Loading...
HomeMy WebLinkAboutItem 8.2 Report on Public Data Security STAFF REPORT CITY COUNCIL Page 1 of 5 Agenda Item 8.2 DATE: March 3, 2026 TO: Honorable Mayor and City Councilmembers FROM: Colleen Tribby, City Manager SUBJECT: Report on Public Data Security Prepared by: Victor Fox, Police Chief and Steve Windsor, Chief Information Security Officer EXECUTIVE SUMMARY: The City Council will receive a report on how the City protects the public data it collects in the course of normal business operations. STAFF RECOMMENDATION: Receive the report. FINANCIAL IMPACT: None. DESCRIPTION: During Item 9 of the December 2, 2025 meeting, the City Council requested a report on how the City protects the public’s data. Background The City collects and utilizes information from a variety of technological sources encompassing public safety, finance, business, recreation, property, infrastructure as part of the normal course of providing community services. This report addresses the protection protocols around the two major categories of information collected and utilized in Dublin – public safety data collected by Dublin Police Services, and data collected by the City through internal systems and third parties to provide general community services and programs. Data Collected by Dublin Police Services Dublin Police Services (DPS) utilizes technology systems to support law enforcement operations while maintaining strict controls over how public data is accessed and used. The primary technologies used by DPS that collect and/or use electronic data are the Flock Safety 82 Page 2 of 5 camera system and the Peregrine Technologies data integration system. DPS also uses its own internal systems in the completion of routine daily business. The following is a discussion of key components of the department's data protection practices across all systems. Automated License Plate Reader and Situational Awareness Cameras (Flock Safety) DPS has deployed Automated License Plate Reader (ALPR) and situational awareness camera (sitcam) equipment and technology since 2017. In October 2024, the City Council approved an agreement with Flock Safety for the purchase and installation of 82 ALPR cameras and sitcams. This transition improves image quality, reliability, and real-time alert capability while maintaining existing governance and compliance policies. Flock’s camera systems capture vehicle data only and are used exclusively for defined law enforcement purposes such as vehicle recovery, suspect identification, emergency notification alerts, and investigative leads. Specifically, ALPR technology supports real-time incident management and aids in investigations and monitors high traffic intersections, including ingress/egress points. This data is not used for generalized surveillance or any type of monitoring without a law enforcement purpose. There are several laws and policies that govern the retention, access, and use of the data collected through ALPR technology, and with which DPS is in compliance:  Senate Bill (SB) 34 (2016). Governs ALPR access, retention, audit logging, and sharing limits. Specifically, it prohibits police from circulating ALPR data with the federal government and agencies in other states.  Alameda County Sheriff’s Office Policy 5.42 (ALPR). Governs the use of ALPR systems, including usage, data collection, training, and security.  SB 54 (The California Values Act, 2018). While this law does not specifically discuss the use of ALPR data, it restricts state and local law enforcement from using resources (which would include technological resources such as ALPR systems) for federal immigration enforcement.  CJIS Compliance. Electronic data collected by DPS systems, including ALPRs, is also compliant with the Federal Bureau of Investigation’s Criminal Justice Information Services (CJIS) Security Policy. This requires federal, state, and local agencies and contractors to implement controls such as encryption, multi-factor authentication, auditing, and background checks to protect data. Real-Time Crime Center (RTCC) and Investigative Data Integration (Peregrine Technologies) Dublin Police Services’ RTCC is a centralized hub that integrates data from a variety of sources, such as ALPRs and sitcams, calls for service, and crime analytics, to give officers instant, actionable intelligence for faster response times, better situational awareness, increased suspect identifications, and safer outcomes. As part of its RTCC operations, DPS uses Peregrine Technologies, a web-based software-as-a-service that consolidates data from existing law enforcement systems into a single point of access for analysis, reporting, and oversight. Peregrine does not independently collect or retain data, and all information remains the property of the City. Peregrine’s data security protocols include end-to-end encryption, granular access and usage control, and audit trails. 83 Page 3 of 5 In addition, the Peregrine system in compliance with CJIS, supports Health Insurance Portability and Accountability Act (HIPAA) requirements, and has achieved high-level security certifications, including the Federal Risk and Authorization Management Program (FedRAMP) High. The FedRAMP control system is one of the most stringent cybersecurity frameworks in existence, with a compliance structure relies on three distinct levels. The “High” certification gives organizations the strongest protections, particularly for those that handle national security, law enforcement, and critical infrastructure data. General DPS Systems In addition, DPS employs the following controls related to the data it collects across all systems.  Data ownership and retention. All data collected through DPS systems is owned by the City. Camera data is automatically deleted after 30 days and cannot be extended by the vendor. Data is not sold, shared, or repurposed beyond its intended law enforcement use.  Access Control. Access to DPS systems is restricted by role, and every search for data requires a registered user identification and documented reason for the search. Permanent audit logs are maintained for all system access and searches. Artificial Intelligence (AI) Where AI features are used, they are limited to informational functions such as summarization. Content generated via AI is clearly labeled, linked to source data, and does not initiate enforcement actions or automate decisions. All operational decisions re main human-directed. Data Collected by City Departments In the course of daily operations, the City collects data in two ways: with internal or City- controlled systems, and through third-party software. Data protection protocols for both are described below. City-Controlled Systems The Information Technology (IT) Department employs a layered security approach to protecting systems that are accessed through the City’s network and the data they contain. The primary systems that collect and maintain sensitive information are: 1) Tyler Munis, Dublin’s Enterprise Resource Planning (ERP) software, which includes finance, human resources, payroll, and permitting modules; and 2) Laserfiche, which digitizes, secures, and organizes documents and workflows. The following areas represent the key components of Dublin's information security program that is utilized with Tyler Munis, Laserfiche, and all other City-controlled information databases.  Data Protection and Encryption. The City uses industry-standard encryption to protect data both in storage and during transmission. Encrypted backups are maintained in secure cloud environments.  Identity and Access Management. Access to City systems is restricted through 84 Page 4 of 5 granular, role-based access controls and multi-factor authentication. System permissions are managed to ensure employees have access only to the information necessary for their role. Physical access to City facilities is managed through a strict electronic badging system that is monitored and controlled remotely.  Network and Threat Protection. City networks are protected by enterprise firewalls and 24/7 security operations monitoring. Endpoint protection is deployed on all City devices to defend against malware and other threats.  Monitoring and Logging. City systems are continuously monitored for unusual activity. Centralized logging and alerting allow staff to identify and investigate abnormal behavior in real time.  Incident Response. The City maintains a formal incident response plan that is tested annually. In the event of a security incident, response efforts are coordinated between IT, DPS, the City Attorney, and City leadership.  Transparency and Privacy. The City balances public access to information with the protection of personal data. Legal review and redaction are applied to public records requests to ensure compliance with applicable privacy laws.  Employee Training. All City employees participate in ongoing security awareness training, including phishing simulations, to reduce the risk of human error. Third-Party Vendors The City works with a number of third-party vendors that handle City data, such as software and apps like ActiveNet (for registering in City programs), HomeKeeper (for managing client data and tracking properties), and FixIT Dublin (for reporting maintenance issues). All third- party vendors are required to complete a security review and meet contractual security requirements related to data privacy before approval. Transparency and SB 272 In 2015, Senate Bill 272 was signed into law, requiring local agencies (excluding school districts) to create catalogs of all enterprise systems that store information about the public, and to post this catalog on their websites. This law, codified in California Government Code Section 6270.5, is designed to increase transparency about the data collected by government. An enterprise system as a software application or computer system that collects, stores, exchanges, and analyzes information that the agency uses that is a multi-departmental system or system that contains information collected about the public and a system of record (a system that serves as an original source of data within an agency). For each enterprise system included in the catalog list, agencies must disclose: o Current system vendor and product o The purpose of the system o What kind of data is stored in it o The department that serves as the system's primary custodian o How frequently system data is collected and updated Dublin’s SB 272 inventory can be found at https://dublin.ca.gov/1852/ESCT-SB-272 and is included as an attachment to this Staff Report. 85 Page 5 of 5 STRATEGIC PLAN INITIATIVE: None. NOTICING REQUIREMENTS/PUBLIC OUTREACH: The City Council Agenda was posted. ATTACHMENTS: 1) City of Dublin SB 272 Inventory 86 Vendor Product Purpose Data Stored Custodial Dept Collected/Updated Tyler Technologies MUNIS ERP City-wide financial management, payroll, HR, and procurement Financial transactions, vendor data, purchase orders, contracts, public-facing billing/AR records FIN Daily Tyler Technologies EnerGov Permitting, licensing, inspections, and code enforcement Permit applications, inspection records, license data, code cases, public applicant info FIN / PLN Daily Tyler Technologies Tyler Cashiering Payment processing for city services Payment transactions, receipt records, payer information FIN Daily Laserfiche Laserfiche RIO Enterprise document management and records retention Official city records, public documents, images, retention schedules CLK Daily Granicus, LLC Peak Agenda, Media Manager, Swagit Streaming/Captioning Public meeting agenda creation, minutes, streaming, captioning Meeting agendas, minutes, video recordings, public comments CLK As needed (per meeting cycle) NeoGov Governmentjobs.com Online recruitment, job postings, applicant tracking Job applications, resumes, candidate evaluations from the public HRM Daily Netfile E-filing System Electronic filing of campaign finance and economic interest disclosures Financial disclosure statements, campaign contributions, filer info CLK As needed (per filing period) OpenGov Budgeting and Planning Suite (incl. Open Town Hall)Budget development, financial planning, public engagement Budget data, public survey responses, community feedback FIN Daily / As needed Salesforce / Grounded Solutions HomeKeeper (Sales & Service Cloud)Affordable housing program management and compliance Homeowner/applicant records, property data, income verification HSG Daily ElectricBaby, Inc Online Homeownership Application (Salesforce)Online application portal for homeownership programs Public applicant personal info, income data, eligibility docs HSG As needed ActiveNetwork ActiveNet Recreation registration, facility reservations, activity management Public registrant info, class enrollments, facility bookings, payments PCS Daily Esri ArcGIS (Enterprise GIS)Geographic information system for spatial analysis and public data Parcel data, zoning, infrastructure layers, spatial datasets ISS / PWK Daily DocuSign DocuSign Electronic signature and agreement management Signed contracts, agreements, signatory info (public parties)CMO Daily CivicPlus Website Hosting and Support Website hosting, forms, ADA compliance Public forms, website content, ADA reports CMO Daily CivicPlus SeeClickFix Public service request and issue reporting Service requests, location data, photos, public requestor info CMO / MKT Daily CivicPlus Next Request Public records request tracking and fulfillment Records requests, public requestor info, response documents CLK As needed CivicPlus ArchiveSocial Social media archiving for records compliance Archived public-facing social media posts, comments, messages MKT Daily (automated) Omnigo Software (Quetel)Physical Evidence Management Law enforcement evidence tracking and chain of custody Evidence records, case associations, chain of custody logs DPS Daily KAM Software Technologies Crossroads Traffic collision investigation and reporting Collision reports, witness/party info, vehicle data, scene diagrams DPS As needed (per incident) Cellebrite Cellebrite UFED Digital forensics for law enforcement investigations Extracted digital evidence, case files, forensic reports DPS As needed (per case) Everbridge, Inc Nixle Engage Mass public notification and community engagement Resident contact info, subscriber lists, notification history MKT Daily CoStar CoStar Realty Information Commercial real estate market data and analysis Property listings, sales data, market analytics, tenant info EDD Daily ZOOMGRANTS Zoom Grants Online grant application and management Grant applications, public applicant info, award amounts, reports PCS As needed (per grant cycle) iCityWork iCityWork Public-facing development activity website and project information Development project details, status, maps, public documents PLN / PWK As needed Amobius Group LLC Veribook Online appointment scheduling for passport appointments and Livescan fingerprinting Public appointment records, scheduling data, requestor info DPS Daily REVEAL DATA CORP Logikcull eDiscovery and public records search Litigation documents, public records search results (verify if public data stored)CLK As needed Interactive Data IDI Core Data Investigative data lookup for law enforcement Person records, address history (verify if Dublin stores originals or query-only)DPS As needed LEHR Investigative Data Platform (IDP)Commercial data for law enforcement investigations Person/entity records (verify if storing originals or query-only)DPS As needed Callyo Investigations Law enforcement call recording Recorded calls with public, communication logs (verify if system of record)DPS As needed CaseGuard Body Worn Camera Redaction Software Video redaction for BWC footage prior to public release Redacted video of public interactions (verify if system of record)DPS As needed Teamsideline Sports Schedule and Roster App Sports league scheduling and roster management Public participant names, team rosters (verify depth of public data)PCS Seasonally EPACT Signature/Emergency Contact Software Participant emergency contact and medical info Public participant emergency contacts, medical info, waivers PCS As needed HydroApps Aquatic Forms and Log Software Pool safety logging and compliance Safety inspections, incident reports (verify if public injury/incident data stored)PCS Daily General Code Publishing Co.Municipal Code Updates Online Municipal Code Proprietary Offsite Database Codified local laws and ordinances CMO As needed Attachment 1 87 Report on Public Data Security March 3, 2026 88 Executive Summary •The City collects and utilizes information from a variety of technological sources. •This report addresses the protection protocols around the two major categories of information collected and utilized in Dublin: •Public safety data collected by Dublin Police Services •Data collected by the City through internal systems and third parties 89 DPS Data Protection 90 Cameras and Investigative Technology •Automated License Plate Reader (ALPR) and Situational Awareness Cameras (Sitcams) in use since 2017 –Vehicle recovery, suspect ID, investigative leads. •82 cameras approved by Council (Oct 15, 2024) to modernize and expand coverage. •Peregrine Technologies consolidates law enforcement data –All systems under strict legal compliance. 91 ALPRs •Capture license plates and vehicle descriptors only. No personal identifying information or demographic data is collected. •Human verification required before any enforcement action. •Support stolen vehicle recovery, emergency notification alerts (AMBER, Silver,Ebony, etc), criminal investigations, at-risk missing persons, and officer safety. Flock Safety —Data Uses 92 Situational Cameras (Sitcams) •Support real-time incident management and aid in investigations. •Monitors high traffic intersections, including ingress/egress points. •Not used for generalized surveillance or any type of monitoring without a law enforcement purpose. •DPS operates these cameras under Policy and Procedure 5.26. Flock Safety —Data Uses 93 •Data 100% owned by DPS -never sold; auto-deleted after 30 days by default. •Every search is logged with user ID and case reason (permanent audit trail). •Flock has no access to personally identifiable information. •DPS decides who to share data with, not Flock Safety. Flock Safety —Data Security 94 •No public IP; data is CJIS-compliant AWS GovCloud with end-to-end encryption. •Achieved 10 security certifications, including CJIS. •Multi-factor authentication, role-based access. Flock Safety — Data Security 95 •Deactivated the ability for out-of-state and federal agencies to request data from California agencies (March 2025). •Created a search filter that blocks any search reason appearing to include immigration enforcement or reproductive care (July 2025). • Created the ability to audit whether or not a search query yielded any results (August 2025). Flock Safety — Data Security 96 Legal and Policy Compliance •SB 34 (2016) – Governs ALPR access, retention, audit logging, and sharing limits. •SB 54 (The California Values Act, 2018) – Restricts state and local law enforcement from using resources for federal immigration enforcement. •ACSO Policy 5.42 (ALPR) – Governs usage, data collection, training, and security. •CJIS Compliance – Requires encryption, multi-factor ID, audting, etc 97 Peregrine — Data Uses •Consolidates existing RMS, CAD, and CRIMS data into a single point of access for analysis, reporting, and oversight. •Not predictive policing – No risk scores, targeting, or automated enforcement. 98 Peregrine — Data Security •Does not independently collect data. •DPS owns all data – Not sold or shared; auto-removed when expunged at source. •CJIS compliant and has achieved high-level security certifications, including FedRamp High. 99 Peregrine — Data Security •AI features are informational only, do not initiate enforcement actions, automate decisions, or operate without human oversight. •Peregrine does not build or train its own AI models. 100 General Privacy and Anti-Bias Safeguards •Role-based access to systems, full audit logging, data encryption, and automated data deletion after 30 days. •No demographic profiling by race, ethnicity, or any protected characteristic. •Monthly supervisory audits. 101 General Accountability and Oversight •Departmental policy governs all data collection, interpretation, and action. •Platform tools support transparency, auditing, and compliance reporting. •Regular audits ensure adherence to policy and law. 102 Summary •ALPR and Situational Awareness cameras in use since 2017 — Flock Safety and Peregrine improve operational capability with strong protections of data privacy. •All systems comply with SB 34, SB 54, DPS Policy 5.26, and ACSO Policy 5.42. •DPS is committed to transparent, lawful, and equitable use of public safety technology. 103 Questions? 104 City IT Data Protection 105 Data Protection and Encryption •Industry-standard encryption protects data in storage and during transmission. •Encrypted backups are maintained in secure cloud environments. 106 Identity and Access Management •System access is restricted through granular, role-based controls and multi-factor authentication (MFA). •Employees have access only to the information necessary for their role (Least Privilege). •Physical access to City facilities is electronically managed and monitored. 107 Network and Threat Protection •Enterprise firewalls protect City networks from external threats. •24/7 security operations monitoring detects and responds to threats in real time. •Endpoint malware protection is deployed on all City devices. 108 Monitoring and Logging •City systems are continuously monitored for unusual activity (SOC). •Centralized logging and alerting identify abnormal behavior. 109 Incident Response •Incident response plan is documented and tested annually (Tabletop). •Response coordination includes IT, Police, Legal, and City leadership. 110 Transparency and Privacy •Public access to information is balanced with protection of personal data (redacting). •Legal review and redaction are applied to public records requests (PRA Review). •Practices comply with applicable state and federal privacy laws. 111 Employee Training •All City employees receive mandatory security awareness training. •Ongoing phishing simulation testing reinforces employee readiness. •Training reduces the risk of human error as an attack vector. 112 Vendor Risk Management •Third-party vendors complete a security review before handling City data. •Contractual security requirements are required for approval. 113 Questions? 114