Park Village Mobile Home Park was ordered to physically disable functional surveillance cameras capable of viewing areas two complaining residents could reasonably be expected to use, after a B.C. privacy adjudicator found that it had unlawfully collected their personal information. In Order P26-15, 2026 BCIPC 99, dated September 14, 2026, adjudicator Alexander Lonergan also required the park to delete the complainants’ existing information collected through its surveillance system.
The Office of the Information and Privacy Commissioner for British Columbia found that three functioning cameras had recorded the residents and their activities. The residents had repeatedly objected, and neither a statutory exception nor deemed consent authorized the collection under the Personal Information Protection Act, or PIPA.
Recording extended beyond claimed monitoring zones
The two complainants, whose names are not given in the order, owned their manufactured home and rented the lot beneath it. In early 2025, Park Village told them it planned to install surveillance cameras. They asked the landlord not to record their home, lot, vehicles or visitors and sought information about the proposed system.
Park Village acknowledged operating three cameras capable of recording video, alongside non-recording dummy devices. It said the functioning cameras monitored common areas, including an access road and septic field, rather than the complainants’ lot. It described a system that detected motion, tracked it and saved short video recordings for up to 60 days.
Lonergan found that the areas identified by Park Village as triggering a recording did not describe the cameras’ full fields of view or what they actually recorded. The landlord’s own sample footage and the residents’ photographs supported the finding that cameras viewed areas used by the complainants and their visitors. Time-stamped photographs also showed one camera changing direction.
On the evidence as a whole, he concluded that the three cameras had recorded the complainants in and around their home and while entering or leaving the park. He found collection was continuing at the time of the inquiry because the cameras had not been removed or disabled.
The dummy cameras were treated differently. Nothing in the evidence established that those devices could record audio or video, so Lonergan accepted that they were not collecting personal information.
Living at home was not consent
Lonergan found that Park Village was a corporation and therefore an organization subject to PIPA. Section 6 generally prohibits an organization from collecting personal information unless the individual consents, the Act authorizes collection without consent, or the Act deems consent to have been given.
The complainants’ consistent objections ruled out actual consent. Their continued use of monitored areas did not establish agreement either: they could not avoid their home or the access road the park required them to use to reach it. Knowingly entering those areas was not voluntary acceptance of surveillance.
Park Village offered purposes including insurance, wildlife management, road-maintenance monitoring, septic-system monitoring and well-water monitoring. It did not explain those purposes in detail or identify a legal provision authorizing collection without consent. After considering section 12’s exceptions, Lonergan found that none covered the collection on this record.
The landlord also could not rely on the deemed-consent provisions in section 8. One route requires an obvious purpose and voluntary provision of information. Lonergan found the stated purposes vague and not obvious from the camera installation, while the residents had no practical choice about using the monitored areas. A separate insurance-related provision did not apply because the park had not established that the complainants were beneficiaries or insured persons under a relevant plan, policy or contract.
Stickers did not cure the consent problem
Park Village pointed to camera stickers and its advance emails as notice of the system. But Lonergan found that the stickers showed, at most, that cameras were nearby; the park had not established that they explained the purposes of collection in an understandable way. Its email about protecting its property and interests was also too vague.
The notice-based deemed-consent route also requires a reasonable opportunity to decline collection, followed by the individual not declining within the allowed time. Park Village had communicated a firm decision, not an opportunity to opt out. The complainants had, in any event, promptly objected.
Those failures were sufficient to defeat deemed consent. Lonergan did not need to decide the additional requirement that collection be reasonable considering the information’s sensitivity.
Physical disabling, deletion and confirmation
Because the cameras could turn remotely and use automated motion tracking, Lonergan required physical disabling rather than reliance on software settings. The order covered all functioning cameras capable of viewing areas either complainant might reasonably access. That included cameras physically capable of turning toward those areas even if software prevented automatic turning, and expressly included the three cameras examined in the decision.
The park was also ordered to stop collecting the complainants’ information through the system, delete all existing information about them obtained that way, and confirm compliance to both the OIPC’s registrar of inquiries and the complainants. The order set October 28, 2026 as the compliance deadline.
The adjudicator did not award compensation or require apologies or fencing, finding those remedies outside his authority under PIPA. He also declined to decide the landlord’s separate allegations about the complainants’ own cameras, which were outside the issues admitted to this inquiry.
