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Surveillance Use Policy for Security Cameras Outside Ada’s Café at Mitchell Park Community Center and Library
Ada’s Café (Ada’s) leases space from the City of Palo Alto (City) at the Mitchell Park Community Center and Library. Ada’s has installed security cameras in the café for safety and security and has an interest in purchasing and installing security cameras on the exterior of the café to deter vandalism and capture incidents of criminal activities.
The owners of Ada’s are responsible for all costs associated with the purchase, installation and maintenance of the cameras and will be responsible for complying with this policy.
In accordance with the Palo Alto Municipal Code Section PAMC § 2.30.680(d), the Surveillance Use Policy for the use of security cameras by Ada’s within and on City- owned property is as follows:
1. Intended Purpose. The intent of security cameras is to enhance the security and safety of Ada’s staff and the public and deter and capture incidents of vandalism and other criminal activity at Ada’s Café.
2. Authorized Uses. The Owners and City personnel may only access surveillance video (“footage”) for official and legitimate security, safety, and law enforcement purposes consistent with this Policy.
The following uses of security cameras are specifically prohibited:
a. Harssament or intimidation. It is a violation of this Policy to use the system to harass and/or intimidate any individual or group.
b. Personal Use. It is a violation of this Policy to use the system for any personal purpose.
c. First Amendment Rights. It is a violation of this Policy to use the system or data for the purpose or known effect of infringing upon First Amendment rights of any person.
d. Invasion of Privacy. It is a violation of this Policy to use the system or data in any manner contrary to local, state, and federal privacy laws.
3. Information Collected. Security cameras will record video and audio (if permitted by law). Depending on the specific technology used, metadata such as time, date, and location of the cameras may be documented with the video.
4. Safeguards. All footage will be closely safeguarded and protected by both procedural and technological means. Ada’s Café will observe the following safeguards regarding access to and use of stored data:
NOT YET APPROVED
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a. All footage shall be accessible only through a login/password-protected system with multi-factor authentication (MFA).
b. The following individuals from Ada’s Café shall have access to the footage: Owners/Founders Kathleen Foley-Huges and Tony Hughes, and Deputy Director Peter Hughes. Footage may be forwarded to law enforcement, including Palo Alto Police Department (PAPD), for investigation. Once reviewed, PAPD shall control footage under their own Department policies.
c. Persons approved to access footage under this policy are permitted to access the data for legitimate safety, security, and law enforcement purposes only, such as when the footage relates to a specific incident or criminal investigation.
5. Retention. Ada’s shall retain footage on a looping basis for thirty days. Footage will be retained longer than the retention period if it is reasonably believed it will become evidence in a specific criminal investigation or is subject to a discovery request or other lawful action to produce records.
6. Access by non-City Entities. The footage may be shared with law enforcement or prosecutorial agencies for official law enforcement purposes or as required by law or court order.
7. Compliance Procedures. Kathleen Foley-Huges, Tony Hughes, and Peter Hughes are responsible for ensuring compliance with procedures, including, but not limited to:
a. Ensuring only designated individuals are allowed access to footage when authorized by this policy.
b. Ensuring the security and retention of the footage collected and compliance with applicable laws.
c. Give written notice to the City if any of the persons listed in this policy are changed to other staff.