TTC Fare Evasion Ad Campaign Violates its own Video Recording Policy

“Do you…what is your question exactly?”

I could sense the unease on the other end of the line.

“Well my main question is, is the TTC fare evasion ad campaign in compliance with the TTC Video Recording Policy?”

A series of stammers ensued.

“Well uh…uhm…well footage can be used for security and evidentiary purposes, so I would…argue that it falls under that.”

That was a phone conversation I had with a Toronto Transit Commission (TTC) official from the Video Surveillance unit of the Transit Enforcement department.

My conversation with the official confirmed what I suspected; that the TTC itself isn’t even aware of the fact that it’s recent fare evasion ad campaign violates its own video recording policy.

The ad campaign, which was launched less than a month ago, includes a series of posters, images and videos displayed online, on vehicles and at stations featuring actual footage of people caught in the act of fare evasion.

One video posted on the TTC Youtube channel shows an elderly man climbing over the presto fare gates at the entrance of a subway station. Other videos and video stills show a man tailgating behind a woman as she passes through a set of presto gates.

The faces of the individuals featured in these videos and images are largely blurred out, but that doesn’t neutralize the breach of the TTC’s own video recording policy, not to mention the ethical problems with publicly shaming individuals for evading one of the most expensive transit fares in the world, in a city where thousands of people struggle daily to cover basic expenses like food and rent.

According to the TTC website, the TTC Video Recording Policy “recognizes the need to balance an individual’s right to privacy and the need to ensure the safety and security of TTC employees, customers and property. While video recording cameras are installed for criminal, safety, security and evidentiary reasons, the TTC’s video recording systems must also be designed to minimize privacy intrusion.”

The policy document goes on to note that “when recorded images from the cameras must be viewed for law enforcement or investigative reasons, this must only be completed by an individual(s) authorized by the DDM in a controlled area. Every reasonable attempt should be made to ensure that images are not viewable by other individuals.”

According to this policy document, these regulations apply to all TTC cameras and recording devices in public areas of the transit system, including the video cameras positioned at presto gate entrances – the cameras which captured the footage featured in the fare evasion ad campaign.

In other words, the footage and images that the TTC pledged it would take “every reasonable attempt” to ensure “are not viewable by others” are the same images currently being broadcasted all over the city and the web for all of the public to see.

The TTC official I spoke with improvised a feeble justification of the ad campaign, arguing that the use of footage in this case was legitimate as it constituted an example of use for “security or evidentiary purposes.”

This is of course patently false. These ad campaigns do not enhance the security of TTC customers or staff in any way, and may even endanger the individuals depicted in these ads whose identities could potentially be exposed. These images are also not being used as evidence in this context – this ad campaign has no bearing whatsoever on any criminal or judicial proceeding. The sole purpose of the footage used in this ad campaign is to publicly shame individuals and intimidate the public.

The disconnect between the TTCs Video Recording Policy and the fare evasion ad campaign represents a more fundamental disconnect between the TTC brand and TTC policies in practice. The video recording policy document frames surveillance activities as being fundamentally about “safety,” “security,” and “protection.” Similarly, the brand slogan of the Transit Enforcement department as shown on transit network posters and their web page declares “We’re serious about your safety.”

However, the recent fare evasion ad campaign and its blatant disregard for the TTCs own video recording policy seems to indicate that the TTC brand may be beginning to unravel. Ironically, in an attempt to publicly expose fare evaders, the TTC seems to have inadvertently exposed its own true identity. The contours of the face beneath the blurred out pixels of euphemistic language and paternalistic condescension can finally be made out, and I have to tell you, I don’t like what I see.

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