Department of Public Health: Closed Circuit Television Cameras (CCTVs) Surveillance Impact Report

As required by San Francisco Administrative Code, Section 19B, departments must submit a Surveillance Impact Report for each surveillance technology to the Committee on Information Technology ("COIT") and the Board of Supervisors.

The Surveillance Impact Report details the benefits, costs, and potential impacts associated with the Department's use of surveillance cameras (hereinafter referred to as "surveillance technology").

DESCRIPTION OF THE TECHNOLOGY

This is a description of how the technology works:

To protect and promote the health of all San Franciscans. SFDPH strives to achieve its mission through the work of two main Divisions – the San Francisco Health Network and Population Health In line with its mission, the Department shall use security cameras only for the following authorized purposes:

Authorized Use(s):

1. Live monitoring.
2. Recording of video and images in the event of an incident.
3. Reviewing camera footage.
4. Providing video footage/images to law enforcement or other authorized persons following an incident.

Prohibited use cases include any uses not stated in the Authorized Use Case section. Further, processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, gender, gender identity, disability status, or an individual person’s sex life or sexual orientation, and the processing of genetic data and/or biometric data for the purpose of uniquely identifying an individual person shall be prohibited. Department technology may be deployed in the following locations, based on use case: The Critical Infrastructure Camera system records video of the private and sensitive entry ways and exits for City and County’s public buildings.

TECHONOLOGY DETAILS

The following is a product description: The Lenel CIC solution provides video surveillance of CCSF medical facilities’ private and secure areas. A. How It Works To function, healthcare industry standard video surveillance and capture technology. Data collected or processed by security cameras will not be handled or stored by an outside provider or third-party vendor on an ongoing basis. The Department will remain the sole Custodian of Record.

IMPACT ASSESSMENT

The impact assessment addresses the conditions for surveillance technology approval, as outlined by the Standards of Approval in San Francisco Administrative Code, Section 19B:

1. The benefits of the surveillance technology outweigh the costs.
2. The Department's Policy safeguards civil liberties and civil rights.
3. The uses and deployments of the surveillance technology are not based upon discriminatory or viewpoint-based factors and do not have a disparate impact on any community or Protected Class.

The Department's use of the surveillance technology is intended to support and benefit the residents of San Francisco while minimizing and mitigating all costs and potential civil rights and liberties impacts of residents.

B. Civil Rights Impacts and Safeguards

The Department has considered the potential impacts and has identified the technical, administrative, and physical protections as mitigating measures:

DPH believes Tenant/Contractor security cameras pose potential risks to civil liberties in respect to dignity loss and loss of liberty.

An individual could be embarrassed or experience emotional distress if cameras capture behaviors, appearances, or circumstances by which they might feel humiliated. Examples include views of someone exhibiting an emotional outburst, a person's clothing or hair being disheveled, or someone having their physique ridiculed or leered at. Risks for loss of dignity are reduced by restricting access to live views, as well as any recorded footage shared with Department by Tenant/Contractor, to a limited number of trained Security staff. In addition, live camera views provided to Department staff do not pan, tilt or zoom, thus removing possible temptation for system operators to use those features to follow or enhance views of individuals. Audio is also not recorded or enabled.

Loss of liberty could potentially occur if a person were to be misidentified as the perpetrator of a crime or other incident, making them subject to wrongful arrest. An innocent person might be similar in appearance to someone who committed an offense. Surveillance images could reinforce other circumstantial evidence tying the wrong person to a criminal incident. As an example, someone might be wearing clothing like clothing worn by someone seen leaving an office where a theft had just occurred. Loss of liberty risks due to misidentification of a subject in surveillance video is mitigated by restricting access to live views and any recorded footage shared with Department by Tenant/Contractor to a limited number of trained personnel.

DPH IT defers to the City Attorney’s Office on all legal matters.

The Department funds its use and maintenance of the surveillance technology through: City and County, DPH General Funds

COMPARISON TO OTHER JURISDICTIONS

CIC are currently utilized by other governmental entities for similar purposes.

APPENDIX A: CRIME STATISTICS

Department: Department of Public Health

Section 19B requires each department in their Surveillance Impact Report to respond to the following question if applicable, “the general location(s) [of the surveillance technology] may be deployed and crime statistics for any location(s).”

The Public Health Department operates a total of 509 Security Cameras at the following locations:

Information on crime statistics in 2020 in this area is provided by the San Francisco Police Department. Statistics are taken from a 1-block radius around the location of cameras. All information is obtained through the San Francisco Open Data Portal.

In addition, the department maintains an internal incident log which is available on request.