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Canadian privacy & access decisions

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Federal (Canada)Personal Information Protection and Electronic Documents ActWell-founded
Federal (Canada) flag
Jun 15, 2001Indexed Jun 30, 2026

Letter of finding regarding the video surveillance issue

Centurion Security Services Co. Ltd.

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.

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Personal Information Protection and Electronic Documents ActWell-founded

Letter of finding regarding the video surveillance issue

Jun 15, 2001
Adjudicator: George Radwanski
Plain-Language Summary

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.

Key Issues
  • Whether the subject matter falls within the Commissioner's jurisdiction under PIPEDA
  • Whether live video pictures of individuals constitute "personal information" under section 2 of PIPEDA
  • Whether the collection of personal information was in the course of a commercial activity under section 4 of PIPEDA
  • Whether Centurion Security Services collected personal information without consent in contravention of Principle 4.3 of Schedule 1 of PIPEDA
  • Whether the absence of recording (live feed only) affects the classification of information as personal information or the requirement for consent