Video visitation

Privacy impact assessment (PIA) summary

Introduction

A PIA has been conducted on video visitation, a video communication national pilot. The purpose of the assessment is to:

• determine if there are any privacy issues associated with the initiative, and
• provide recommendations for their mitigation or resolution.

Proposal description

Video visitation is a video communication initiative (national pilot) used by CSC that provides inmates incarcerated at all federal institutions with another means of interacting with their family, friends, and community ties. While CSC policy supports in-person visits and correspondence, some are not able to visit regularly due to a number of factors.

Video visitation aims to give all inmates another way to communicate with their visitors if required, that is consistent with the principle of protection of the public, staff members, and inmates.

Taking an iterative approach, CSC has tested local small-scale solutions in Atlantic and Ontario Regions as a means to test assumptions live in an operational setting.

The application of video visitation in correctional settings is well established across jurisdictions. Examples of benefits realized by offering a video visitation model include:

• improved security and safety
• reduction in the amount of contraband entering a facility
• reduction in staffing requirement for the in-person visits process, and
• improved visitation efficiencies (more frequent visitations, accessibility to contacts who may not be able to visit in-person)

The technology is utilized extensively in the United States corrections market, and has been adopted internationally. In Canada, the Edmonton Remand Centre that went operational in 2013 utilizes video visitation exclusively with no in-person visitation.

The proposed project is to implement a video visitation solution at institutions across the country. Implementation will be performed using a corporate PC (CED) connected to a WebEx account. WebEx is a "Skye-type" service currently provided by the Government Telecommunications Service of Shared Services Canada to all Government of Canada departments. WebEx maintains an internal log. The events in the log include a description of the activity/action that triggered the event and captures information such as the name, email and IP address of the person accessing the system and the call duration. At the institution, a staff member initiates the session and ensures a connection is established. The offender will not have access to the keyboard/mouse or CPU. They will be able to:

• view the video on the monitor
• speak into the headset/microphone, and
• be seen via webcam

The video visitation kiosk will be logged in to the corporate network via a generic account (auto logged in) that has no privileges to corporate drives, email, or other assets. Monitoring of the session can be carried out on a separate CED computer by joining the call and muting the camera/audio.

Each institution will have its own standing order that will outline the process and guidelines for video visitation. Visitors must be an approved visitor for the inmate, pursuant to Commissioner's Directive 559 Visits, and have completed the Visiting Application form. While priority will be given to visitors who meet the criteria outlined in the standing order, the institutional head may authorize a video visit for a visitor who does not meet such criteria, in exceptional circumstances.

Collection, use, disclosure and retention of personal information

The Corrections and Conditional Release Act (CCRA) provides CSC with the authorization to collect personal information for the purpose of authorizing visits. Section 71(1) of CCRA states that:

to promote relationships between inmates and the community, an inmate is entitled to have reasonable contact, including visits and correspondence, with family, friends and other persons from outside the penitentiary, subject to such reasonable limits as are prescribed for protecting the security of the penitentiary or the safety of persons.

Therefore, CSC is authorized to establish programs to allow contact between inmates and their family, friends, and other persons.

Visits and Correspondence records are retained until the offender reaches 70 years of age or until five years after the last warrant expiry date, whichever is longest. Historical records are transferred to Library and Archives Canada.

Personal information concerning visitors is collected directly from the individuals via a Visiting Application Form (CSC 0653). This also applies to video visitation, as the individual must be an approved visitor. The inmate is also required to submit an Inmate Application for Video Visitation, which will contain the personal information of the visitor, for approval. The visitor is made aware of the purpose for the collecting of personal information and that the information will be used to determine their eligibility to receive authorization to participate in video visitation with the inmate. The Inmate Application for Video Visitation contains a Privacy Act statement that outlines the authorities for interception. The email provided to visitors following approval of a video visit provides a notice as per the recording services of WebEx, and the instructions that have been issued to staff in regards to the recording of video visits. CSC has instructed staff not to use the recording feature at this time.

In accordance with section 8(2)(j) of the Privacy Act, the offender's personal information may be used for research and statistical purposes; however, all personal identifiers will be removed to ensure the anonymity of the individual.