Surveillance Technology Governance Policy – Draft Policy Overview

View the pdf here

This policy establishes a Citywide framework to ensure surveillance technology is used lawfully, responsibly, transparently, and with strong safeguards and accountability.

Key Elements

• Clear Purpose & Necessity: Use only when there is a specific, legitimate need and no reasonable alternative.
• Privacy & Civil Rights: Protect privacy, civil rights and civil liberties while serving the community.
• Review & Approval: Use a decision framework and complete required reviews before implementation.
• Safeguards & Responsible Use: Limit collection and use, protect data, set retention limits and restrict access.
• Transparency & Accountability: Inform the public, report uses, and allow oversight and auditing.
• Continuous Improvement: Train staff, audit compliance, and update practices as technology and risks evolve.

What is Surveillance Technology?

Technology intentionally used to observe, monitor, track, analyze, or record identifiable individuals or groups. This includes technologies that:

• Collect or create surveillance data
• Use cameras, sensors, location data, logs, analytics or artificial intelligence
• Have capabilities that are presumptively within the policy’s scope, regardless of current use

What matters most is primary use. This policy applies when surveillance is the primary use of the technology.

What Does This Policy Apply To?

Applies across ALL City departments and operations when surveillance is the primary Use of the technology.

Applies when:

• The primary use of the technology is to observe, monitor, track, analyze, or record identifiable individuals or groups.

Does NOT apply simply because a system has:

• Cameras, sensors, logs, location data, analytics or artificial intelligence capabilities – unless those capabilities are used for Surveillance.

Decision Framework:

5 Key Questions

1. Is the City intentionally using technology to observe, monitor, track, analyze or record identifiable individuals or groups?
2. Is the use planned, recurring, operationally significant or programmatic?
3. Is there an authorized governmental purpose?
4. Is the use necessary, appropriate and proportionate to the approved purpose?
5. Has the required governance been completed (reviews and approvals) Before implementation?

If any answer is “no,” the policy does not apply or the use is outside scope, unless required by law or directed for review. If “yes” to all, complete required review and follow safeguards.

Foundational Requirements

• Surveillance Technology Impact Report (required for in-scope uses)
• Surveillance Use Policy (required for in-scope uses)
• Data governance, retention limits, access controls and security
• Strong vendor and procurement standards
• Responsible use requirements and staff training
• Audits, compliance monitoring and policy improvement
• Transparency, public accountability and reporting
• Emergency use only as permitted by law

Technologies Presumptively Within Scope

• Facial recognition or other biometric identification of individuals
• Persistent or bulk tracking of the location or movements of Identifiable individuals or vehicles over time
• Other technologies whose primary use is surveillance of Identifiable people or groups

Balancing Privacy and Effective Governance

This policy promotes responsible use of surveillance technology that respects privacy, supports public trust and advances City priorities.

Draft summary for discussion. Not an official policy.