SR 08-27-2019 3C
City Council
Report
City Council Meeting: August 27, 2019
Agenda Item: 3.C
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To: Mayor and City Council
From: Katie Lichtig, Assistant City Manager, City Manager's Office
Joseph Cevetello, Chief Information Officer, Information Services
Department, Lane Dilg, City Attorney, City Attorney's Office
Subject: Proposed update to the City’s Privacy Policy to provide the public with a
comprehensive overview of what information the City obtains through the
website and other channels and how the City uses that information
Recommended Action
Staff recommends that the City Council approve an updated privacy policy for the City
of Santa Monica. The updated policy would be accessible on the city’s website,
providing the public with a comprehensive overview of what information the City obtains
through the course of business, including through the website, and how the City uses
that information.
Summary
As a result of advancements in technology, a commitment to use technology to engage
interactively with residents and other community members, and changes in privacy
laws, the City needs to update and expand the scope of its privacy policy. Online
service enrollment, online surveys, electronic newsletters, online alerts, and online
business and payment transactions are all increasingly used by the City to serve the
public, and particularly to make service requests, information, and public safety
notifications available 24 hours a day, seven days a week. The City is equally
committed to protecting the integrity of personal data, both through robust cybersecurity
measures and a comprehensive privacy policy. To advance both commitments, staff is
proposing an updated privacy policy to address what information the City obtains from
members of the public, how the City uses this information, and how community
members can unsubscribe from City-generated communications.
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Discussion
The City’s current privacy policy applies to and is available on the City’s website
(https://www.smgov.net/privacy) (Attachment A). The current privacy policy has not
been updated for a significant period and was adopted prior to the proliferation of digital
communication and online service delivery. Staff proposes an updated privacy policy
(Attachment B) to reflect the rapidly evolving use of technology by community members
to access information and services and ensure a high level of customer service, while
respecting the privacy of individuals accessing City services.
Other local governments have updated their privacy policies recently, and staff found
the updated privacy policies of the Cities of Seattle, Boston, and West Hollywood to
provide good models of contemporary municipal privacy policies. Much of
the updated privacy policy being proposed for the City is based on policies currently in
place in those cities.
The City of Santa Monica provides numerous services and programs and is a source of
official information about policies in the event of an emergency. This requires the City to
receive, collect and store information about the public it serves. The City does not
collect personal information via the website unless it is voluntarily provided, such as by
completing a survey or requesting services. Tracking technologies, such as cookies, are
used to collect information (using tools such as Google analytics) that does not identify
any particular person, for example, general statistical information such as which pages
are visited and for how long or where visitors to the site are generally geographically
located. This enables the City to provide better service through the site and is consistent
with best practices used across industries.
The City does not sell personal identifiable information (PII) to third parties, does not
profit from sharing PII with third parties, and does not sell aggregated anonymized data
to third parties for marketing or commercial uses. If information must be shared with
third parties who provide services for the City, such as ActiveNet, the third party is
contractually held to the same privacy standards as the City.
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The updated privacy policy provides information about when the City uses information
to generate unsolicited electronic communications. For instance, the City does not use a
cell phone number to initiate a call or SMS text message except for certain public safety
emergency notifications. However, if an individual provides the City with contact
information by sending an e-mail, filling out and submitting an online form, or registering
an account, the City may use the information provided to respond and to place the
individual on lists to inform the individual about City initiatives, programs, and events
that may be of interest. Individuals can ‘unsubscribe’ or ‘opt out’ from electronic
communications sent by the City. All email outreach generated by lists provides the
option to opt out of receiving any future emails from that list.
We continue to hear from a small segment of the community that is very resistant to
using electronic processes and communications. The updated privacy policy makes
clear that the City will continue to make every effort to accommodate service delivery for
residents who do not want to provide information electronically. The updated privacy
policy also explains that individuals who elect not to provide information electronically
may not receive all of the information available to those who elect to receive information
electronically absent additional steps or legally required accommodations to receive
information in person or in print.
Financial Impacts and Budget Actions
There is no immediate financial impact or budget action necessary as a result of
recommended action.
Prepared By: Beth Rolandson, Administrative Services Officer
Approved
Forwarded to Council
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Attachments:
A. Attachment A: Existing Privacy Policy
B. Attachment B: Proposed Privacy Policy and Security Statement
C. Written Comments
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City of Santa Monica’s Privacy and Security Statement
Introduction
The City of Santa Monica collects personal information from the public to assist us in providing
many important services, including but not limited to recreation programs, recycling and waste
management, street and landscaping services, permitting, and water delivery. We understand the
value of personal information and strive to find a fair balance between gathering information that
will assist us in better providing these services and protecting the public’s privacy. This privacy
statement explains how and why information is collected from the public, whether in person,
over the phone, through social media or a visit to the City’s website, or by mail (electronic or
otherwise), and how that information is retained and used by the City. This privacy statement
does not apply to information collected by the City for public safety purposes. Due to the
individualized and serious nature of emergency response efforts, a variety of personal
information may be collected by first responders and other personnel as needed. Such data
collection, use, and disclosure practices are subject to separate policies and fall outside the scope
of this privacy statement.
Collection
The City collects different kinds of information from the public to assist in conducting City
operations. Some of this information you provide directly to us. Some of it is collected in the
course of your interactions with the City. Our goal is to collect information only as reasonably
needed to perform City services and provide informed customer care, and to let you know when
providing personal information is optional. We also seek to aggregate or otherwise de-identify
personal data, when possible, whenever it is not necessary to store or share personally
identifiable data elements. Below are some examples of the types of information we collect and
how we collect it.
Website Information
The City collects a range of information about visitors to the City’s website. During your visit to
the City’s website, you may choose to provide personal information online, for example, by
electing to send us an email, complete an online form, or participate in a survey. “Personal
information” is information about you that is readily identifiable to you. Personal information
includes such things as your name, birthdate, address, phone number, social security number, and
driver’s license number. Personal information also includes financial and/or payment card
information, for example, bank account information, credit or debit card numbers, or other
billing information, that you may provide to sign up or pay for City services. We collect no
personal information about visitors to our website unless you voluntarily provide it by sending an
email, participating in a survey, completing an online form, or engaging in an online transaction.
You may choose not to send an email, participate in a survey, provide personal information using
an online form, or engage in an electronic transaction. But you may not be able to access certain
user-specific features of the web site without providing personal information.
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Information collected from all visitors to our website
Even if you do nothing during your visit to our website but browse, read pages, or download
information, certain information will be collected, aggregated and used for analytical and
statistical purposes to help better manage the site. When you visit a page on the site, information
may be automatically collected and stored through the use of cookies and other similar tracking
technologies. Examples of the information that may be collected and stored are:
1. The internet domain (for example, "xcompany.com" if you use a private Internet
access account, or "yourschool.edu" if you connect from a university's domain)
and Internet Protocol (IP) address from which you access the City's website;
2. The type of browser and operating system used to access the City's website;
3. The date, time and duration of the visit, as well as the general geographic location
of the device from which the visit is made;
4. Derived demographic information;
5. The web pages and/or services you accessed during your visit, as well as any
applications used and forms data; and,
6. If you link to the City's website from another website, the address of that other
website.
We may use this data automatically collected through cookies and other technologies to: (a)
remember information so that you will not have to re-enter it during your visit or the next time
you visit the site; (b) provide custom, personalized content; (c) provide and monitor the
effectiveness of our website; (d) monitor aggregate metrics such as total number of visitors,
traffic, usage, and demographic patterns on our website; (e) diagnose or fix technology
problems; and (f) otherwise plan for and enhance our website and the services we provide. For
example, the City's web site uses software programs to create summary statistics, which are used
for such purposes as assessing what information is of most and least interest, determining
technical design specifications, and identifying system performance or problem areas.
We may also use analytic and security tools hosted by third parties or managed within the City as
part of maintaining our web presence. These tools help us measure traffic and usage trends for
our web site and help ensure that this service remains available to all users. These tools can also
be used to monitor network traffic to identify unauthorized attempts to upload or change
information, or otherwise cause damage. Except for authorized law enforcement investigations
and the security purposes mentioned elsewhere in this notice, no other attempts are made to
identify individual users or their usage habits.
The City does not generally use cookies or other tracking technology to track its users across
websites or over time, nor does it permit third-party ad networks or other companies to track
users on our website. Because we do not track users over time and across websites, your use of
the Do Not Track feature on your browser will have no effect on our website.
As noted above, we may employ cookies to control the operation of our website. Cookies are
pieces of information generated by our web server and stored (temporarily) on the end user’s
computer to facilitate the current website visit. In the event a cookie is used, its use will be
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transient in nature and will apply only to the website visit in progress. Generally, if you choose
to, you may disable cookies through your browser settings. (For example, in Google Chrome,
under settings, privacy and security, content settings, you can elect not to allow sites to save and
read cookie data and/or block third-party cookies, and you can also choose to see all cookies.)
Disabling cookies, however, may mean that you are unable to use certain features of our website.
Information collected from website visitors who choose to provide personal
information online.
If during your visit to our website you participate in a survey, send an e-mail, participate in a
City hosted web-based discussion, register an account, participate in online commerce, or
perform some other transaction online, we may collect personal information from you, including:
(a) the e-mail address, and contents of the e-mail, for those who communicate with us via e-mail;
(b) information provided while participating in a City hosted web-based discussion; (c)
information volunteered in response to a survey; (d) information provided through an online
form for any other purpose; (e) information submitted when participating in an online transaction
with the City; and (f) information provided when you register an account. The information
collected is not limited to text characters and may include location, audio, video, and graphic
information formats you send us.
In order to provide online transaction capabilities, the name, address and payment information (if
applicable) that you provide when using this website may be collected and processed to complete
an online transaction and for record-keeping for such activities as billing, permits, licenses and
other business-related purposes. Every effort is made to protect any sensitive personal
information you provide online. For online payment transactions, we use a third-party payment
processor that has in place industry-standard data security protocols to ensure that the payment
transactions will be conducted securely. If City personnel take payment information, it is used
only for the transaction at hand and is not kept, stored, or used for any other purpose. The City
does not store credit card information on any of its servers and will not disclose credit card
information to any third-party except as necessary to complete your online transaction or as
required by law.
Information collected from your mobile device.
If you access our website and online services or use an application on a mobile device, we may
collect certain information about that device. Messages sent from certain mobile devices contain
unique identifiers about the physical location of such devices. Mobile devices also typically
transmit caller ID data when used to transmit a telephone call or text message. Depending on the
device and its settings, this information includes but is not limited to geolocation data, unique
device identifiers and other information about your type of device, wireless provider, date and
time of transaction, browser type, browser language and other transactional information.
We may use this information to contact you and to respond to requests. With the exception of
certain public safety emergency notifications, we will not use your phone number to initiate a
call or SMS text message to you without your express prior consent.
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The City of Santa Monica may periodically offer non-emergency SMS alerts. These alerts will
only be sent to those who have subscribed to them, and subscribers will be provided with the
option to cancel their subscription. By signing up to receive those alerts, subscribers
acknowledge that SMS message charges may apply depending on their individual mobile carrier
and plan. Your wireless carrier and other service providers also collect data about your SMS
Service usage, and their practices are governed by their own privacy policies.
Paper forms
City departments may collect information on paper forms as part of providing a government
service or community engagement. These forms may request personal information, such as
name, birthdate, address, telephone number, and email address. Forms may also request
additional information necessary to determine eligibility for a service, such as income. When
possible, forms will note what information is required to obtain a government service or
participate in a government function, what information is optional, and if there are options for
opting out of certain data uses, such as follow-up communications not directly related to the
service being requested. City personnel will handle and store paper forms containing personal
information using methods intended to ensure the security of the personal information.
Telephone calls
Individuals may contact the City via phone such as when calling a City department or staff
member directly. Our phone system automatically logs the phone number and other
characteristics of calls to and from City numbers, such as call duration and the extension in the
City that received or made a call. It is not possible to opt-out of this collection. During the course
of your call to a City call center, we may ask for additional information. This information will be
used to help provide the requested service. The call taker will inform you about what information
may be optionally provided. We will also provide notice if, and when a call center records a call
for training purposes or to improve the services. We may also collect personal information when
we call you or notify you of an event via phone or text message, including by creating a record of
when a call was made and whether it was received by a live person. With the exception of
certain public safety emergency notifications, we will not use your phone number to initiate a
call to you without your express prior consent.
Email communications
When you send an email to a City email address, such as hello@santamonica.gov, we collect
personal information that may be contained in the email message and automatically log certain
information about the message, including the sender information, the IP address, routing
information, and email address. It is not possible to opt-out of this collection. In some cases,
when the City sends an email to a user, it may contain beacons, which help the City track which
emails have been opened and which links are clicked by our recipients.
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Opting-Out
While it may limit the services we are able provide or limit the services you are able to access
online, where it is possible we will present information about what we are collecting and provide
an opportunity to decline to provide it to us and/or to opt-out of uses we may take with the
information, such as using your email address to send follow-up communications not directly
related to the service being requested. Please understand that in some circumstances, we may not
be able to provide the desired services if you decline to provide necessary information.
Using your information
We recognize that the public expects government both to protect individual privacy and to
operate effectively. Toward that end, the City of Santa Monica uses personal information in the
course of providing services, protecting the public’s safety, meeting our mission obligations, and
determining the best use of our resources. We endeavor to collect only as much information as is
necessary to perform these functions and to limit information use to the purpose stated at the
time of collection and to protect and improve our services. Here are examples of the use we
make of information we collect.
Research and Audit
We may use information we collect to help the City better understand community needs and
improve the efficiency, effectiveness, and equity of our service delivery. When performing
research, attempts will be made to de-identify data, either performing analysis at an aggregate
level or removing data elements containing personal information that are not necessary for
analysis.
We may also use collected information to ensure that our online website services remain
available to all users, to detect fraudulent transactions, and to identify unauthorized attempts to
upload or change information or to otherwise interfere with service delivery.
Informational Communications
Should you provide the City of Santa Monica with personal information by sending an e-mail,
filling out and submitting an online form, or registering an account, the information provided
may be used to respond to you and to assist in providing you with the information or service
requested. Survey information is used for the purpose identified by the survey. Information from
online forms and account registrations is used for conducting City business related to the online
form or account registration.
In addition to the uses described above, personal information you provide may be used to place
you on email lists used to generate emails to you to inform you about City initiatives, programs,
and events that may be of interest to you. Any email you receive as a result of being placed on
such a list will provide you with the option to opt out of receiving future emails from that list.
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Personal information you provide may also be used to invite you to subscribe to email or e-
newsletter services that may be of interest to you. The City offers several email and e-newsletter
services to inform users about City initiatives, programs, and events. These are all “opt-in”
email and e-newsletter services, meaning that users must indicate their interest by choosing to
subscribe to the email or e-newsletter service and providing their email addresses. If you choose
to subscribe to a City email or e-newsletter service, you will always have the option of canceling
your subscription or changing your preferences – this option will be included at the bottom of
each email or e-newsletter you receive. Any online form, account registration, or survey
response you submit will include at the bottom an option to opt-out of receiving any invitations
to subscribe to email or e-newsletter services.
Sharing your information
We do not sell personal information to third parties, nor do we profit from sharing personal
information with third parties. We may share personal information to coordinate delivery of
services to the public, improve customer service, maintain data consistency, assess program
performance, and identify opportunities to improve our operations. We may also share
information where we are required to do so by law. We may also share information that has been
aggregated or de-identified. How we do and do not share personal information is described
below.
Internal sharing within the City
We share personal information within the City to enable different City departments to use that
information to assist in providing the services for which they are responsible, to assess their
performance, to improve their customer service, and to identify opportunities to improve their
operations.
Sharing with third-parties
We share personal information with third parties who provide services on behalf of the City
when that personal information is necessary for them to provide the services. For example, the
City may share personal information with a consultant who is doing research on behalf of the
City that requires the use of personal information to provide meaningful results. The City also
contracts with third parties to handle data containing personal information. For example, the
City contracts with third parties to process financial transactions, technology companies that
provide cloud and managed services, and analytics companies that measure traffic visiting the
City’s websites. In doing so we comply with state and federal laws and follow information
security practices to protect both physically and electronically stored and transmitted data. We do
not sell personal information to third parties for marketing purposes or for their own commercial
use. The City also does not sell aggregated, anonymized data to third parties for marketing
purposes or for their own commercial use. Certain of the third parties with whom the City
contracts may, however, market aggregated, anonymized data derived in whole or in part from
City data.
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Sharing with government agencies
We may share information with other government agencies, external service providers,
researchers, contracted vendors, and others to perform city functions and comply with applicable
laws. We ask third parties to abide by our privacy principles when handling data provided by the
City. In many cases, we require compliance through contractual obligations that include: (a)
providing notice when information is collected and used on our behalf by contracted third
parties; and (b) directing that contracted third parties agree to and follow our contractual privacy
requirements.
Public record disclosures
You should be aware that information that you provide to the City of Santa Monica, whether
through the City’s website, emails sent to the City, or any other methods, may be considered
public records pursuant to the California Public Records Act, Government Code §§ 6250 et seq.
(PRA). As a government agency, we are subject to this law, and any information received
through the City’s website is subject to the same provisions as information provided on paper.
As a result, under some circumstances, some of the personal information you provide, including
your email address, may not be considered private and may be subject to disclosure under the
PRA. For a more complete discussion of the PRA, please refer to the California Attorney
General’s summary of the PRA and/or the California League of Cities guide to the PRA, which
can be found at the following links:
http://ag.ca.gov/publications/summary_public_records_act.pdf
https://www.cacities.org/Resources/Open-Government/THE-PEOPLE%E2%80%99S-
BUSINESS-A-Guide-to-the-California-Pu.aspx.
Retention
Public records created or received by the City must be retained for legal or operational purposes
according to applicable laws. As a government entity, much of the information that the City
collects is considered a public record regardless of format or where it is stored. The City
maintains a records retention schedule indicating the standard time periods for retention of
identified categories of records. A copy of the City’s current records retention schedule is
maintained by the City Clerk.
Accuracy
We take reasonable steps to ensure that personal information we have is up-to-date. Where
possible, we implement processes for updating inaccurate information that is used in the course
of doing business.
Accountability
We comply with laws, statutes and regulations that govern the information we collect. We also
seek to follow best practices and implement internal policies to reduce or eliminate the potential
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impact of new technologies and practices on the public’s privacy. Should we become aware of
programs or applications that are contrary to this privacy statement we will take steps to educate
staff and remediate the issue. .
Endorsements and Links
Content on the City of Santa Monica’s website is intended to provide information about City
services and City events, keep residents and visitors informed about matters of interest, and help
the City fulfill service requests. Any inclusion of third-party hyperlinks, images, applications, or
references on the site does not constitute an endorsement or recommendation by the City of
Santa Monica. Their inclusion is simply to provide website visitors with relevant information
and resources.
The City of Santa Monica’s website has many links to other websites. These include links to
websites operated by other government agencies, nonprofit organizations, and private businesses.
When you use a link to access another website, you are no longer on the City of Santa Monica’s
website and the City of Santa Monica’s privacy and security policy will not apply. When you
use a link to access another website, you will be subject to, and we encourage you to examine,
the privacy and security policy of that new site.
Children
A number of pages on the City of Santa Monica’s website provide information about youth
services and programs. And, in signing children up for youth services or programs, parents may
be asked to provide personal information for their children. This personal information will be
subject to the same protections and limitations on use and sharing specified in this privacy
policy.
Security
For site security purposes and to ensure that this website and the services offered through it
remain available to all users, the City of Santa Monica employs commercial software designed to
monitor network traffic to identify unauthorized attempts to upload or change information, or
otherwise cause damage. Unauthorized attempts to upload information or change information on
this website or any of the services offered through it are strictly prohibited and may be
punishable by law.
The City has taken steps to safeguard the integrity of its data and to prevent unauthorized access
to information it maintains. Depending on the type of information, we may use physical,
administrative and technological techniques to protect data including but not limited to access
control, monitoring, auditing, and encryption to secure data. Security measures have been
integrated into the design, implementation and day-to-day practices of the entire operating
environment as part of the City’s continuing commitment to protecting our environment.
This information should not be construed in any way as giving business, legal, or other advice, or
warranting as fail proof, the security of information provided via the City's web site. Please
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remember that no security system is impenetrable, and we cannot guarantee the security of our
systems 100%. In the event that any information under our control is compromised as a result of
a breach of security, the City will take reasonable steps to investigate the situation and where
appropriate, notify those individuals whose information may have been compromised and take
other steps, in accordance with any applicable laws and regulations.
Intellectual Property
Some content on the City’s website, including the City logo, the Santa Monica City Pier logo,
and other graphics and images, are copyrighted either by the City of Santa Monica or by a third-
party provider. Any third-party images, graphics, or content on our website is used with
permission from the copyright holder. Before reproducing or otherwise using any content from
our website, including images and graphics, users must obtain permission from the appropriate
copyright holder. If you wish to use any content from our site as to which the City of Santa
Monica holds the copyright, or to inquire as to who the copyright holder for certain content is,
please submit an inquiry to hello@santamonica.gov (be sure to specify the page on which the
content appears, and the specific content on that page to which your inquiry pertains). The
City’s website also uses the City of Santa Monica Seal. Santa Monica Municipal Code §
2.32.020 prohibits use of the City Seal for anything but official City business.
Disclaimer
The City of Santa Monica is neither responsible nor liable for any viruses or other contamination
of your system nor for any delays, inaccuracies, errors or omissions arising out of your use of the
City’s website or out of material obtained from this website, including without limitation, any
material sent to you via the City’s website.
The information and materials on our website have been compiled from a variety of sources and
are subject to change without notice. The City of Santa Monica does not make any warranties or
representations with respect to the content, quality, accuracy, or completeness of any information
or materials contained on our website or through links to other websites, including but not
limited to: text, graphics, applications, databases, services, or any other information or materials.
The City’s website and all materials distributed on it are distributed and transmitted "as is"
without warranties of any kind, either express or implied, including without limitation,
warranties of title or implied warranties of merchantability or fitness for a particular purpose.
The City of Santa Monica is not responsible for any special, indirect, incidental, or consequential
damages that may arise from the use, completion, or accuracy of financial transactions conducted
on, or the inability to use, our website and/or the materials distributed by our website, whether
the materials distributed by our website are provided by the City of Santa Monica or a third
party.
Communications to the City of Santa Monica via the City’s website shall in no way be deemed
to constitute legal or official notice to the City, its agencies, officers, employees, representatives
or agents with respect to any existing, pending or future claim or cause of action against the City
or any of its agencies, officers, employees, representatives or agents where notice is required by
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Federal, State or local law. Nor shall communications to the City via the City’s website be
deemed to constitute legal or official notice for any other purpose.
Contact
If you have any questions regarding the City of Santa Monica’s privacy statement or data
security, or if you have any comments, suggestions, or corrections regarding the information
contained on the website, please contact us at: hello@santamonica.gov.
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Vernice Hankins
From:Council Mailbox
Sent:Tuesday, August 27, 2019 1:30 PM
To:City Council Distribution Group
Cc:councilmtgitems; Rick Cole; Katie E. Lichtig; Debbie Lee
Subject:FW: Agenda Item C.3 - Oppose as Written
Council‐
Please see the below email regarding the privacy policy.
Thank you,
Stephanie
From: Ann Maggio [mailto:annmaggio@gmail.com]
Sent: Tuesday, August 27, 2019 12:03 PM
To: Council Mailbox <Council.Mailbox@SMGOV.NET>
Subject: Agenda Item C.3 ‐ Oppose as Written
Dear City Council and Mayor,
It is not okay to share citizen data with non-profits, contractors, researchers, vendors, etc. A citizen has the
right to adress their government without the intrusion of the aforementioned groups being provided
access to an individuals positions. A resident's tax dollars should not be used to work against these
positions.
The new policy before you includes the following statements.
1."We also seek to aggregate or otherwise de-identify personal data, when possible, whenever it is not
necessary to store or share personally identifiable data elements. " - To this statememnt we respond with a
recent article in the NY Times where data scientists have proven the de-identification myth.
https://www.nytimes.com/2019/07/23/health/data-privacy-
protection.html?em_pos=small&ref=headline&nl_art=4&te=1&nl=upshot&emc=edit_up_20190725%
3Fcampaign_id%3D29&instance_id=11161&segment_id=15544&user_id=7a11f9ae0365e06ac6111d
6830d83d10®i_id=79116004emc%3Dedit_up_20190725&fbclid=IwAR3cv6zcoz4K0Zlcp7hKH8Jsr_j
nQM8nK6L37QUvcSmdoH6xKm2oswDgaAY
2."Certain of the third parties with whom the City contracts may, however, market aggregated, anonymized
data derived in whole or in part from City data. "
Sharing with government agencies
3.We may share information with other government agencies, external service providers, researchers,
contracted vendors, and others to perform city functions and comply with applicable laws. We ask third parties
to abide by our privacy principles when handling data provided by the City. In many cases, we require
compliance through contractual obligations that include: (a) providing notice when information is collected and
Item 3-C
08/27/19
Item 3-C
08/27/19
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used on our behalf by contracted third parties; and (b) directing that contracted third parties agree to and follow
our contractual privacy requirements. "
The 15 Pr/marketing firms you contracted with on March 23rd and all other vendors you may be
approving to share our pii is unacceptable.
Do not approve this policy.
Ann Maggio Thanawalla
SM Privacy Coalition
Item 3-C
08/27/19
Item 3-C
08/27/19