Recording meetings using Microsoft Teams or other applications
Employees are staying connected and collaborating using Microsoft Teams and other applications. However, the recording function in these applications must not be used without first notifying, and receiving consent from, all meeting participants.
Recording meetings, in Microsoft Teams, Skype for Business, Cisco WebEx or other applications raises important concerns including access to information and privacy issues:
- A recorded meeting is considered a "record" under the Access to Information Act (ATIA), and, if personal information was discussed or otherwise made known, the recording would likely be subject to the Privacy Act as well. Under the ATIA, a record means any documentary material, regardless of medium or form.
- Any sensitive information discussed in the recorded meeting, such as legal advice and protected or classified information, would be subject to review by Access to Information and Privacy (ATIP) to ascertain whether any of the recording would be protected.
- A recorded meeting would likely capture incidental personal information about any individual who is referenced by any of the participants during the meeting.
- The department would be required by legislation and by policy to retain a recorded meeting on file for a certain period of time.
- It follows, then, that an ATIP request for the record of the meeting could make the recording subject to release.
Exceptional cases, such as official AAFC training sessions, may be exempted with the approval of an assistant deputy minister. In such cases, all participants must be notified in advance that a recording will be made. For participants who do not consent to the recording, another option must be made available such as viewing the recorded training at a later time.
For more considerations and best practices for using videoconferencing services, see the Office of the Privacy Commissioner of Canada's published blog post: Videoconferencing – Maintain your physical distance, but keep your personal information close.
For further guidance please contact ATIP for advice by email at firstname.lastname@example.org.
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