private or confidential nature, and replies to that correspondence that would reveal the contents of the original correspondence,
  7. the views or opinions of another individual about the individual, and
  8. the individual's name if it appears with other personal information relating to the individual or where the disclosure of the name would reveal other personal information about the individual.

Contact

Director, Enterprise Projects & Facilities Management

Print this page