City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Community Services
Meeting Date: October 5, 2026
Report #:2602-5958
TITLE
Approval of Surveillance Use Policy for Security Cameras at the Palo Alto Animal Shelter; CEQA Status - Not a Project.
RECOMMENDATION
Staff recommend that the City Council approve the attached surveillance use policy for the use of security cameras to enhance security and safety and deter unauthorized or criminal activity at the Palo Alto Animal Shelter (Attachment A).
EXECUTIVE SUMMARY
The Palo Alto Animal Shelter (operated by Pets in Need) has a need to acquire and use surveillance technology to ensure the safety of animals, visitors, and staff. A Surveillance Use Policy has been developed to comply with the City’s Surveillance Technology Ordinance and include mitigations to ensure appropriate use of the information captured. Key elements are summarized in Table 1 in the Analysis section of this report.
BACKGROUND
Palo Alto’s Surveillance Technology Ordinance, codified PAMC § 2.30.6201, et seq., sets criteria and procedures to protect personal privacy in the acquisition and use of surveillance technology and provide for ongoing oversight. Security camera technology is “surveillance technology” as defined by the ordinance. The ordinance requires City Council approval of the acquisition of new surveillance technology and of a Surveillance Use Policy specific to each new approved technology. In approving new surveillance technology, the Council must determine that its benefits outweigh the associated costs and concerns.
The ordinance sets forth specific elements that must be present in a Surveillance Use 1 Palo Alto Municipal Code Section 2.30.620, et seq.;
https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-62120#JD_2.30.620
Policy, including limitations on use, access, and retention, as well as a description of compliance procedures.
ANALYSIS
Prior to approval of a new surveillance activity by the Council, the ordinance requires the completion of a Surveillance Evaluation, consisting of five specific elements below. Table 1 evaluates the use for the Palo Alto Animal Shelter.
Table 1: Surveillance Evaluation for Palo Alto Animal Shelter
1. A description of the surveillance technology, including how it works and what information is captured
The surveillance technology will include security cameras and monitoring systems designed to capture real-time video footage of entry points, the front parking lot, and animal housing areas. Video and audio will be captured only when the front doorbell is pressed and is solely for staff to communicate with the individual at the front doorbell. Audio is not captured on any video recordings. The technology may also include motion detectors and alarm systems that notify designated personnel of suspicious activities.
2. Information on the proposed purpose, use and benefits of the surveillance technology The primary purpose of implementing surveillance technology is to enhance the safety and security of Pets In Need, which has been subject to overnight loitering, mail tampering, animal abandonment, and occasional animal related incidents. The technology also allows shelter management to view the facility when staff are not on site to ensure the safety of animals. It will also provide evidence to the Palo Alto Police Department (PAPD) if an incident should occur inside or outside the facility.
PIN will provide an annual surveillance report to the City to comply with Section 2.30.680(a)3 of the Palo Alto Municipal Code.
3) The location or locations where surveillance technology may be used Surveillance technology will be located inside and outside of the animal shelter - in strategic high-risk areas prone to vandalism, theft or other criminal activity. This includes entry points, the front parking lot, and animal housing areas.
4) Existing federal, state and local laws and regulations application to the surveillance technology and the information it captures; the potential impacts on civil liberties and privacy; and proposals to mitigate and manage any impacts 3 Palo Alto Municipal Code Section 2.30.680(a);
https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-62178 Surveillance technology will comply with applicable laws related to video and audio recording. This includes Labor Code section 435, which forbids employers from recording in a restroom, locker room, or changing room; and Penal Code section 632, which prohibits recording audio of “confidential communication,” subject to exceptions such as for public meetings under Penal Code section 632(c).
Mitigation Actions for Pets In Need:
Access to surveillance footage is limited to designated positions in Pets in Need and is permitted only when there is a legitimate operational, safety, or investigative need.
The Chief Executive Officer is authorized to access surveillance footage and can authorize access to other PIN management if relevant to the type of investigation. The Director of Shelter Operations and Facilities & IT Manager are authorized to access and review surveillance footage when requested by the CEO for a specific, authorized purpose but are not authorized to independently access or review footage.
When footage is relevant to an investigation, only the applicable portion of the footage may be clipped and shared with the following positions on a need-to-know basis:
Animal-related investigations: Director of Behavior & Medical Services and Behavior, Training & Rescue Manager.
Employee-related investigations: Director of Human Resources and CEO.
City police personnel will be granted access for law enforcement purposes. 5) The costs of the surveillance technology, including acquisition, maintenance, personnel and other costs, and current or potential sources of funding All costs to purchase, install, and maintain the cameras will be the responsibility of Pets in Need.
FISCAL/RESOURCE IMPACT
There is no cost to the City for the surveillance cameras at the Palo Alto Animal Shelter. Pets In Need will purchase, install and maintain security cameras.
STAKEHOLDER ENGAGEMENT
The Community Services Department and Police Department coordinated with Pets in Need to develop this policy.
ENVIRONMENTAL REVIEW
Council action on this item is not a project as defined by CEQA because it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment. CEQA Guidelines section 15061(b)(3).
ATTACHMENTS
Attachment A: Palo Alto Animal Shelter Surveillance Policy APPROVED BY:
Kristen O'Kane, Community Services Director