BC Freedom of Information and Privacy Association
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The Council of the Town of Greater Napanee has approved an updated policy governing the municipality’s Closed-Circuit Television (CCTV) surveillance system following the expansion of its public-space security camera network.
The revised policy was presented to Council on Tuesday, Mar. 11, 2026, by Chief Administrative Officer (CAO) Matthew Grant, who said the changes reflect the growth of the Town’s camera program and clarify how video footage may be used while ensuring compliance with provincial privacy legislation.
Council previously partnered with the Ontario Provincial Police (OPP) to expand the camera network from 12 locations to approximately 48 across the community.
Grant said the system has operated as a pilot project for the past year and a half.
“After a period of a pilot project of approximately 18 months, with lots of views, lots of learning, and lots of collaboration with our partners at the OPP, we think that we are in a position to upgrade that policy now,” Grant told Council.
The updated policy outlines how the cameras may be used, who can access recorded footage, and how video records may be shared with police.
Grant said the policy must comply with Ontario’s Municipal Freedom of Information and Protection of Privacy Act (MFIPPA), the provincial law that governs how municipalities collect, store, and share personal information.
Under the legislation, video footage that captures “someone’s likeness,” Grant said — that is, an identifiable person — is legally considered a record containing personal information. Because of that designation, municipalities must treat video recordings with the same level of care as other sensitive records — “the same way we would someone’s banking records or other personal information,” Grant explained.
The policy confirms that the cameras are placed in public spaces and are positioned to avoid capturing private residences whenever possible.
Although people generally have a lower expectation of privacy in public spaces, the municipality must still manage recorded images in accordance with privacy legislation.
The policy also states that the Town does not intend to use facial recognition technology as part of the CCTV program. Grant said any future consideration of facial recognition would require a privacy impact assessment and a separate decision by Council.
The revised policy also clarifies how video footage can be provided to police.
Grant explained that MFIPPA allows municipalities to share existing recordings with law enforcement in certain circumstances without a warrant, including when police are conducting a specific investigation.
However, the legislation does not allow municipalities to provide police with live access to the cameras.
“Law enforcement is not named in the legislation as an entity allowed to operate municipal cameras,” Grant noted. Instead, police must request recorded footage connected to a specific investigation.
“The municipality should support law enforcement with these cameras as far as legislation permits — and no further,” Grant said.
The limits prompted some discussion among councillors about how the cameras could be used in urgent situations.
Councillor Bill Martin said he believes privacy concerns should not prevent the use of cameras to assist police when public safety is at risk.
“If somebody commits a crime, then I think their privacy is done,” Martin said.
Grant acknowledged the concern but said the municipality must operate within the legal limits set by provincial legislation.
“If legislation changes in a way that allows us to assist law enforcement more directly, we would certainly bring that back to Council,” he said.
Other councillors focused on how the system is managed and how long recordings are retained.
Councillor Angela Hicks noted that video footage is stored for a limited period: “The records are only kept for 30 days, and then they’re overwritten,” she said. “Nothing is stored indefinitely.”
Hicks added, “The cameras were a really good investment, and I think they do a lot.”
The updated policy also calls for additional signage to notify residents and visitors that CCTV cameras are operating in public areas.
Council voted to adopt the revised policy and approved the installation of additional notice signs as part of the program. The changes mean the Town’s expanded network of surveillance cameras will continue to operate under updated
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