City of Santa Monica’s Privacy and Security Statement

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.

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:

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;
The type of browser and operating system used to access the City's website;
The date, time and duration of the visit, as well as the general geographic location of the device from which the visit is made;
Derived demographic information;
The web pages and/or services you accessed during your visit, as well as any applications used and forms data;
and, 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 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: the e-mail address, and contents of the e-mail, for those who communicate with us via e-mail;

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.

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 recordof 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 communications@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.

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. 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.

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: https://oag.ca.gov/sites/all/files/agweb/pdfs/publications/summary_public_records_act.pdf

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 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 privatebusinesses. 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 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 communications@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 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: communications@santamonica.gov