Matters ▸ Attachment
Impact Report - GLX Cameras_12_17_20 — File 211105
PerAPPENDIX A: SURVEILLANCE TECHNOLOGY IMPACT REPORT
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Department or Division:
Somerville Police Department (SPD)
Compliance Officer (name and
position):
Lt. Jeff DiGregorio
Submitted by:
Lt. Jeff DiGregorio
Date:
Surveillance Technology:
GLX Cameras
X
Please identify the purpose(s) of the proposed surveillance technology.
Select ALL that apply by entering “X” in the left column.
Identifying and preventing threats to persons and property and preventing injury to persons or
significant damage to property
x
Identifying, apprehending, and prosecuting criminal offenders
x
Gathering evidence of violations of any law in criminal, civil, and administrative proceedings
x
Providing information to emergency personnel
Documenting and improving performance of City employees
Executing financial transactions between the City and any individual engaged in a financial
transaction with the City
Preventing waste, fraud, and abuse of City resources
Maintaining the safety and security of City employees, students, customers, and City-owned or
controlled buildings and property
Enforcing obligations to the City
Operating vehicles for City business
Analyzing and managing service delivery
Communicating among City employees, with citizens, or with third parties
Surveying and gathering feedback from constituents
Other (Describe):
To monitor roadways affected by the ongoing and ever changing impact on traffic patterns
caused by GLX project
If the surveillance technology is used for a purpose not listed above, does the purpose comply
with the surveillance use policy? __x_ Yes ___ No
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Complete ALL of the following items related to the proposed surveillance technology. Be as specific as possible.
If an item is not applicable, enter “N/A.” Do NOT leave fields blank.
1.
Information describing the surveillance technology and how it works:
Four stationary cameras were installed on city roads to monitor GLX work and the effect on traffic. These
cameras are the same type as the Homeland Security cameras and operate off of the same server.
a.
Authorized use – the uses that are authorized, the rules and processes required before that use, and the
uses that are prohibited (10.64.b.2):
All video surveillance would fall under SPD General Order #423, which articulates the rules, purposes, and policy
of using video surveillance equipment
The cameras are running continuously and are accessible to those with a user account, which includes Detectives,
Traffic, Station Officers, and Commanders.
The purpose is to monitor traffic in the areas around GLX
construction. These cameras operate on the same server as the Homeland Security cameras and those with
access to city cameras have access to the 4 GLX cameras as well.
The camera's primary use is to monitor traffic in relation to the GLX project. The Homeland Security Sergeant is
the primary liaison for the company that maintains them, Lantel, and the Boston Office of Emergency
Management. Cameras can be also accessed in case of public emergency, accident investigation, or criminal
investigation. The cameras can be accessed by police personnel to monitor roads as well as the camera system in
police headquarters. Station officers and shift commanders would log into this system to view cameras in the cell
block to insure the well being of those in custody. Currently the Homeland Security cameras and GLX cameras
run on the same server as the cameras in police headquarters, so access would be granted to all of the cameras
on that system.
b.
Training – the training, if any, required for any individual authorized to use the surveillance technology or
to access information collected by the surveillance technology, including whether there are training
materials (10.64.b.9):
SPD General Order #423 provides the following in regards to training- “The Chief of Police, or his/her designee,
shall ensure that all department personnel successfully complete training which the Chief of Police deems
necessary to successfully operate and monitor Video Surveillance Equipment. Furthermore, the policy states “
Superior Officers and Detectives shall receive training in the operation of the system, including but not limited to
, logging on, angle manipulation (pan, tilt, zoom), and retrieving archive video.” Patrol Officers would be trained
in regards to the location of cameras and familiarization of the system. Lantel, the company that installs and
maintains the cameras, offers on site training in the use of these cameras.
Lantel, the company that installs and maintains the cameras, offers on site training in their use. There are no
training manuals, however lantel will assist with technical needs and questions.
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2.
Information on the proposed purpose(s) for the surveillance technology (10.64.b.1):
Purpose of this technology is to monitor traffic conditions affected by GLX construction. If certain routes are
overly congested, a traffic mitigation plan can be made with the help of this data.
3.
Information describing the kind of surveillance the surveillance technology is going to conduct and what
surveillance data is going to be gathered (10.64.b.3):
Cameras are used to monitor traffic on roads affected by GLX construction.
a.
Data access – the individuals who can access or use the collected surveillance data, and the rules and
processes required before access or use of the information (10.64.b.4):
Use of this technology falls under the guidelines established in SPD policy 423 - Video Surveillance.
Those with access capabilities can view live feeds from the camera in real time. If footage is needed for an
investigation it can be preserved.
All requests for copies of recorded images from the SPD camera system
Preservation of video would be made in an active investigation, assigned a case number, and done with the
knowledge and authorization of a detective supervisor. Requests for copies of recorded images police
department or court personnel shall be made to the Administrative Captain or his/her designee. At this time the
Homeland Security Sergeant is the Administrative Captain’s designee. As of this report these 4 cameras have not
been used in the course of a criminal investigation.
Preservation of video and video retrieval will be the responsibility of the Homeland Security Sergeant as the
Administrative Captain’s designee. Examples of circumstances where video preservation and retrieval would be
necessary may include, evacuation route planning, traffic monitoring, investigative purposes, and motor vehicle
crash reconstruction.
b.
Data protection – the safeguards that protect information from unauthorized access, including, but not
limited to, encryption, access-control, and access-oversight mechanisms; (10.64.b.5)
The SPD has issued General Order #423 entitled ‘Video Surveillance’. The purpose of this order is to establish
general procedures for conducting video surveillance, establish internal control processes and procedures to
ensure the protection of individual’s civil rights. All users need to log into department computers to view the
camera application. The access is tracked via a user log, and this log would be available through a user audit.
Video is only viewable by department members with login access.
Some members of the department are
required to log into the system as a course of their regular duties. Station officers would need to view cameras to
monitor arrestees while in custody of the SPD.
The Traffic unit would have access to monitor live feeds of
roadways in the city. Commanders would have access to monitor cameras within the SPD to ensure safety of the
personnel in the building as well as people in custody of the SPD. Since all of the cameras operate on the same
server there is no way currently to differentiate access to certain devices.
c.
Data retention – the time period, if any, for which information collected by the surveillance technology
will be routinely retained, the reason that retention period is appropriate to further the purpose(s), the
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process by which the information is regularly deleted after that period has elapsed, and the conditions
that must be met to retain information beyond that period (10.64.b.6):
Data retention is 30 days unless recording is preserved .
d.
Public access – if and how collected surveillance data can be accessed by members of the public,
including criminal defendants (10.64.b.7):
Members of the public can make a Public Information Request through the Administrative Captain in writing.
This request is then forwarded to the City of Somerville Law Department for final approval. If the video is
preserved for a criminal investigation and becomes evidence and it is subject to discovery.
e.
Third-party data-sharing – if and how other city or non-city entities can access or use the surveillance
data, including any required justification and legal standard necessary to do so, and any obligation(s)
imposed on the recipient of the surveillance data (10.64.b.8):
Video could be shared with other city or law enforcement agencies depending on the type of investigation. i.e.
State police investigating an accident on McGrath Highway.
Select members of the Somerville Police Department, Fire Department (Chief Breen, Deputy-Chief Majors, Fire
Alarm) and the DPW Highway Superintendent can view the cameras on these servers. Any outside agency would
make a request for footage per SPD Policy #423 - Video Surveillance (Section 9, subsection B).
4.
The location(s) it may be deployed and when:
Locations are based on areas affected by GLX work and could change. At the time of this report there are two
cameras on Broadway (Broadway @ Boston Ave. and Broadway @ Cedar St). There is a camera at Cedar St. and
Morrison Ave. and another camera at College Ave. @ Morrison Ave.
5.
A description of the privacy and anonymity rights affected and a mitigation plan describing how the
department’s use of the equipment will be regulated to protect privacy, anonymity, and limit the risk of
potential abuse:
Cameras are in fixed positions and used for evacuation route planning, traffic monitoring, investigative purposes,
motor vehicle crash reconstruction. Although these cameras capture all items with their range of view, their use
is designed to capture traffic patterns, not citizen activities.
SPD policy number #423 states “ The Video
Surveillance System shall be used to view only what is in the general public’s view. Monitoring anything that
would be deemed an invasion of privacy would be prohibited.”
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6.
The potential impact(s) on privacy in the city; the potential impact on the civil rights and liberties of any
individuals, communities or groups, including, but not limited to, communities of color or other marginalized
communities in the city, and a description of whether there is a plan to address the impact(s):
The Somerville Police have a Bias Based Policing Policy (#115).
This policy emphasizes the Department’s
commitment to protecting the Constitutional and civil rights of its citizens. Any misuse of these cameras to police
prejudicially would be a violation of department policy.
Cameras are installed in locations based on GLX
construction and not on particular populations. Any movement of cameras for an investigative reason would
have to be approved by a detective supervisor. Cameras could only be moved for a legitimate law enforcement or
emergency reason. Log in procedures and user logs would track users and help ensure against abuse.
Camera positions are based on GLX construction and traffic impact. Cameras are on city roads and directed at
traffic flow. They are not positioned on any other basis other than traffic observation and would be placed on
roads affected by GLX construction on a temporary basis.
7.
An estimate of the fiscal costs for the surveillance technology, including initial purchase, personnel and other
ongoing costs, and any current or potential sources of funding:
$23,417.65 for the 4 cameras and installation. These cameras are on the same server as other city cameras so
there would be no additional costs other than repair. The Homeland Security Sergeant and the Special Operations
Lieutenant are in charge of managing and maintaining video operations in the SPD as part of their assigned
duties.
8.
An explanation of how the surveillance use policy will apply to this surveillance technology and, if it is not
applicable, a technology-specific surveillance use policy:
Since this technology involves city owned cameras on city roads, the city’s Surveillance Policy would apply.
a.
Oversight – the mechanisms to ensure that the surveillance use policy is followed, including, but not
limited to, identifying personnel assigned to ensure compliance with the policy, internal record keeping
of the use of the technology or access to information collected by the surveillance technology, technical
measures to monitor for misuse, any independent person or entity with oversight authority, and the
sanctions for violations of the policy (10.64.b.10):
The Homeland Security Sergeant and Special Operations Lieutenant would oversee cameras and their placement.
Department policy would serve as a guideline for use and retention of data from these cameras. Any misuse and
violation of department policy could lead to discipline up to and including termination.
The Homeland Security Sergeant and Special Operations Lieutenant have been designated by the Chief of Police,
based on their familiarity with the platform and their positions as supervisors.
Currently, The Somerville Police have a Video Surveillance Policy (#423) that would establish internal control
processes and procedures to ensure the protection of individual’s rights and to ensure the efficiency and
effectiveness of video surveillance operations. The system generates an access log, which can be preserved if
necessary through the IT department, that tracks username log-ins.
This would allow for monitoring and
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identification of who used the technology and when.