Sabha, Tamer
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Tuesday, October 6, 2026 5:10 PM
PublicComment-AutoResponse
Municipal Services Oct 7 Item 2
Body Worn Cameras comments.pdf
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The attached document is public comment for Item 2. PARKING DIVISION BODY-WORN CAMERA POLICY.
HumairaPasadena Resident
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1 Body Worn Cameras for the Parking Division
RECEIVED
?0?COCT-6 PH 5: 13
y/
Community members have repeatedly expressed privacy and security cfincernsaround.thg, use of body worn cameras (BWCs) and other technology, yet the few references to privacyin the proposed Body Worn Camera Policyfocus on the absence of a reasonableexpectation of privacy and fail to directly address very legitimate concerns. What lawsapply and what elements of the policy ensure that the laws are followed? What are the bestpractices for ensuring privacy and how will they be implemented? This content is strikinglyabsent from the policy. Asserting in the presentation that the "policy ensures compliance with privacy Law and protects sensitive information" doesn't make it true. I urge the MSC not to approve the proposed policy and to direct that it be rewritten with close attentionpaid to addressing privacy, security and other concerns.I also encourage the MSC to request that DOT staff also provide data-based scientific analysis regardingthe effectiveness of equipping parking enforcement personnel with body worn cameras before adopting their use. According to recent research on Body Worn CamerasM^^^^ the California Mobility and Parking Association (CMPA)*, the adoption of BWCs for parking enforcement is emerging but not yet widespread. The dearth of peer-reviewed analyses on this use means that the City must be especially cautious before pursuing a BWC program for Parking Enforcement. Anecdotalevidence suggests that BWCs may help achieve the professed goals, but this is more akin to vendor marketing and is not scientific, data-based analysis. The California and Mobility Parking Association recommends starting with a 90-180 day pilot with measurableoutcomes for complaint rates, incident escalations, officer/public satisfaction, andcitation dispute resolution.
Some additional comments (organized to align with the policy document):
Purpose and Scope
No analysis has been presented to show that BWCs are effective at achieving the stated purpose.
How does the Dept of Transportation intend to assess the efficacy and costeffectiveness of the cameras in achieving the stated goals? Should state that BWS will NOT be used for routine surveillance or continuous monitoring, not just that they are "not intended" for that use.
NO FUNCTION CREEP ALLOWED
o All allowed uses should be explicitly spelled out in the policy and not just listed as the general purpose
o No additional uses allowed or additional capabilities turned on without review and approval by City Council after public discussion and engagement Operations fActivation)
Logs should be kept of all activations (including unintentional activations) and of allinstances in which a camera is not activated when it should have been due tomalfunction, personnel safety concerns, etc.
Advisement About Recording
Will other people in the area who are not involved in the parking-related interaction be advised that they are being recorded? They DO have a reasonable expectation ofprivacy to not be recorded by City personnel.
What steps will be taken to avoid videoing children?
Faces of uninvolved individuals should be blurred
Data Collection and Retention
What are the criteria for assessing proper collection and retention of BWC data?Wilt data be stored on local servers? In the Cloud? On whose servers? Where?Will the data be stored as part of a software system provided by the BWC or anothervendor? How will the data be protected from access by unauthorized third parties? A BWCrelated vendor or service provider should not have access to the data except for troubleshooting requested by Parking Department or other appropriate City staff.
How will this be addressed in contracts etc? How will it be audited? What steps willbe taken to ensure that the vendor or related service providers do not access Citydata for their own use or purposes? Data should not be stored on any network accessible by other agencies or entities. "BWC system audits should be conducted on a regular basis." Regular basis should be defined. Who will conduct the audits? Audit findings should be publicly reported.
A one year data retention period is excessive. Six months maximum unless a specific video clip is needed for a case.
Review of Recordings
ALL faces should be blurred if using recordings for Parking Division trainingAll access should be documented with a reason, ticket number or other identifying info to connect to the stated reason, and user information.
Releasing BWC Data
Policy should reference the specific Pasadena Police Department policy A Logwith documentation of reasons should be maintained of all access by o Other city staff, including Pasadena PD and Human Resourceso All other entities or individuals Info on the release of BWC data should be audited and publicly shared at least annually
Data breaches should be publicly reported immediately after they are resolved orinvestigated Consequences for Policy Violations
All policy violations should be logged and publicly reported at least annually Policy violation reporting should include information on any corrective action taken(anonymized to protect staff privacy) and repeat violations.
The policy also needs to explicitly prohibit the use of facial recognition technology and address concerns about the role of artificial intelligence in BWC technology. *rCMPA: Brief: Body-Worn Cameras in Parking Enforcement, California Parking and Mobility Association Brief, 2/9/2026, https:.//www,parking-mobiUty,org/blog/bo^&a.r.ki.ng-e.nfQrcem.ent/.
HumairaPasadena resident