Body Worn Camera (BWC) and Digital Evidence Management Service (DEMS)

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• Description of program or activity
• Why a PIA was conducted
• Scope of PIA
• Results of PIA
• More information

Description of program or activity

In 2020, through its Fall Economic Statement, the Government of Canada announced funding for the implementation of a National BWC Program for the RCMP. As part of the Program, the RCMP plans to deploy up to 15,000 BWCs to frontline officers in support of contract and federal policing. Once fully implemented, the Program will see all RCMP officers who interact with the public equipped with a BWC while on duty. BWCs will be used overtly and in plain sight to capture audio and visual recordings of interactions and incidents between uniformed police officers and members of the public.

Why a PIA was conducted

The RCMP is named in the Schedule to the Privacy Act and is subject to the privacy policies and directives of the Treasury Board of Canada Secretariat (TBS). Under the TBS Policy on Privacy Protection, all federal institutions subject to the Privacy Act are required to undertake an assessment of the privacy impacts associated with the development or design of new programs or services involving personal information (or when making significant changes to an existing program or service).

The purpose of the PIA was to help ensure that the RCMP operates its BWCs in a privacy sensitive manner. The PIA report serves as a record of the RCMP's consideration of privacy matters related to the use of BWCs for general duty policing and as an assessment of controls adopted by the RCMP to help ensure that its BWC and DEMS Service complies with the federal Privacy Act.

Scope of PIA

The PIA included a review of the lifecycle of personal information collected through BWCs and an assessment of core features and functionality of the RCMP's BWC and DEMS Service. It also included a review of policies, practices, and processes adopted by the RCMP in support of the implementation of its National BWC Program. This includes protocols relating to the activation and de-activation of BWCs, standards for recording in sensitive situations, rules governing access to video recordings, and processes for informal viewings, video management and uploading, video redaction and deletion, evidence storage, and retention.

Results of PIA

Most privacy issues identified in the PIA process have been addressed by the RCMP. Risk mitigation measures, implemented prior to the Program's launch and monitored on an ongoing basis, are expected to reduce the Program's overall privacy risk to a low or acceptable level. Key findings and results from the PIA are summarized below:

• Proper Authority: The RCMP has established the legal authorities under which the Program can be deployed and will limit its planned use of BWCs (and all associated collections of personal information) to requirements under the Privacy Act and Charter.
• Clear Accountability: The RCMP has designated senior-level individuals accountable for the Program and established clear expectations and responsibilities for the proper use of the BWC and DEMS Service by its members.
• Good Governance: The RCMP has developed a comprehensive policy and robust governance framework to guide and support the use of the BWC and DEMS Service and to guide the proper collection, use, disclosure, and retention of personal information.
• Openness and Transparency: The RCMP has been open and transparent about the Program and its implementation, and has made specific information about its policies and practices relating to the management of personal information publicly available.
• Proper Notification: The RCMP has developed operational policies and protocols to guide members on how to inform individuals of the use of the BWCs, and issued public notices about the use of BWCs and their recording of police-public interactions in affected communities. Notifications include both verbal and visual prompts, and extensive communications materials.
• Limited Use: The RCMP will only use BWCs to document officers' interactions with members of the public during the execution of their law enforcement duties, and for training purposes. BWCs will not be hidden or used covertly, or deployed for general surveillance.
• Limited Collection: The RCMP will restrict the use of BWCs in private and sensitive settings where there is a heightened expectation of privacy. The use of BWCs in private dwellings, healthcare facilities, spiritual spaces, and places of worship is only permitted with an individual's consent or in exigent circumstances.
• Limited Disclosure: The RCMP has established limits on the sharing of BWVs to limit disclosures to those permitted by law. This includes policies and procedures to support the limited disclosure of BWVs proactively in the public interest, and the disclosure of recordings as evidence to the Crown.
• Limited Retention: The RCMP has established clear retention periods for BWVs. Retention periods are sufficiently long to facilitate an individual's right of access to recordings, and reasonably short so as not to retain recordings of little to no business value for longer than needed.
• Secure Storage: Access to BWCs and BWVs will be highly restricted and monitored. All recordings will be encrypted at rest, during transit, and while stored in third-party systems. The secure storage and transmission of BWVs is supported by enterprise policies and procedures, and all employees will be trained on data security and protection measures. The primary mechanism to transfer data will be via a secure link. Should it be necessary to use portable storage devices to support the transfer of BWVs to authorized officials and partner agencies - all storage devices used will be encrypted and password protected. In all such instances, the use of USB keys to transfer BWVs will comply with the RCMP and Government of Canada's guidelines and policies pertaining to portable storage devices. Of note, the RCMP created a working group at the Director General level to examine the use of USB keys within the RCMP propose safer storage options and alternatives where feasible. The RCMP will continue to prioritize DEMS to DEMS transfers, whereby information is shared with law enforcement partners and the Crown through a secure on-line channel only.
• Public Access to Information: The RCMP has developed policies and procedures to respond to requests for access to BWVs and an informal process to allow members of the public to view BWVs of themselves with a view to promoting the early resolution of public complaints. RCMP ATIP will receive specialized training and tools to support the timely review and redaction of BWVs. ATIP resources will be re-assessed and re-aligned where necessary to ensure that the RCMP meets its statutory duties.

More information

If you would like more information about this PIA, contact:

• Access to Information and Privacy Branch (Privacy Management Division)
• RCMP MAILSTOP #61, 73 Leikin Drive, Ottawa, Ontario K1A 0R2
• Telephone: 613-843-6800
• atippolicy_politiqueaiprp@rcmp-grc.gc.ca