Letter of finding regarding the video surveillance issue
The federal Privacy Commissioner investigated a complaint regarding Centurion Security Services' installation of surveillance cameras at a downtown Yellowknife intersection. The Commissioner found that both live and recorded video images of individuals constitute "personal information" under PIPEDA. Centurion Security Services, a private company, was monitoring public spaces for commercial purposes without the consent of individuals, which contravened Principle 4.3 of Schedule 1 and section 5(1) of the Act. Although the cameras were removed before the complaint was received, the Commissioner concluded that Centurion's intended future public video surveillance for commercial purposes would also be unlawful. The complaint was found to be well-founded.
- 1Whether the subject matter falls within the Commissioner's jurisdiction under PIPEDA
- 2Whether live video pictures of individuals constitute "personal information" under section 2 of PIPEDA
- 3Whether the collection of personal information was in the course of a commercial activity under section 4 of PIPEDA
- 4Whether Centurion Security Services collected personal information without consent in contravention of Principle 4.3 of Schedule 1 of PIPEDA
- 5Whether the absence of recording (live feed only) affects the classification of information as personal information or the requirement for consent
- Definition of personal information: Live and recorded video images are personal information
- Consent for collection: Collection without consent contravened PIPEDA
- Lawfulness of future surveillance: Intended future surveillance would be unlawful
- Complaint outcome: Complaint well-founded
Complaint well-founded — future unlawful activity prevented
The Commissioner found that live video feeds of identifiable individuals constitute personal information collected in the course of a commercial activity, requiring consent under PIPEDA. Centurion Security Services failed to obtain this consent, and its proposed future surveillance activities were also deemed unlawful.
The Commissioner informed Centurion Security Services that its intended public video surveillance for commercial purposes is unlawful and cannot be pursued.
- s.2 PIPEDA
- s.4 PIPEDA
- s.5(1) PIPEDA
- Principle 4.3 PIPEDA
This summary is informational only and not legal advice.
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