Video Surveillance Policy

1. General Obligations

1. 1. Encorp Pacific (Canada) (“Encorp” or the “Company”) may collect, use or disclose video surveillance to provide for and monitor the security and safety of its Express & Go Outlets and Express Plus Locations, set out in Appendix “A”, and the users of the Express & Go Outlets and Express Plus Locations. Encorp may also collect, use or disclose video surveillance to conduct investigations.
   2. Any video surveillance conducted by Encorp will be reasonable, with particular reference to the rights and obligations created by the British Columbia Personal Information Protection Act (“PIPA”).
   3. Encorp shall limit its use and disclosure of personal information collected by way of video surveillance to the purposes specified in this Policy, or as required by law.
   4. Encorp’s Privacy Policy applies to this Video Surveillance Policy. The identity of the Privacy Officer and the process for seeking further information or making a complaint is addressed in the Privacy Policy, along with more general obligations of Encorp in respect of the collection, use, disclosure and security of Express users’ personal information.
2. Terms of Surveillance Policy 
   1. Encorp currently conducts video surveillance at the locations of its Express & Go Outlets and Express Plus Locations, following the procedures set out in this Policy, including creating the necessary documentation, as is reasonable in the circumstances:
      1. designating a person(s) to be in charge of the surveillance system, including in relation to Encorp’s privacy obligations under PIPA;
      2. specifying the location of the recording equipment;
      3. specifying the location of the reception equipment (i.e., the location where visual or other signals received through the surveillance system will be monitored);
      4. indicating the times when surveillance will be in effect;
      5. specifying whether the surveillance system will be monitored on an intermittent basis, or on a reactive basis in response to reported incidents;
      6. indicating whether the surveillance will be conducted in a surreptitious or non-surreptitious manner; and
      7. following the provisions relating to Surveillance Records that are set out in this Policy.
3. Non-Surreptitious Surveillance
   1. Encorp has signage posted in conspicuous locations at the Express & Go Outlets and Express Plus Locations indicating the use of video surveillance cameras. The signage will indicate that surveillance footage may be monitored and turned over to security, Encorp, or law enforcement for investigative purposes. The signage will also provide contact information for the person who can answer questions and provide further information about the video surveillance system and its use.
   2. The closed-circuit video surveillance cameras are visible to individuals. There are cameras at the Express & Go Outlet and Express Plus locations throughout British Columbia, the number of which vary depending on the location. Video surveillance will be active for specified hours depending on the location, as set out in Appendix “A”.  The cameras are set to activate and record footage only when there is activity in the designated area through motion detection. The camera will deactivate once the motion is discontinued.
   3. The surveillance system does not record audio but only images, as described herein.
   4. The recording equipment of any non-surreptitious surveillance system shall not be positioned so as to monitor areas where individuals have a reasonable expectation of privacy, including without limitation, washroom facilities or near health clinics. The cameras are not trained on any particular work area but may collect personal information about third parties’ employees during the course of their workday.
   5. Video surveillance will only be used for the following purposes:
      1. to enhance the security of the premises, Company assets, and equipment at the Express & Go Outlets and Express Plus locations;
      2. to enhance the safety of users of the Express & Go Outlets and Express Plus locations;
      3. to be used as evidence in any incident, unlawful activity or complaints that arise at an Express & Go Outlet or Express Plus location; and
      4. to be used as evidence in any investigations carried out by Encorp that arise pursuant to user or employee activity at an Express & Go Outlet or Express Plus location.
   6. Encorp shall not use surreptitious surveillance at its Express & Go Outlet or Express Plus locations.
4. Surveillance Records
   
   1. “Surveillance Record” includes, without limitation, a closed-circuit video, linked to a DVR (Digital Video Recorder). Real-time access to view images from cameras will be limited to SecurCo Services Inc. (“SecurCo Services”), a third-party commercial security company.
   2. The Surveillance Record is maintained within a Digital Video Recorder (“DVR”) hard drive, which can only be accessed by SecurCo Services. The system automatically overwrites 30 days after the event. Access to the DVR hard drive is limited to SecurCo Services, unless it is required for evidentiary purposes, in which case it or a Surveillance Record may be disclosed to Encorp pursuant to this Policy.
   3. A Surveillance Record may be retained by Encorp if there are reasonable grounds to believe that the Surveillance Record identifies a contravention of the laws of British Columbia or Canada, or is otherwise necessary for an investigation, or is otherwise subject to be retained pursuant to a request by a regulatory or other law enforcement body.
   4. Access to a Surveillance Record will be limited to only those individuals authorized by Encorp who have a need to access a Surveillance Record in accordance with this Policy and applicable law.
   5. Where personal information contained in a Surveillance Record is used to make a decision about an individual, that Surveillance Record shall be retained for a period of at least one year after the decision is made.
   6. Where a Surveillance Record is required for evidentiary purposes, it shall be retained and stored by Encorp in a secure manner according to standard procedures until requested by the relevant authority, at which time a Surveillance Record release form shall be completed that indicates:
      1. the identity of the individual to whom the Surveillance Record was disclosed;
      2. the authority pursuant to which the Surveillance Record was disclosed;
      3. the date of disclosure; and
      4. whether the Surveillance Record will be destroyed by the authority or returned to Encorp after use.
   7. Each Surveillance Record shall be numbered and dated appropriately.
   8. Encorp shall maintain a log of all instances of disclosure of the Surveillance Record to a third party.
   9. Encorp shall, upon receipt of a written request from an individual who is the subject of surveillance, comply with PIPA in providing that individual with access to his or her recorded personal information.
   10. Once its retention is no longer necessary for a business or legal purpose, each Surveillance Record shall be disposed of in a secure manner, which may involve shredding, burning, or magnetically erasing such record, depending on the nature of the storage media at issue in each case.
5. Agreement with Service Provider 

1. 1. Encorp has entered into an agreement with SecurCo Services which requires SecurCo Services to ensure that:
      1. all video surveillance at the Express & Go Outlet and Express Plus locations is conducted in accordance with this Policy and applicable law;
      2. the DVR hard drive is stored in a secure environment and accessed only by authorized individuals who are trained on the relevant privacy obligations under this Policy and applicable law; and
      3. video surveillance footage is only monitored or reviewed as required to support Encorp’s legitimate business, safety, or security interests, to further an investigation, or as permitted or required by law.

APPENDIX “A”