Security cameras help hotels deter theft, investigate incidents and protect staff. They also record guests, and in Canada that makes them a privacy matter. This guide covers where cameras belong, audio, signage, how long to keep footage and how to handle requests for it, based on guidance from the Office of the Privacy Commissioner of Canada (OPC).
This is general information, not legal advice. For a specific situation, talk to a privacy lawyer.
Which Rules Apply to Ontario Hotels?
Private businesses in Ontario that collect personal information in the course of commercial activity, including video of identifiable people, are generally covered by the federal Personal Information Protection and Electronic Documents Act (PIPEDA). The OPC’s OPC guidelines for overt video surveillance in the private sector set out how businesses should use cameras in publicly accessible areas. They do not cover covert surveillance or monitoring of employees, which have separate guidance.
Where Cameras Belong, and Where They Do Not
The OPC says surveillance should be used only where it is reasonable for a specific purpose, collect the minimum needed, and not be used where people have a much higher expectation of privacy, such as washrooms or treatment rooms.
| Usually reasonable in a hotel | Not appropriate |
|---|---|
| Entrances and exits | Guest rooms |
| Lobby and front desk | Washrooms and change rooms |
| Parking lots and garages | Spa or treatment rooms |
| Corridors and stairwells | Cameras that can see into rooms or windows |
| Back-of-house doors and loading areas | Areas outside your property, such as the street |
Aim cameras at what you need to protect, and make sure they cannot be adjusted to look into private spaces.
Should Hotel Cameras Record Audio?
Usually not. The OPC says sound should not be recorded unless there is a specific need, and it flags Criminal Code provisions on intercepting private communications. Most hotel camera systems should have audio turned off.
Signage
Post clear signs before people enter areas under surveillance, so they know cameras are in use. The OPC recommends signs include a contact person for questions or access requests. Put them at entrances, the lobby and parking areas.
How Long to Keep Footage
There is no single fixed number. The OPC says to keep recordings only as long as needed for their purpose, store them securely with access limited to a few authorized people, and destroy them securely when no longer needed. Many hotels set a short default period, with footage of an incident saved separately. Write your period into a policy and configure the recorder to match.
Requests for Footage
- Guests asking for their own footage: people have a right to access images of themselves. Before releasing a clip, hide other people’s identities, for example by blurring faces.
- Police requests: disclosure to law enforcement can be appropriate, for example after a vehicle break-in. Document every disclosure: who asked, why, what was provided and who approved it.
- Insurance and legal requests: route these through management and keep the same record.
Write a Short Camera Policy
The OPC recommends a written policy. A one-page version covers:
- Why cameras are used and which areas they cover
- Recording times and whether anyone watches live
- How long footage is kept and how it is deleted
- Who can view, export or delete footage
- How guest and police requests are handled and recorded
- Who is accountable for privacy (your privacy contact)
- A yearly review of whether each camera is still needed
Secure the Camera System Itself
A camera system is also a network device. Change default passwords, give each person their own login, keep firmware updated, put cameras on their own network, and avoid exposing the recorder directly to the internet. See our hotel security camera planning guide and hotel network design.
Frequently Asked Questions
Can hotels have security cameras in guest rooms?
No. Guest rooms, washrooms and similar spaces carry a high expectation of privacy, and the OPC says video surveillance is inappropriate in places like washrooms and treatment rooms.
Do hotel security cameras record audio?
They should not, in most cases. The OPC says sound should not be recorded unless there is a specific need, and recording private conversations raises Criminal Code concerns.
How long should a hotel keep camera footage?
Only as long as needed for its purpose. There is no single legal number; set a short default period in your policy and save incident footage separately.
Can a guest get a copy of footage of themselves?
Generally yes, people can access images of themselves. Other people in the footage should be masked or blurred before it is released.
Do we have to give footage to the police?
Disclosure to police can be appropriate, but it should be justified and documented. If you are unsure, ask for the request in writing and get legal advice.
Talk to AutoSecure
Planning new cameras or tidying up an old system? AutoSecure installs and manages hotel surveillance systems across Ontario, set up with privacy and security in mind. Call 226-476-3358 or book a free hotel technology assessment.