TO: PUBLIC SAFETY, FINANCE, AND FROM: Rob Lloyd
STRATEGIC SUPPORT COMMITTEE
SUBJECT: DIGITAL PRIVACY PROGRAM DATE: March 8, 2022
STATUS REPORT
Approved Date
RECOMMENDATION
Accept the status report on the progress of the Digital Privacy Program, reviewing implementation of review and processes, outcomes, and approaches to responsible digital surveillance practices.
OUTCOME
The Committee will be aware of and provide input on the progress of the Digital Privacy Program.
BACKGROUND
Data science remains one of the fastest growing segments of the technology sector. 1 The volume
of data globally has more than quadrupled from 2013 to 20192. At the same time, the number of data science jobs has more than doubled,
3 enabling more applied use of data. The San José
community, City Council, and City staff recognize the need to operationalize robust privacy controls to ensure that the City’s usage of data and analytics is equitable, effective, and responsible. The wellbeing and trust of residents is central to public services, requiring a high bar for privacy to maintain public confidence.
The City tasked the Information Technology Department (ITD) to operationalize the City’s Digital Privacy Policy to be effective, equitable, and responsible. These efforts align with the 1 Technavio (2021), Data Science Platform Market by Component and Geography: https://www.technavio.com/report/datascience-platform-market-industryanalysis?utm_source=prnewswire&utm_medium=pressrelease&utm_campaign=T47_report_wk48_003_22&utm_content=IRTN TR71287
2 Estimated by Statista: https://www.statista.com/statistics/871513/worldwide-datacreated/#:~:text=The%20total%20amount%20of%20data,replicated%20reached%20a%20new%20high. 3 Indeed Hiring Lab (2019), Data Scientist: A Hot Job That Pays Well, Indeed Hiring Lab:
https://www.hiringlab.org/2019/01/17/data-scientist-job-outlook PSFSS COMMITEE: 3/17/2022
ITEM: (d) 4.
FILE:
ITEM:
CC 21-199
3/11/2022
PUBLIC SAFETY, FINANCE, AND STRATEGIC SUPPORT COMMITTEE March 8, 2022
Subject: Digital Privacy Program Status Report
City’s Fiscal Year 2021-2022 City Roadmap priorities of “Digital Equity” and “Drive to Digital”,4as well as supporting delivery of City services wherein data is collected and used.
History of the City’s Digital Privacy Efforts
In 2017, the City recognized the need for a dedicated effort on digital privacy. Staff from the City Manager’s Office, the Office of Civic Innovation, and the Information Technology Department worked with the Harvard Berkman Klein Center for Internet & Society, as well as internal and external advisory groups,
5 to define a path for creating a digital privacy program fitting the requirements of modern government and emerging technologies.
The Mayor and City Council approved the resulting work as the City of San José’s Digital Privacy Policy6, 7on December 8, 2020, and effective July 1, 2021. This established the foundations of the City’s Digital Privacy Program. The Information Technology Department led immediate work to implement basic privacy review processes for major projects and purchases, defined a start-up privacy program, and developed the job description for the City’s Digital Privacy Officer (DPO) to support all departments as the Citywide privacy lead.
In the Fiscal Year 2021-2022 City Budget Process, Mayor and City Council approved the DPO position to lead the City’s Digital Privacy efforts.
8 In October 2021, the City hired the DPO and
formally initiated the program and its long-term work plan. The DPO is responsible for partnering across City departments and external partners to implement the City’s Digital Privacy Policy, protecting community trust in how the organization collects, processes, and uses information.
Throughout the formulation and operationalization of the Digital Privacy Program, the City has coordinated with privacy experts from its Digital Privacy Advisory Taskforce, City departments, and peer governments. This has allowed the City to develop and implement a formal process for privacy reviews that weighs civic benefits against potential risks, as well as data usage controls that help manage those decisions in day-to-day City operations.
Stakeholder Input for Designing Formal Privacy Protocols The DPO is continuing to build out City privacy protocols that tailor best practices to the specific needs of the City. Input on best practices came from a variety of privacy leaders, peer governments, and national privacy forums, including:
4 Item 21-2379 of the November 16, 2021, City Council meeting for the most recent update on the Fiscal Year 2021: 2022 City Roadmap: https://sanJosé.legistar.com/LegislationDetail.aspx?ID=5202113&GUID=311A1F9A-612F-4E40-8420- 4990A2FDFFF6
5 Digital Privacy Advisory Task Force on the Digital Privacy: https://www.sanjoseca.gov/your-government/departmentsoffices/information-technology/digital-privacy 6 Digital Privacy memo and presentation from the 12/8/2020 City Council Meeting:
https://sanJosé.legistar.com/View.ashx?M=F&ID=8931718&GUID=5744C552-4DED-40B8-9D1A-123DCB1CF2CC and https://sanJosé.legistar.com/View.ashx?M=F&ID=8997095&GUID=CEB58E6D-8D87-4459-AA7B-5B26F9881A4C 7 City of San José Digital Privacy Policy: https://www.sanjoseca.gov/home/showpublisheddocument?id=68053 8 City of San José 2021-2022 Adopted Operating Budget, Page 28:
https://www.sanjoseca.gov/home/showpublisheddocument/78329/637739734655100000
PUBLIC SAFETY, FINANCE, AND STRATEGIC SUPPORT COMMITTEE March 8, 2022
Subject: Digital Privacy Program Status Report
• The Harvard Cyberlaw Clinic;
• The City’s Digital Privacy Advisory Taskforce;
• Privacy offices from other jurisdictions, such as the County of Santa Clara Privacy Office; and
• National forums dedicated to government adoption of digital privacy protections, including the Center for Digital Government and the Future Privacy Forum.
Practices identified highlighted the need for the following key elements (see figure for summary):
• A process requirement for DPO review on technology and data-related initiatives; • A high-level initial assessment or “threshold analysis” to determine the general risk level and review requirements for an initiative;
• A short-form review process for lower-risk projects;
• A wholistic privacy impact assessment for high-risk projects; • Clear data usage policies for high-risk data initiatives; and • An avenue for ongoing data usage reporting and public comment on high-risk projects.
Figure 1: Key insights from privacy experts and peer governments
PUBLIC SAFETY, FINANCE, AND STRATEGIC SUPPORT COMMITTEE March 8, 2022
Subject: Digital Privacy Program Status Report
Input on the City of San José’s specific privacy needs came from lessons learned in previous City privacy efforts, implementing new use cases, and engaging members of the public. This included:
• Previous outreach and other learnings from drafting the Digital Privacy Policy; • Needs identified while reviewing key use-cases, including traffic safety monitoring, affordable housing public portal, and youth intervention services; • Engagement with the City’s Digital Privacy Advisory Taskforce9composed of Bay Area privacy leaders from academia, private industry, peer governments, and civil liberty groups (American Civil Liberties Union, National Association for the Advancement of Colored People); and
• Public hearings and written public comments.
City of San José-specific input provided additional key guidance for:
• Requiring clear expectations for Notice, Minimization, Retention, Accountability; Accuracy, Sharing, and Equity processes, in accordance with the City’s Digital Privacy Policy;
• Minimizing, if not eliminating privacy risks as related to immigration status and ability to live in San José; and
• Building a library of privacy precedent to streamline future privacy reviews and decisions.
ITD applied and refined its protocol to a variety of data use cases including:
• Fingerprint database management;
• Traffic simulation software;
• AI-based electricity demand prediction;
• Affordable housing open portal;
• Online eviction support portal; and
• Youth intervention services.
Applying and Refining City Privacy Protocol Through Key Use Cases – Traffic Safety Enforcement through Automated License Plate Reading (ALPR) To illustrate the privacy protocol, this memo dives into the ongoing cross-department review of traffic safety and enforcement using ALPR cameras. ALPR utilizes high speed cameras angled to capture digital images of vehicles and their license plates. 9 Privacy Advisory Task Force: https://www.sanjoseca.gov/your-government/departments-offices/informationtechnology/digital-privacy
PUBLIC SAFETY, FINANCE, AND STRATEGIC SUPPORT COMMITTEE March 8, 2022
Subject: Digital Privacy Program Status Report
While the ALPR camera is angled to capture license plate information, it may collect additional information, including car make/model, and distinguishing characteristics (e.g., bumper sticker(s), aftermarket wheels).
ALPR cameras may be placed in a fixed location, such as on a street light pole, or in a roaming location, such as on a police patrol car. The technology also collects the date and time that the license plate passes an ALPR camera, and the location of the camera at that time. The exact location of a vehicle is not tracked but can be closely inferred based on the location of the camera at the time of the photograph.
Figure 2: Example picture from an Automated License Plate Reader Camera from the Pasadena, CA Police Department. This picture identifies 1) the license plate, 2) the time and location of the car at this time, and 3) any other information captured in the photograph. Source - https://www.pasadenanow.com/main/city-council-to-consider-purchasing-more-automatic-license-platereaders The Police Department developed a usage protocol for ALPR in 2017 10, which is currently in use
and complies with California Senate Bill 34 regarding law enforcement usage and auditing requirements of ALPR. Staff identified the need to update the protocol for three reasons:
1. The 2021 Council Memo on ALPR usage redefined usage limitations for future ALPR11 and needs to be updated and consolidated into the overall ALPR usage. 10 See San José Police Department Duty Manual L4207; approved by Council as item 8.2 on January 24, 2017:
https://www.sanjoseca.gov/home/showpublisheddocument/57582/637248116781300000 11 See item 21-2485 of the November 30, 2021, City Council meeting for the memo on ALPR data usage; see item 3 in the Council memo from Liccardo, Jones, Carrasco & Mahan:
https://sanJosé.legistar.com/LegislationDetail.aspx?ID=5217224&GUID=CC4AC350-D1D1-475C-B998-1023103F2DF5
PUBLIC SAFETY, FINANCE, AND STRATEGIC SUPPORT COMMITTEE March 8, 2022
Subject: Digital Privacy Program Status Report
2. The 2021 Council Memo on ALPR usage required that the City revisit the ALPR usage protocols in Quarter 1 of 2022.
12 3. The 2017 usage protocol needs to be reviewed given the passage of the City Digital Privacy Policy in late-2020.
13 ANALYSIS
In conjunction with the City’s Police, Transportation, and Information Technology departments, along with input from the City Manager’s Office, the Smart Cities Committee, and the Mayor’s Gang Prevention Task Force, ITD developed a robust protocol for reviews, defining data usage, and monitoring.
Control points focus on three City processes: purchasing, project approvals and execution, and budget requests. Retroactively, the DPO is engaging departments to review existing data usage and define their usage policies to align with the City’s Digital Privacy Policy.
Current progress includes:
• 13 departments / offices that have been advised, educated, or had projects reviewed by the DPO;
• Over 60 projects reviewed for privacy; and
• Over 100 community leaders engaged through public hearings and events since November 2021.
Digital Privacy Program Mission
Mission statement: “The data we collect on a community is used to support that community. We work so that our residents understand what data we’re collecting, why we’re collecting it, and how to engage to create a smarter, safer, and more equitable City.” The Digital Privacy Program identified five key levers in supporting this mission for more equitable, effective, and responsible data usage across City services:
1. Supporting strategic data usage aligned with City goals – The DPO serves as an advisor in targeting the necessary data, minimizing resident privacy concerns, and providing the best possible service experience.
2. Reducing risks of compromised information – The DPO works with the Cybersecurity Office to reduce the amount of unnecessary private information collected, reducing the consequences and risks from a data breach.
3. Defining data usage – Aligned with best-practice, the DPO takes a “usage-based” approach for technology, reviewing how projects can use data in a way that aligns with 12 Ibid, see footnote 13
13 Ibid, see references in footnotes 4 and 6
PUBLIC SAFETY, FINANCE, AND STRATEGIC SUPPORT COMMITTEE March 8, 2022
Subject: Digital Privacy Program Status Report
the City’s Digital Privacy Policy. For example, defining the types of criminal investigations some surveillance technology can initiate (e.g., per State law, a camera cannot automatically trigger a speeding ticket).14
4. Monitoring where data is used – Additional surveillance enables a much higher “catchrate”. When that surveillance is inequitably applied across the City, it can lead to disproportionate enforcement on a community because there is more evidence available in that location. The DPO monitors and reports on surveillance technology placement and application to identify potential equity concerns.
5. Tracking accuracy of automated technology – As the City explores more automation in its systems and processes, the DPO supports the review, procurement, and ongoing monitoring of automated technologies to ensure they are accurate and used equitably.
One key control is ensuring human review of an automated decision before it leads to punitive action on an individual, such as confirming a license plate is read correctly, before taking enforcement action.
Privacy in action: Standardized Privacy Review Protocol The privacy review process serves as the key mechanism through which the DPO monitors and improves City-wide privacy practices. These steps include a privacy assessment, data usage definitions, public engagement, and routine monitoring. While not all steps are necessary for every project, the protocol provides the general framework for reviewing any City project that uses personal information.
1. Data Initiative Proposal: Departments first engage the DPO to discuss their project.
Departments should provide existing material related to the project, including details on project purpose and data collected.
2. Initial Privacy Assessment: The DPO conducts a “threshold analysis” to determine if a project requires additional review, a DUP, and public engagement. Low-risk projects are approved at this step. Medium-risk projects can often be handled through an abbreviated version of the steps.
3. Data Usage Protocol (DUP): The DPO determines if the proposed project is covered under an existing usage protocol called a “Data Usage Protocol”. If so, the project can generally move to step 5, otherwise the departments and DPO draft a DUP.
4. Public Engagement: The draft DUP is published online15 for public comment. If the project is considered high-risk and applies City-wide, the DPO conducts in-person outreach targeting communities with limited access to online comments (either due to language or internet access issues). Community feedback is then incorporated into the DUP.
14 California legislature has proposed laws to allow automated speeding enforcement, but none have passed:
https://www.mercurynews.com/2021/03/16/new-push-for-speed-cameras-in-california-this-is-about-savinglives/#:~:text=Also%20known%20as%20automated%20speed,driver's%20speed%20in%20real%20time 15 City of San José Data Usage Policies: https://www.sanjoseca.gov/digitalprivacy
PUBLIC SAFETY, FINANCE, AND STRATEGIC SUPPORT COMMITTEE March 8, 2022
Subject: Digital Privacy Program Status Report
5. Privacy Review: Departments fill out the required review form for the DPO. The DPO provides assessment, approval/denial, and/or recommendations. High-risk projects require a full Privacy Impact Assessment (PIA), covering in detail all seven components of the City’s Digital Privacy Policy. Medium-risk projects only require an abbreviated review. A separate review on the project’s cybersecurity from the Cybersecurity Office is required for technology procurements.
6. Submittal to CMO and Council: High-risk projects without a previously approved DUP are submitted to the City Manager’s Office, then the DUP rises to Council pending review from a relevant Committee. Separately, the PIA and DUP are published online. 16 Note that the published DUP and PIA contain no personal information or other confidential information.
7. Ongoing Monitoring: Departments report annual metrics defined in the DUP and PIA.
Reports usually require metrics on data usage and project effectiveness. The public can comment on data usage and annual updates online.
16 As of writing, these can be found online: https://www.sanjoseca.gov/digitalprivacy
PUBLIC SAFETY, FINANCE, AND STRATEGIC SUPPORT COMMITTEE March 8, 2022
Subject: Digital Privacy Program Status Report
Figure 3: City privacy protocol developed from best practices and use-cases. Steps 3-7 may not be required pending assessed risk in step 2. The image lists the seven potential steps of the DPO’s privacy process.
Established Approach for Defining Data Usage and Receiving Public Input Permissible data usage for a project is defined in its relevant DUP. The DUP is typically 1-3 pages and covers a type of data usage. It is typically composed of six elements:
1. Project summary
2. Authorized and prohibited uses of data
3. Practices for data collection, storage, notice, retention, sharing, access, and corrections
4. Summary of security practices
• Departments propose initiative to Digital Privacy Officer (DPO) • DPO assesses general risk; determines required process steps • Low-risk projects approved at this step
• For high-risk projects without prior DUP: Refer DUP and Privacy Review to City Manager’s Office and relevant Committee
• Post PIA and any updates to existing DUPs on digital privacy webpage
• If existing Data Usage Protocol (DUP) applies, move to “Privacy Review” step
• If not, departments and DPO draft DUP
• Publish draft DUP online for public comment
• For high-risk projects, conduct in-person outreach
• Incorporate feedback into DUP
• Medium-risk: Brief privacy procurement/initiative review • High-risk: Full Privacy Impact Assessment (PIA)
Data Initiative
proposal
Initial DPO
assessment
Data Usage
Protocol
(DUP)
Public
engagement
Privacy
review
Submittal to
CMO and
Council
Ongoing
monitoring
• Monitor data usage as defined in DUP – annual reporting • Provide ongoing avenue for online public comment on DUP – monitored by DPO
1 2
3 4
5 6
7 PUBLIC SAFETY, FINANCE, AND STRATEGIC SUPPORT COMMITTEE March 8, 2022
Subject: Digital Privacy Program Status Report
5. Required training for personnel using systems and technologies (if any)
6. Oversight and annual compliance expectations, written in an Annual Data Usage Report The Annual Data Usage Report mentioned in item 6 is typically 1-2 pages, drafted by the applicable department(s), and details:
1. Project summary
2. Required performance metrics as defined in the DUP (e.g., accuracy, effectiveness, cost)
3. Plans for the data initiative (e.g., expansion, shift in usage) Once a Data Usage Protocol is drafted, it will be made available to the public. If the project is considered high-risk, the department or the DPO may conduct in-person outreach to community members and leaders. The public must be notified of high-risk data usage through public forums, such as City Council and/or committee meetings, and in-person and/or virtual outreach to specific communities. The public can provide ongoing comment on all active DUP’s online or by contacting the DPO directly at 408-793-6878, or through other public meetings on privacy.
Application of Privacy Protocol to a Key Use Case – Traffic Safety Enforcement through Automated License Plate Reading (ALPR)
ALPR cameras have been a tool for San José’s Police Department since 2006. While more research is needed, there is some evidence that using ALPR technology may improve traffic investigations17 and reduce the risk of crime in an area.18 The recent proposed expansions of ALPR cameras launched a broader review of the City’s ALPR usage.
19 Current progress is detailed below:
Step 1: Data initiative proposal
The City’s Transportation and Police Departments approached the DPO regarding ALPR technology in the context of the Monterey & Curtner traffic safety project. Police Department staff and the DPO then began work to update the general ALPR Data Usage Protocol.
Step 2: Initial DPO assessment
ALPR technology for law enforcement has a high privacy risk based on volume, details, and outcomes. The data collected is considered low-mid risk, since license plates can identify a person but are publicly visible (i.e., you can see a car’s license plate on the road). The project is ultimately assessed as high-risk given elements of:
17 Koper, Christopher S., and Cynthia Lum. "The impacts of large-scale license plate reader deployment on criminal investigations." Police Quarterly 22.3 (2019): 305-329: https://journals.sagepub.com/doi/abs/10.1177/1098611119828039 18 Koper, Christopher S., Bruce G. Taylor, and Daniel J. Woods. "A randomized test of initial and residual deterrence from directed patrols and use of license plate readers at crime hot spots." Journal of Experimental Criminology 9.2 (2013): 213-244:
https://link.springer.com/article/10.1007/s11292-012-9170-z 19 Ibid, see footnote 13
PUBLIC SAFETY, FINANCE, AND STRATEGIC SUPPORT COMMITTEE March 8, 2022
Subject: Digital Privacy Program Status Report
1. Purpose: Data will be used for law enforcement purposes. Cars that pass an ALPR camera can be checked if they match a “wanted” list of license plates for law enforcement investigations.
2. Notice/Consent: Cameras will photograph license plates without data subject consent, and notice is not inherently provided in the system.
Step 3: Data Usage Protocol (DUP)
A DUP is being drafted to consolidate existing ALPR protocol, enable effective usage of ALPR, and align ALPR usage with the City’s Digital Privacy Policy. The draft DUP will be circulated for public input once complete.
Key items within the DUP include:
• Authorized and prohibited uses;
• Expectations for providing Notice;
• Ongoing monitoring for effectiveness and equity; and
• Protocols to mitigate risk of unauthorized data access and usage Step 4: Public Engagement
The City will coordinate with the City Manager’s Office/Office of Communications, Economic Recovery Task Force, Digital Privacy Advisory Task Force, and the Mayor’s Gang Prevention Task Force in engaging the community on a draft update to the Automated License Plate Reader (ALPR) DUP. Additionally, signage will be placed at the Monterey and Curtner intersection for the traffic safety pilot. The signage will provide notice of ALPR collection at the intersection and a link to provide feedback on ALPR usage.
Step 5: Privacy Review
The DPO will assess ALPR usage across the seven elements of the City’s Digital Privacy Policy.
20 Step 6: Submittal to City Council
The updated ALPR DUP will be submitted at a later date with the recommendation to send to Council for approval and replacement of all existing ALPR usage protocols, including those detailed in Police Duty Manual L 4207 and Council item 21-2485.
Step 7: Ongoing Monitoring
Annual reporting requirements will be defined in the DUP, which will be circulated for public comment.
20 Notice, Minimization, Retention, Accuracy, Accountability, Sharing, and Equity. See more details on the City website:
https://www.sanjoseca.gov/your-government/departments-offices/information-technology/digital-privacy
PUBLIC SAFETY, FINANCE, AND STRATEGIC SUPPORT COMMITTEE March 8, 2022
Subject: Digital Privacy Program Status Report
CONCLUSION
New and existing initiatives that follow the City of San José’s Digital Privacy Policy allow the City to balance potential uses of data with the requirement to maintain public trust. With evolving technologies, Digital Privacy Reviews will continue to be a crucial process for the City’s responsible use of data across operations, public safety efforts, and equity initiatives.
Executed well and with critical feedback from the public and the City’s advisory groups, San José can make strong decisions about instances where public benefits do and do not merit the risks of using sensing technologies and data.
Progress to date from the DPO can be summarized in four main points:
1. Progress in San José’s Drive to Digital and all services using data following the hiring the Digital Privacy Officer (DPO). The DPO has developed and put into practice best-in-class privacy processes for review, public engagement, and data usage policies.
2. Implementation of privacy review and outreach processes in over 60 projects in the past five months. The Digital Privacy Program will continue to evolve as needed with the support of the City’s Digital Privacy Advisory Task Force, peer government partnerships, and feedback from the public and City staff.
3. Positive outcomes and public feedback from community organizations, City staff, task force leaders, members of the public, and outside governments.
4. National leadership in government digital privacy, sharing the City’s practices with other jurisdictions through national privacy forums like the Center for Digital Government and the Future Privacy Forum.
The Police Department has worked with the DPO in drafting an update to the DUP for ALPR cameras used for law enforcement. The DPO and Police Department will present a draft for the updated DUP to the Committee at a later meeting, with the recommendation that it is brought to Council for approval.
ITD with the DPO is making progress towards San José’s “Digital Equity” and “Drive to Digital” priorities. By continuing to engage the public, City staff and external privacy leaders, the City is defining clear, responsible data usage for a smarter, more equitable San José.
EVALUATION AND FOLLOW-UP
The Information Technology Department will report progress on Data Usage Policies and overall progress on the City’s Digital Privacy Program at future PSFSS Committee meetings at the request of City Council.
PUBLIC SAFETY, FINANCE, AND STRATEGIC SUPPORT COMMITTEE March 8, 2022
Subject: Digital Privacy Program Status Report
Key next steps include:
1. Continue drafting and engaging the public on Data Usage Protocols for upcoming and existing priority data initiatives to align with the City’s Digital Privacy Policy.
2. Expand the City’s Equity through Data and Privacy efforts with support from the City Manager’s Office and the Knight Foundation.
3. Continue to develop San José’s Digital Privacy Program model to help lead national adoption of digital privacy programs in state and local governments, and building a community of practice on digital privacy.
CLIMATE SMART SAN JOSÉ
The recommendation in this memo has no effect on Climate Smart San José energy, water, or mobility goals.
COMMISSION RECOMMENDATION/INPUT
This report was not presented at a Commission.
CEQA
Not a Project, File No. PP17-009, Staff Reports, Assessments, Annual Reports, and Informational Memos that involve no approvals of any City action. (Information Technology)
PUBLIC OUTREACH
This memorandum will be posted on the Public Safety, Finance and Strategic Support Committee agenda website for the March 17, 2022, meeting. In addition, the City will coordinate with the Economic Recovery Task Force, Digital Privacy Advisory Task Force, and the Mayor’s Gang Prevention Task Force in engaging the community on an update to the Automated License Plate Reader (ALPR) Data Usage Protocol (DUP). Additionally, signage will be placed at the Monterey and Curtner intersection for the traffic safety pilot. The signage will provide notice of ALPR collection at the intersection and a link to provide feedback on ALPR usage.
PUBLIC SAFETY, FINANCE, AND STRATEGIC SUPPORT COMMITTEE March 8, 2022
Subject: Digital Privacy Program Status Report
COORDINATION
This memorandum has been coordinated with the City Manager’s Office, Police Department, Department of Transportation, and City Attorney’s Office. /s/
ROB LLOYD
DEPUTY CITY MANAGER/
CHIEF INFORMATION OFFICER
For questions, please contact Albert Gehami, Digital Privacy Officer, at (408) 793-6878 or [email protected].