CC SR 20241106 I - Security Camera Video Retention Policy
CITY COUNCIL MEETING DATE: 11/06/2024
AGENDA REPORT AGENDA HEADING: Consent Calendar
AGENDA TITLE:
Consideration and possible action to adopt a City Council Policy on Security Cameras
and Video Retention.
RECOMMENDED COUNCIL ACTION:
(1) Adopt City Council Policy No. 59, the City’s Security Camera and Video Retention
Policy.
FISCAL IMPACT: None
Amount Budgeted: N/A
Additional Appropriation: N/A
Account Number(s): N/A
ORIGINATED BY: Matt Waters, Senior Administrative Analyst, Recreation and Parks
REVIEWED BY: Daniel Trautner, Director, Recreation and Parks
APPROVED BY: Ara Mihranian, AICP, City Manager
ATTACHED SUPPORTING DOCUMENTS:
A. Draft City Council Policy No. 59 (page A-1)
B. September 17, 2024 City Council Staff Report
BACKGROUND:
The City Council does not have a policy establishing guidelines for the placement of
security cameras on City property and the retention of video footage recorded by those
cameras. 15 security cameras were installed as part of the Ladera Linda Community
Park Project that opened to the public in February 2024. There are also four cameras
located inside the Point Vicente Interpretive Center building that can be monitored at the
front desk. Most recently, Open Space Management Staff (OSM) purchased five
cameras for use in the Preserve at trailheads and on trails, including in the Del Cerro
area. At its September 17, 2024 meeting, the City Council approved the purchase and
installation of 12 additional security cameras to be installed at nine different open space
areas and City-owned parking lots, as part of an expanded pilot program to better monitor
for incidents of vandalism, accidents, and crimes in these areas .
1
DISCUSSION:
Given the use of cameras at Ladera Linda Community Park, the Point Vicente Interpretive
Center, and various open space areas and City-owned parking lots, City Staff developed
a policy outlining the appropriate use of the equipment and any resulting video footage.
City Staff and the City Attorney have prepared a draft Security Camera and Video
Retention City Council Policy to provide clear guidelines on security camera installation
and operation, privacy concerns, and procedures for the proper storage, retention, and
dissemination of recorded images (Attachment A).
The attached policy consists of the following six sections for the City Council’s
consideration:
A. Scope: Outlines the limits on allowable uses of the security footage including
intelligence gathering for criminal conduct and the identification and apprehension
of suspected criminals. The public’s right to privacy is emphasized in this section.
B. Responsibilities: Provides details on who is responsible for maintaining public
safety, managing the cameras, and determining permittable access to camera
footage.
C. Equipment: Outlines guidance and limitations on where and how the cameras will
be mounted and used, including privacy restrictions.
D. Access and Third Party Sharing of Security Camera Data: States that recorded
images are for official use only. Outlines policy guidelines for access and sharing
of images to the extent required by law.
E. Data Storage of Security Cameras: Details how the video footage will be stored
and how long it will be retained.
F. Security Camera Training: States all personnel authorized to use or access the
cameras or footage will be properly trained.
CONCLUSION:
To memorialize the City’s position on security cameras and video retention, Staff
recommends the City Council adopt the attached policy which, if adopted, will be added
to the City Council Policies.
ALTERNATIVES:
In addition to the Staff recommendation, the following alternative actions are available for
the City Council’s consideration:
1. Do not adopt City Council Policy on Security Cameras and Video Retention and
provide Staff direction on how to address matters related to security cameras.
2. Identify revised language that can be read into the record or direct staff to return
with a revised policy for City Council consideration at a future meeting.
3. Take other action, as deemed appropriate.
2
CITY COUNCIL POLICY
NUMBER: 59
DATE ADOPTED/AMENDED: 11/6/2024
SUBJECT: Security Camera and Video Retention
BACKGROUND:
The City of Rancho Palos Verdes (“City”) is committed to establishing and
maintaining a safe and secure environment for both City employees and visitors of City
property and facilities. To assist with creating a safer environment, the City operates and
maintains a security camera system in and around various public trails, parks, parking
lots, and facilities.
This Policy provides a comprehensive guideline for approval, placement,
monitoring, access, and operation of the City’s security camera equipment, storage, and
retention of capture images including the dissemination of stored data related thereto.
This Policy does not address, restrict, enhance, or modify standards for portable video or
still recording of City sponsored program, events, or activities.
POLICY
A. Scope
The City recognizes the need to protect the public’s constitutional standards of
privacy. Any use of the data produced by security cameras other than the uses described
below are strictly prohibited. Security camera recorded images may be used for and/or
assist with the following purposes:
• Identification and prevention of threats;
• Identification, apprehension, and prosecution of individuals suspected of
committing criminal offenses;
• Intelligence gathering to prevent or prosecute criminal conduct;
• Response to emergency services personnel for emergency events; and
• Assistance in resolving citizen or employee complaints, internal investigations, or
other City or law enforcement investigations.
Footage shall not:
• Be used to target legally protected individual characteristics including, but not
limited to race, ethnicity, national origin, religion, disability, gender, or sexual
orientation; and
• Be used to harass, intimidate, or discriminate against any individual or group.
A-1
B. Responsibilities
• The City Council is responsible for approval and oversight of the City’s security
camera use.
• The City Manager, Risk Manager, and Los Angeles County Sheriff share
responsibility for managing public safety and security around City facilities.
• The Information Technology (“IT”) Division Manager or designee and the
Recreation and Parks Director or designee are responsible for maintaining storage
of electronic data from the security camera systems. The IT Division Manager or
designee and the Recreation and Parks Director or designee are also responsible
for maintaining the functionality of the security camera systems.
• Authorized staff are responsible for maintaining the physical media within the
cameras. IT and designated Recreation and Parks Staff are responsible for directly
implementing or overseeing the placement of the security cameras by consultants.
Any new camera locations require approval by the Director of Recreation and
Parks and the City Manager.
• Camera feeds or recordings shall be viewable only by the City Manager, IT
Manager, the Director of Recreation and Parks, Open Space Management Staff,
the Los Angeles County Sheriff’s Office, and the City Attorney, or their designees.
C. Equipment
City’s security camera equipment:
• Will be in a fixed, visible location;
• Will only monitor City facilities, trails, and public areas where no reasonable
expectation of privacy exists;
• May be located inside and outside buildings, facilities, and/or trails, and will not be
directed to look through windows to areas outside the buildings, facilities, or trails
unless necessary to protect external assets in the promotion of the personal safety
of individuals, or deter criminal activity;
• Will not be directed to look into adjacent, non-City owned buildings or private
property;
• Will be marked in a conspicuous manner with signage informing the public and
employees that the area is under surveillance. Signs will be posted in letters of a
size that is easy to read, include pictures, and have no visibility obstructions;
• Will not intentionally invade the privacy of individuals or observe areas where a
reasonable expectation of privacy exists;
D. Access and Third Party Sharing of Security Camera Data
• All recorded video images gathered by the security camera equipment are for the
official use of the City. Recorded information will never be sold and will not be
publicly viewed or distributed in any other manner, except as provided by this
policy and applicable to federal and state law (5 U.S.C.A. § 552 et seq.; Gov. Code
§ 7920.000 et seq.).
• Camera systems that do not have a dedicated physical server must have their
access passwords changed and a list of authorized users updated on a monthly
basis.
A-2
• Routine video monitoring records are investigative records and not subject to
disclosure pursuant to Government Code 7922.000 et seq., apart from the
exception described in section (F) below.
• Victims of crimes or insurance carriers against whom a claim has been or might
reasonably be made will have access to information acquired through routine video
monitoring, but only to the extent required by law. (Gov. Code § 7922.000 et seq.)
• Requests for recorded video images from other law enforcement agencies will be
referred to the Los Angeles County Sheriff’s office for release in accordance with
law enforcement purposes.
• Recorded video images that are the subject to a court order or subpoena document
production request will be produced in accordance with the established City
Department(s) subpoena process. This process will require coordination with the
City Clerk.
• Any viewing of the security camera feed or recordings by anyone other than
expressly permitted personnel is prohibited. The City Manager, the City Attorney,
and the Los Angeles Sheriff’s Department must review and may grant access to
an individual requesting to view a recording from the security system and only as
may be required by applicable law and this policy.
• All authorized personnel will receive training, in order to access the system.
• Images stored on servers will only be accessed and retrieved by the IT Manager,
the Recreation and Parks Director, the Open Space Management personnel, and
any designee authorized by the City Manager for the purposes prescribed by this
Policy.
Note: Any employees found to have accessed information without granted access
pursuant to these guidelines will be subject to discipline, up to and including termination.
E. Data Storage of Security Cameras
• All video will be recorded and stored digitally with restricted access to authorized
persons. Records will be retained for up to 180 days. After 180 days, the records
will be automatically deleted or overwritten with no backups on the server.
• Certain recorded images needed as evidence in a criminal, civil, or administrative
proceeding will be copied to a suitable medium and booked into evidence in
accordance with Los Angeles County Sheriff’s evidence procedures.
• Security camera images relating to potential criminal charges that are not filed will
be retained for at least one year after the statute of limitations has expired.
• Security camera recordings related to complaints of employee misconduct
(whether externally or internally) shall be retained in accordance with relevant law
and in coordination with the City Attorney and law enforcement or until the matter
has been resolved, whichever is later.
• Any downloaded media will be stored in a secure area with access restricted to
authorized persons from the office of the City Manager or the office of the City
Attorney. A copy of the downloaded media will be retained by the IT Division
• Storage devices will be securely kept in a controlled access area.
A-3
F. Security Camera Training
Any personnel authorized to operate or access the security camera systems will
be informed of the policies that affect their responsibility and receive appropriate training.
Training will include guidance on the usage of the security cameras and a review o f
relevant policies and procedures, including this Policy. Training will also address state
and federal law related to the use of security camera equipment and public privacy.
A-4