NYU Policing Project Recommendations and SPD Response

Forward by Interim Chief Andre Sayles:

Public trust is something we earn every day. We will never take it for granted.

To those worried about privacy, about our most vulnerable and immigrant neighbors being targeted, or about illegal surveillance: I hear you. Like you, I get frustrated when I hear of government agencies misusing camera technology. That is not who we are, and it is not how these cameras will be used.

Our commitment is concrete:

• Clear safeguards on how the system is used
• Regular auditing
• Public engagement and notice before any camera expansion
• Ongoing partnership with technology and civil liberties groups

Since our Real Time Crime Center went live, in a limited capacity in April 2025, it has played a role in hundreds of investigations. Our analysts have helped track homicide suspects, recover stolen property, and find people who were missing and in danger.

This summer, as hundreds of thousands of soccer fans and visitors filled our streets, the Stadium District cameras were on. In June, we had zero homicides. I won’t credit that to cameras alone, but they helped our officers and detectives tremendously.

Last year, this department completed a 13-year federal consent decree. Transparency and accountability are not new words for us. They are the standard we were held to, and the standard we will keep.

I serve the people of Seattle, and so do our officers. Thank you for your trust, and thank you for holding us to it.

Chief Andre Sayles

Interim Chief of Police

Seattle Police

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NYU Policing Project Recommendations and SPD Response

The Seattle Police Department’s (SPD) mission is to reduce harm and crime in our communities and enhance quality of life for all. To be successful, we must remain committed to advancing strategies that protect public safety, uphold civil rights, and improve recourse for crime victims.

Since its implementation, the RTCC has been an invaluable tool for officers, assisting with 4,868 distinct crime reports, with a focus on support around violent crime investigations, including 57% of homicide investigations this year.

The public’s concerns, and even confusion, surrounding the capabilities of the RTCC and how this technology is being used continue to be a hurdle for SPD.

This NYU report, and accompanying recommendations, provide an excellent roadmap as we continue to learn and grapple with potential expansion in an uncertain technological future. We are resolved to take this feedback, and focus on continual learning as technologies, laws, and best practices evolve.

In summary, after reviewing the NYU Policing Project’s 19 recommendations regarding SPD’s RTCC, SPD will adopt 15 of them and has already begun addressing many of them. Recommendations #1 and #9 will not be adopted as written. As to Recommendation #1, SPD will continue to monitor the law and act consistently with existing law. SPD does not intend to use the RTCC to act inconsistent with existing warrant requirements. Recommendation #9 does not align with current SPD retention practices.  Recommendations #4 and #13 are specific to other City departments and will need to be answered by them.

SPD, in lockstep with the Mayor and the City Attorney, will continue to monitor ongoing case law and legal precedent, and act accordingly if laws change regarding the need to obtain a warrant for certain types of data or if SPD is asked to use the RTCC in a way that is outside of the current practice, draft policy, and SOPs.

We will review each recommendation in depth below to help answer specific questions about how the department is adopting these recommendations and moving forward.

Recommendations Adopted by SPD

1. Recommendation 2: SPD should work with CPC and OIG to develop rules around the use of the RTCC in relation to protests. These rules should conform to existing rules to the greatest extent possible — e.g., they should require authorization before accessing footage of protests or other political activities.

SPD agrees and will work with accountability partners to strengthen RTCC standard operating procedures and policy governing the use of CCTV during protests. These policies will be included in the upcoming Omnibus Surveillance Ordinance.

As an aside, the current draft SOPs allow cameras to be accessed only at a Lieutenant’s request when they observe criminal behavior. SPD will finalize these draft SOPs by the end of November.

• Recommendation 3: SPD should end its practice of indefinitely retaining all data stored on Evidence.com. Instead, it should develop new retention periods for such data based on case status and disposition, consistent with existing laws and policies governing data retention.

SPD ultimately agrees with this approach and is committed to working with accountability partners and other stakeholders to align digital evidence with the Washington State records retention policy.

The state retention policy for cases referred for prosecution is complex because of the appeals process, and automation will require further collaboration and integration of case systems with the Seattle City Attorney’s Office and the King County Prosecutor’s Office.

• Recommendation 5: SPD should finalize its draft RTCC procedures requiring analysts to verify that a request is tied to a valid SPD case and does not relate to immigration enforcement or protected health care. The procedures should direct analysts to decline any request the purpose of which they cannot confirm. All requests should be logged, and that record should be made available for OIG’s review during its annual audits.

SPD is governed by City and State law, which prohibits local law enforcement from assisting with civil immigration enforcement. RTCC Analysts will be required to verify that the purpose of all video requests is not related to an immigration matter. RTCC Analysts will decline any requests for which they cannot verify the incident type, and the department will develop a process for logging declined requests.

• Recommendation 6: SPD should launch the data dashboard as soon as possible, and no later than three months from now (i.e., publication of this audit). In addition to including the reporting criteria identified in the SIR (i.e., areas where cameras are recording, resulting number of police actions such as arrests or warrants), the dashboard should include statistics on frequency of RTCC use, the types of offenses it was used for, the type of support provided, and a broader array of case dispositions (e.g., crisis referral, investigation open or pending).

SPD agrees and is close to finalizing our data dashboard. The dashboard will be updated monthly and made public no later than December 1, 2026.

• Recommendation 7: SPD should finalize a draft of the omnibus surveillance technology policy to send to its accountability partners — CPC and OIG — for review within the next three months of publication of this audit.

SPD agrees and will follow its regular policy adoption process, including review by SPD accountability partners and the Mayor’s Office. The timing of this will depend on the various review steps to ensure that the policy meets our City’s needs.

• Recommendation 8: SPD should clearly specify the full range of incident types and other public safety situations for which the RTCC may be used, including standards governing situations in which the nature of an incident is uncertain or an incident may escalate into one that qualifies for RTCC involvement. During any review of the RTCC’s authorization, the City Council should consider whether to further limit the circumstances in which the RTCC may be activated.

SPD does not restrict RTCC operations to certain crimes by priority levels and/or incident types.  RTCC analysts use a triage model, so Priority One calls for service (posing an immediate threat to human life) are the highest priority, Priority Two calls for service are second priority, and so on.

The Surveillance Impact Reports (SIRs) for the RTCC and CCTV did focus on, but were not restricted to, serious and violent crimes. That said, calls for service often have a final incident type that is different from the initially reported incident type. Because many calls change over time, restricting the RTCC to one incident type may result in no RTCC involvement in serious and violent crimes. Moving forward, SPD will clarify which incident types are included, including by releasing the data dashboard, which will break down the different types of calls the RTCC is involved with.

The classification of priority codes are:

• Priority 1: Critical incidents which pose an immediate threat to human life or involve significant bodily harm 
• Priority 2: Active incidents which could escalate; crimes where apprehension/enforcement is still possible
• Priority 3: Incidents that do not meet criteria of Priority 1 or 2, but may require investigation or action by an officer 
• Priority 4: Non-critical service requests (e.g., found property, parking complaints) 
• Priority 5: default for events designated for Internet and Telephone Reporting Unit callback 
• Priority 7: default for Traffic Stop

• Recommendation 10: At least twice a year, SPD should publish in a clear and conspicuous location on its website a full list of the tools and features it is actually using — and seeking approval to use — in the RTCC.

SPD will publish a list of RTCC tools and features it currently uses on its website and update it annually.

• Recommendation 11: SPD should apply one set of rules to all cameras integrated at the RTCC to the greatest extent that is possible technically.¹⁶³ This should include ensuring that non-public spaces are not recorded, whether through privacy masking or other means.

SPD agrees and will require any integrated cameras to display only publicly available views or to mask non-public areas so they are not visible. If a privately integrated camera cannot apply a privacy mask and has views into non-public areas, SPD will not accept those camera feeds.

The Mayor’s Office will convene an advisory group of surveillance technology experts and data privacy policy analysts to recommend additional plans and policies for the private-camera integration program. SPD will incorporate private camera retention restrictions within policy and SOPs after the recommendations from the Mayor’s Office working group.

Currently, it is not technically possible to set an owner’s private camera retention. SPD will incorporate private camera retention restrictions within policy and SOPs.

1. Recommendation 12: SPD should clarify the types of events in which it might monitor cameras on an ongoing basis (i.e., not connected with an active incident), for how long, and for what purposes.

As part of SPD’s SOPs and policies, SPD will outline RTCC’s involvement in large-scale events, separately from protests. As a matter of practice, SPD will access cameras only if there is an incident case number associated with the event or if criminal activity has been reported.

During large scale events, like the FIFA World Cup this past summer, when the Emergency Operations Center (EOC) is activated, RTCC Analysts may work with the EOC to review crowd sizes, traffic flows, and any emergent safety issues.

• Recommendation 14: In a report to the City Council’s Public Safety Committee, SPD should clarify its plans and policies for private cameras that are directly integrated into the RTCC. This report should include information on the number of cameras it plans to integrate and how those cameras are selected.

The Mayor’s Office will convene an advisory group of surveillance technology experts and data privacy policy analysts to recommend plans and policies for the private-camera integration program. SPD will work with its accountability partners as part of its regular policy development process and will submit an updated report after finalizing its policies.

• Recommendation 15: SPD and its RTCC vendor should memorialize in their contract that new RTCC surveillance features must be disabled by default, and only added after a determination regarding whether the new feature constitutes a “material change” (which, under local law, would require approval by the City Council).

SPD agrees, and conversations are already underway to amend the contract language.

As part of this process, SPD will work with Axon to develop criteria for determining which updates fall under this change, so as not to prohibit the timely deployment of security patches and immaterial changes (such as user interface changes).

• Recommendation 16: SPD should disclose publicly the data and analysis underlying decisions about where cameras are deployed. If deployment is based on crime patterns, calls for service, operational needs, or other considerations, SPD should provide the relevant data. The agency need not reveal any sensitive operational information — only the data necessary to allow for a meaningful assessment of whether deployment decisions rest on a sound basis.

SPD agrees to publicly share the shots-fired data used in the original decision-making process for the initial three camera selections. This data will be posted on the SPD CCTV website by December 1, 2026.

The advisory group convened by the Mayor’s Office will make recommendations on criteria for any potential future expansion of CCTV deployments e.g. event size, calls for service, or shots fired.

• Recommendation 17: SPD should reassess at least annually whether the conditions that justified camera deployment continue to exist. Just as reassessment of changes in crime patterns, victimization, case clearance rates, or other investigative outcomes informs where cameras are needed, this same data would help ensure that cameras do not simply remain in place because they once were justified.

SPD will assess camera placement-related data annually and post it publicly. Once the University of Pennsylvania releases their metrics, SPD will incorporate feedback into the annual review.

• Recommendation 18: SPD should insist that Axon develop new features for Fusus that (a) require a case number or reason for any camera activation and (b) log any use of object detection or other AI features.

SPD has requested the RTCC software vendor (Axon) to require a case number to be entered when cameras are accessed and will continue negotiations on implementation. SPD already requires analysts to log object detection within their records management system (Mark43) and will request that Axon include object detection searches in the Fusus system logging.

• Recommendation 19 : SPD should establish a policy for regular internal audits of the RTCC, including checks of whether data was accessed for any prohibited purpose and whether any unusual patterns in system access indicate misuse of tools or data.

SPD agrees and will finalize a clear policy for internal audits of RTCC and CCTV usage, as well as continue to support the OIG in its annual audits of all surveillance technology adopted by the department. Currently, SPD conducts monthly audits on usage and access using a sample of incidents.

Recommendations Not Adopted by SPD

1. Recommendation 1: Warrantless tracking of individuals (i.e., the tracing of a person’s location or movements across multiple camera clusters) should be permitted only when police are responding to an active incident and have probable cause to believe a crime is being or has been committed and that immediate action is needed to prevent physical harm to the officers or other persons, the destruction of relevant evidence, or the escape of the suspect. In all other circumstances, tracking generally should require a warrant supported by probable cause.

The primary work of the RTCC is to respond to calls for service through 911 or officer-initiated calls (“on-views”).  RTCC Analysts are not commissioned law enforcement officers and therefore do not determine probable cause – that is the job of the responding officers.

Detectives pursue warrants in cases where the current law and/or case law requires them. Currently, the law does not require law enforcement to obtain a warrant for RTCC cameras in public spaces. SPD will monitor ongoing developments in the law and act accordingly if the law changes regarding the need to obtain a warrant for certain types of data.

The RTCC Standard Operating Procedures (SOPs) require a call for service initiated by a 911 call or an officer-created incident.

The RTCC does work with SPD investigators to assist with retrospective investigations. The retention policies and practice for RTCC footage do not support the ability to perform long-term tracking or surveillance.

• Recommendation 9: SPD should make its five-day retention period a matter of written policy.

A retention policy already exists and practices differ for technological and legal reasons. The SPD Policy Manual, which also matches the SIR language, already states that the retention is “up to a 30-day retention period (actual retention periods may be shorter due to operational needs/privacy interests but will not exceed 30 days).” (12.100 POL)

For example:

• SPD maintains a five-day retention for its public space cameras.
• SPD maintains a one-day retention for integrated SDOT cameras.
• SPD maintains a five-day retention for integrated SPD facility cameras (but 31 days retention in the City facility security camera system).
• There are times when SPD needs to increase its retention period for cameras to preserve records for public disclosure requests.

Recommendations for City Departments Outside of SPD

Recommendation 4: The City should adopt and publish a policy stating how it will respond in the event a demand arrives at SPD or Axon for RTCC data relating to an immigration- or health care-related investigation, including whether the City will intervene and seek to quash the order as a matter of course when a good-faith legal basis exists.

Recommendation 13: As part of its annual surveillance review of the RTCC, OIG should conduct a “material change” review, evaluating how current RTCC use and capabilities compare to those approved by the operative SIR. OIG should identify any changes it deems “material” that were not previously reported and thus require SPD to submit an updated SIR.