Legal Topics for Canadian Criminal Investigators
Henry Waldock, B.Sc., LL.B

Prisoner's Phone Calls

Henry Waldock
Last updated: 2013-11-07

Summary

Sometimes, prisoners use their phone privileges to talk about crimes they committed or plan to commit.  Sometimes they use the phones to commit offences.  Recordings of these conversations make great evidence, if you can get them.

Legislation and regulations in many Canadian jurisdictions authorize corrections officials to record the telephone calls of inmates of provincial institutions.

Some provinces adopted "passive monitoring" systems, which record all prisoners' phone calls (except privileged ones).  When a senior official learns of reasons to believe that particular phone calls pose a threat to the institution, or an inmate is committing crimes, the official may authorize someone to listen to the calls in question, and act on them.

Proving the recordings requires a witness who can explain how they were made.

Procedure

If you learn of a prisoner making telephone calls relating to crime, you should:

  1. Determine which legislation applies (provincial or federal).
  2. Ask the institution to preserve any relevant recordings (if they exist).
  3. Inform the institution why they should monitor the prisoner (best done in writing).
  4. If the institution will release the recordings and related information to you without warrant, find out what they need in order to comply with your request.
  5. If they won't release the recordings without warrant, then draft your application.
  6. Ask for the recordings and logs and records related to them.  These will provide useful data like times, dates, and phone numbers involved in the conversations.
  7. Identify the person who downloads the recordings from the monitoring system.  That person's a witness.

Because recording inmate telephone calls fills data storage devices quickly, institutions tend to destroy recorded conversations after a short time.  In BC it's around 30 days.

B.C. and Albertan Corrections officials won't release the recordings unless you get a search warrant.  But they may tell you orally what's in the recordings, without a warrant.

Expect institutional resistance.  Legislation and regulation generally prevents the authorities from listening to the conversations unless a senior official has "reasonable grounds to believe" that the recordings qualify for snooping.  Privacy concerns may limit what they can tell you.  Each jurisdiction has slightly different rules.

Grounds

Level of knowledge

Information in the recordings

Procedure

Articulable cause

Prisoner’s phone conversations contain discussion of the offence, but pose no risk to anyone.

Investigate more. Don’t try to get the recordings yet.  In order to preserve evidence, you might contact the institution to warn them of your interest in the recordings, and ask hem to preserve them.

Reasonable grounds to suspect that life is in imminent peril Listening to the recordings will protect the endangered persons.
Contact the Director of the institution and explain the peril.  Demand disclosure.
Legislation which empowers you includes s.487.11 of the Criminal Code
Legislation which authorizes disclosure includes public sector freedom of information act in your jurisdiction.  In B.C., it's the Freedom of Information and Protection of Privacy Act s.33.1(m) or (m.1)  For other jurisdictions, see this page.

Reasonable grounds to believe

Prisoner is involved in illegal activities, harassing or causing harm to others, or jeopardizing the safety, security or operation of the correctional centre.

Inform the Director of the institution (or the appropriate designated person) what information you have.  If possible, do it in writing.  Ask them to tell you if they have evidence of criminal offences.

Reasonable and probable grounds

Conversation on the ICCS system contains information relevant to an offence.

Search Warrant s.487
Production Order s.487.012

If you only suspect that a person of interest will discuss evidence with someone, this does not pose a risk to the public. In most situations, neither you or the Director have sufficient grounds to review recorded telephone conversations for such discussions. Do more investigation.

If you have reasonable and probable grounds to believe that the recordings already contain the information you want, then draft your search warrant (s.487) or productions order and apply to a J.P..

If you suspect that an inmate may

(i) become involved in illegal activities,

(ii) harass or  harm others, or

(iii) participate in an activity that may jeopardize the safety, security or operation of the correctional centre; or

(iv) breach a no-contact order

then you should warn the Director as soon as possible by providing any information you have in writing, like an ITO.  Explain what cooperation you need to react to these problems when they arise.  I strongly recommend communicating grounds in writing, in the expectation that a court will review whether the grounds justified an intrusion into privacy.

If you believe that the ICCS already recorded calls of interest, then send the institution a letter explaining why. Draft it like an Information to Obtain. Source your facts. Protect the identity of your confidential sources if possible. Focus your attention on public risks, like tampering with witnesses or evidence, or other threats.  Ask the institution to preserve the recordings -- they destroy recordings after 30 days.

The institution may permit you to listen to the recording, but they may not let you take a copy away with you.  But listening and taking notes should suffice for obtaining a warrant.

Facts to Investigate

In which institutions has your suspect been lodged? Who is/are the Director(s) of those institution(s)? (Get address, internal phone and FAX.) Try the Corrections website: BC; Alberta; Saskatchewan; Manitoba; Ontario; Quebec; Nova Scotia, New Brunswick. Ask them whether the inmate made calls from that institution.

Who are your suspect(s) associates? What phone numbers do they use?

Which witnesses will your suspect(s) be interested in affecting? What are their phone numbers?

What evidence will your suspect(s) want to destroy or tamper with?

Through which friends or acquaintances is your suspect(s) likely to make third party calls? What are their phone numbers?

Your suspect(s) may ask other inmates to lend their calling cards in order to evade telephone blocks. Which inmates’ cards will they borrow?

If witnesses already complain of threatening calls: What dates? What times? How long? What phone numbers?

Relevant Legislation & Recording Systems

Although I know about B.C.'s inmate call control system, I have little experience with the systems in other provinces.  Please email me if you know the mechanics of the systems in your jurisdiction.

Province
Legislation
Recording system
B.C.
Section 19 of the  Corrections Act expressly permits an "authorized person" to intercept, monitor or record inmate communication.  This may be done for a variety of situations: "involved in illegal activities, harassing or causing harm to others, or jeopardizing the safety, security or operation of the correctional centre".  But the act requires a high standard of belief ("reasonable grounds to believe").
Section 15 of the Corrections Act Regulations prohibits release of the recordings without "lawful authority".  Corrections authorities interpret this to mean police must get a warrant.  In my view, this is unnecessary, because s.33.2(i)(i) of the Freedom of Information and Protection of Privacy Act applies.
All calls recorded except calls made to privileged numbers.
Alberta
Section 14.4 of the Corrections Act authorizes the "director" of a correctional institution to record conversations.  The director may monitor conversations if there are reasonable grounds to believe that they contain evidence of offences (past or future), or affect victims or their families, or affect institutional security.
Sections 31-31.6 of the Correctional Institution Regulation sets out specific rules the institution must follow.
All calls recorded except calls made to privileged numbers.  Calls may not lawfully be retained no longer than 90 days without reason.
Saskatchewan
Section 56.1 of the Correctional Services Act authorizes recordings of telephone calls.  Sections 48-48.91 of the Correctional Services Administration, Discipline and Security Regulations govern the rules the institution must follow.  Section 48.91 permits disclosure of telephone conversations without warrant.
Calls may not lawfully be retained no longer than 90 days without reason.
Manitoba
S. 42 of the Correctional Services Act very generally authorizes interception of inmate communications on reasonable grounds.  s. 71 of the Correctional Services Regulation specifically authorizes interception of inmate telephone calls.  S. 56(5) of the regulations authorizes release of prisoner information if there is a security risk, danger to a person, or the information will identify an offender.  Arguably, s.44 of the Freedom of Information and Protection of Privacy Act may permit further disclosure of recordings which would assist law enforcement.

Ontario
S.17.1 of the General Regulation pursuant to the Ministry of Correctional Services Act empowers the Superintendent or designate to authorize in writing the recording of any inmate.  There must be reasonable grounds that the "conversations will contain evidence of an act that would jeopardize the security of the institution or the safety of any person".  S.10 of that Act seems to authorize disclosure to police.

Quebec
I found nothing in the legislation nor regulation regarding recording inmate telephone calls.

New Brunswick
Neither the Corrections Act nor the General Regulation discuss inmate communications.

PEI
Neither the Correctional Services Act and General Regulations discuss inmate telephone calls.

Nova Scotia
S.55 of the Correctional Services Act generally authorizes interception of inmate telephone communications, but s.60 of the Correctional Services Regulations spells out that the superintendent must have reasonable grounds to believe that that offender is involved in crime, harassment, bothering children, violating court orders, creating a security risk or public risk.

Newfoundland
Nothing in Newfoundland's Adult Corrections Act breathes a word about inmate communications.  I can't find any associated regulations either.

Nunavut
Neither the Corrections Act nor the Corrections Service Regulations discuss inmate communications.
Yukon
Section 17 of the Corrections Act and s.15 of the Corrections Regulation authorize recordings of inmate communications.

Northwest Territory
Neither the Corrections Act nor the Corrections Service Regulations discuss inmate communications.

Canada
Corrections and Conditional Release Act
s.94 of the Corrections and Conditional Release Regulations empowers the the institutional head or designate to intercept inmate communications if there are reasonable grounds to believe that doing so will produce evidence of criminal offences or institutional risk.
Inmates may call only telephone numbers which were pre-approved.  Their calls may be recorded.

B.C. & Alberta's Inmate Call Control Systems

In British Columbia and Albertan prisoners enter a Provincial correctional centre, they must sign a form which warns them that their calls “may be monitored or recorded”. In B.C., each prisoner receives a unique “CS number” (like an FPS number), which is recorded onto a phone card.

When the prisoner wants to make a call, he enters a phone booth over which stands a sign warning him again that calls “may be monitored or recorded”. When he picks up the hand set and inserts the card, an automated voice warns him again that the call “may be monitored or recorded”.

When he dials a number, the phone system checks to see if he’s calling a privileged number (lawyer, M.L.A., ombudsman) or an unprivileged number. If it’s unprivileged, the phone system also checks to see if this number blocked prisoner’s calls. If not, the call goes through, and the call is recorded.

When the recipient picks up the phone, s/he hears an automated voice which warns that the call may be recorded or monitored. The voice asks the recipient to press “0” to accept the call, “5” to block all future calls, or to hang up to reject this particular call.

British Columbia's system is called the "Inmate Call Control System" (ICCS).  The system logs and records all calls from ICCS to unprivileged numbers.

Correctional Service of Canada - the "Millenium" system

As I understand it, when CSC receives an inmate, they create a list of the phone numbers the inmate would like to call.  The phone system permits them to make these calls, but blocks all others.

I hope to find out more about their system shortly.  If you need to know immediately, contact the institution in question.

Do you need a warrant or production order?

If the jail authorities find evidence of crime in the recordings, can they disclose the evidence to you?

In Manitoba and Saskatchewan, they can, without warrant, because their legislation says so.

In B.C., unless you present the prison authorities with a search warrant, production order or wiretap authorization, they may "relate the content" of the record to you.  (B.C. Corrections Branch Adult Custody Policy 7.8.14. Dissemination of ICCS Records.), but they won't release them.

Generally, courts find that prisoners have a small, but real, expectation of privacy over their telephone calls.  In B.C. s.15 of the Corrections Act Regulations prohibits release of the recordings without "lawful authority".  Corrections officials think this means "warrant or production order".  They won't release the recordings without one.

I disagree with this policy, because s.33.2(i)(i) of the Freedom of Information and Protection of Privacy Act permits public institutions to release information to law enforcement agencies which are investigating crime.  All provinces have similar legislation. 

Witnesses Needed

The recording doesn't speak for itself.  Judges won't permit the recording into evidence unless a witness testifies how it came into existence.  Therefore, make sure you identify the person who downloaded the recording from the monitoring system.  Giroux, 2013 NWTTC 4.

Case Law

British Columbia

The binding decision in B.C. on how the Corrections Act works is R. v. Siniscalchi, 2010 BCCA 354.  The court confirms that prisoners enjoy an expectation of privacy over their telephone calls, and you need a warrant or court order based on reasonable grounds to get inmate recordings. (The court did not consider whether the freedom of information legislation applies.) The court also confirmed the constitutionality of the entire call system.  It's okay for Corrections to record the calls.

Alberta

In Alberta, Drader, 2012 ABQB 168 reconsidered 2012 ABQB 469, the court reached the same conclusions about Albertan legislation, and added that it saw no need for a correctional institution to seek permission of an independent authority (like a judge) before reviewing inmate communications.

Curiously, in Simon, 2013 ABQB 95, a court found that absent any specific notice, a prisoner of police in a holding cell could expect that his conversations with a prisoner in a nearby cell would not be recorded.  The judge excluded recordings made that way.

Canada

Federal penitentiaries monitor inmate phone calls using the "Millennium" system.  In Hunter v. Canada, [1997] 3 F.C. 936, the court found that Federal inmates do not enjoy an right of privacy over their telephone calls.

Alcorn v. Canada (Commissioner of Corrections) 163 F.T.R. 1 affirmed at [2002] F.C. J. No. 620

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