TOWNSHIP OF ESQUIMALT STAFF REPORT
MEETING DATE: November 3, 2025 Report No. ADM-25-057
TO: Council
FROM: Deb Hopkins, Director of Corporate Services
SUBJECT: Rescind Council Policy ADMIN-76 Video Surveillance
RECOMMENDATION:
Recommendation
That Council rescind Policy ADMIN-76 Video Surveillance.
Body
EXECUTIVE SUMMARY:
Staff are seeking Council’s approval to reclassify Council Policy ADMIN-76 Video Surveillance as Management Policy M-ADM-16 Video Surveillance Systems. This reclassification will improve organizational agility and responsiveness by enabling staff to make required policy changes without requiring Council approval given that significant oversight rests with the Freedom of Information and Protection of Privacy Act (FIPPA) and the Office of the Information and Privacy Commissioner for British Columbia (OIPC). To facilitate this Council is requested to consider rescinding Council Policy ADMIN-76 Video Surveillance.
BACKGROUND:
Video surveillance is one of the most effective methods of keeping Township facilities and assets operating in a manner that protects public safety, security, and privacy. Public bodies using this tool are required to establish organizational policies outlining procedures, acceptable use, and roles and responsibilities under the Freedom of Information and Protection of Privacy Act (FIPPA). Council Policy ADMIN-6 Video Surveillance provides for the safety and security of Township staff, clients, visitors, facilities, and assets while balancing the privacy rights of individuals. Under FIPPA, this policy must be subject to regular review to ensure continued compliance with FIPPA and best practices as informed by the Office of the Information and Privacy Commissioner for British Columbia (OIPC).
ANALYSIS:
Council Policy ADMIN-76 Video Surveillance requires changes as a part of the work underway to modernize and identify efficiencies to Esquimalt’s Privacy Management Program. Video surveillance is a privacy-related activity, and the policy was identified as outdated. The policy is predominantly operational in nature and requires frequent updates as technology, AI, public expectation, and legislation continue to evolve. Since the policy’s inception six years ago, legislative changes have resulted in four policy amendments that required Council attention and approval.
The Township of Esquimalt utilizes video surveillance in accordance with the privacy provisions of the Freedom of Information and Protection of Privacy Act (FIPPA). The Township must maintain an up-to-date policy to remain compliant and set requirements and permitted use of video surveillance to balance safety and security with the privacy rights of individuals in areas where surveillance is utilized. The current Council Policy ADMIN-76 (Attachment 1) does not conform to best practices outlined by the Office of the Information and Privacy Commissioner for British Columbia (OIPC) and is not reflective of updated provisions to FIPPA. Further amendments to the policy are necessary to continue utilizing this method of security and protection within the Township.
This policy, as currently established, requires Council approval prior to implementing any required changes. This is the fourth required amendment resulting from legislative changes since the policy’s inception six years ago. Each amendment requires administrative work and Council meeting time for this policy that outlines operational roles and responsibilities. Each time that a Council Policy requires amendments, staff must bring forward a report and proposed amendments to Council for approval. This process places an unnecessary burden on Council who should be relying on staff expertise to ensure continued compliance with the regulatory framework.
There is significant oversight for video surveillance both through FIPPA and the OIPC. Staff must complete a detailed Privacy Impact Assessment (PIA) prior to video surveillance system deployment, replacement, upgrade, or other substantial change. A PIA is a mandatory assessment conducted by municipal staff to determine whether a current or proposed project, program, initiative, or activity that involves the collection of personal information meets or will meet the privacy requirements as set out in FIPPA. Each PIA goes through a robust review process that includes several municipal staff, including the Privacy Officer, prior to receiving final approval. The public can ask questions about the collection of personal information, submit complaints to staff, or file a complaint for non-compliance with FIPPA with the OIPC for potential investigation.
Acknowledging the operational nature of the Video Surveillance Policy, the comprehensive legislative oversight already in place, and the anticipated administrative efficiencies, staff are requesting Council’s authorization to rescind Policy ADMIN-76 Video Surveillance. Once the Council policy is rescinded, it will be immediately replaced by Management Policy M-ADM-16 Video Surveillance Systems (Attachment 2) that is more reflective of current regulatory requirements.
OPTIONS:
1. That Council rescind Policy ADMIN-76 Video Surveillance. [Recommended]
2. That Council request additional information from staff.
3. That Council receive Staff Report No. ADM-25-057 for information.
COUNCIL PRIORITY:
Good Governance and Organizational Excellence
FINANCIAL IMPACT:
There are no significant financial implications associated with rescinding Council Policy ADMIN-76 Video Surveillance and replacing with Management Policy M-ADM-16 Video Surveillance. There may be minimal costs associated with updating signage in program areas where video surveillance is in effect to meet the requirements of the Freedom of Information and Protection of Privacy Act.
COMMUNICATIONS/ENGAGEMENT:
Should Council rescind Policy ADMIN-76, staff will ensure distribution of the revised Management Policy M-ADM-16 to municipal staff and work with business units to update the signage in areas under video surveillance and update the Township’s website.
TIMELINES & NEXT STEPS:
Next steps include replacing signage in areas under video surveillance to comply with the provisions of FIPPA as outlined in Policy M-ADM-16.
This policy will be subject to regular ongoing review and will be updated as required.
REPORT REVIEWED BY:
1. Ian Irvine, Director of Finance, Reviewed
2. Dan Horan, Chief Administrative Officer, Concurrence
LIST OF ATTACHMENTS:
1. Council Policy ADMIN-76 Video Surveillance
2. Draft Management Policy M-ADM-16 Video Surveillance Systems