NOT YET APPROVED
Surveillance Use Policy for Security Cameras for Palo Alto Junior Museum and Zoo
In accordance with Palo Alto Municipal Code Section PAMC § 2.30.680(d), the Surveillance Use Policy for the City’s use of security cameras at the Palo Alto Junior Museum and Zoo (JMZ) is as follows:
1. Intended Purpose. The intent of security cameras is to increase the safety and security of City assets in and immediately around the Palo Alto Junior Museum and Zoo, a place with staff, animals, and public coexist in a single space with multiple access points.
2. Authorized Uses. 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. Harassment 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 or data 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 24/7. Depending on the specific technology used, metadata such as time, date, and location of the camera may be documented with the video.
4. Safeguards. All footage will be closely safeguarded and protected by both procedural and technological means. The City will observe the following safeguards regarding access to and use of stored data:
a. All footage shall be accessible only through two factor authentication and/or Single Sign-on, to access sensitive systems and applications. b. Only select and necessary leadership staff members of the Palo Alto Junior Museum & Zoo shall have access to the footage and may delegate access to specific City staff members as long as such delegation is in writing and compliant with this Policy. Permissible personnel: the JMZ Senior Program Manager (Executive Director), Zoo Director (Specialist), and Exhibits Director (Specialist).
NOT YET APPROVED
c. Staff may provide footage to law enforcement, including Palo Alto Police Department (PAPD), for investigation. Once received, PAPD shall control footage under their own Department policies.
d. 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. e. Encryption
o Verkada ensures that all connections to its web application from its users are encrypted using certificated TLS configurations. Both website and application are reachable exclusively over HTTPS.
o Verkada stores customer data in databases that are encrypted at rest. f. Network security
o Production environments run in an isolated Virtual Private Cloud network with only necessary services enabled.
o Verkada uses configurations that ensure only approved networking ports and protocols are implemented.
g. Monitoring and Alerting
o Verkada tools monitor server CPU use, free storage space, message age and read I/O in Verkada’s databases, servers and messaging queues and notify appropriate personnel of any events or incidents based on predetermined criteria. Incidents are escalated per policy.
5. Retention. The City shall comply with Govt. Code section 34090.6 et seq. to retain footage pursuant to state law (currently one year). Additionally, the City will retain relevant footage longer than the retention period if it is reasonable to believe 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 outside of the City with law enforcement or prosecutorial agencies for official law enforcement purposes or as required by law or court order.
7. Compliance Procedures. The Assistant Director for Community Services (Arts & Sciences Division) and the JMZ Senior Program Manager (Executive Director) of the Junior Museum & Zoo shall be responsible for ensuring compliance with procedures, including, but not limited to:
a. Ensuring only designated staff 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.