The City of Fort Collins is asking residents to review a proposed policy governing how city departments acquire and use surveillance technology. Residents can submit comments through Thursday, Nov. 12.
The draft Surveillance Technology Governance Policy would establish a citywide review process for technologies used to observe, identify, locate, track or analyze people, vehicles, movements, communications and behavior. It would apply to technology administered by the city, including systems already in use and information obtained from outside parties.
City officials said the proposal was developed through community feedback gathered during focus groups, boards and commissions meetings, and a survey conducted between July and October 2026.
The proposal does not prohibit surveillance technology. Instead, it establishes an administrative process intended to weigh a technology’s governmental purpose and potential benefits against its effects on privacy, civil liberties, data security, public trust and city finances.
Under the draft, operational efficiency or cost savings would not be sufficient on their own to justify surveillance.
Policy focuses on how technology is used
The proposal distinguishes between technology that has surveillance capabilities and technology the city uses for surveillance.
A camera, sensor, database or automated analytics system would not necessarily be classified as surveillance technology simply because it could identify someone. The city would instead consider the purpose and actual use of the system.
Routine monitoring of city buildings, infrastructure, networks, equipment, environmental conditions and public services would generally fall outside the policy when people or vehicles are only incidentally recorded. The same information could become subject to the policy if the city began using it systematically to observe or evaluate identifiable people.
The draft also excludes information that has been appropriately anonymized, aggregated or de-identified so individuals cannot reasonably be identified.
Proposed uses would go before a review board
Before acquiring technology for surveillance, beginning a new surveillance program or materially expanding an existing use, a city department would have to submit a proposal through the city’s Technology Review Board.
The sponsoring department would have to explain the governmental purpose, expected benefits and operational need for the proposed use. It would also have to designate an owner responsible for compliance, safeguards and management of the technology throughout its lifecycle.
The Technology Review Board would decide whether the proposed use constitutes surveillance and whether it qualifies as “high impact.”
The board’s review could include:
- The governmental purpose and expected public benefit.
- The technology’s effectiveness and cost.
- Less intrusive alternatives.
- The type and amount of information collected.
- Privacy and civil-liberties implications.
- Data retention, access and sharing practices.
- Cybersecurity protections.
- Vendor practices and legal requirements.
- Operational and financial risks.
The board could recommend approval, conditional approval, a limited pilot, additional review or denial. An approval would identify the authorized purpose, principal safeguards, restrictions and any conditions that could trigger another review.
High-impact surveillance would receive public notice
The policy creates heightened requirements for surveillance considered to have a high impact.
That category would include mass or indiscriminate surveillance, broad or systematic biometric identification, persistent tracking of people or vehicles, and certain forms of automated profiling or data integration that substantially increase the city’s ability to identify, locate, track or profile individuals.
If the review board classified a proposal as high impact, the city manager would have to notify the Fort Collins City Council and the public through a regularly scheduled council meeting before granting final authorization or entering a binding purchasing agreement.
The notice will describe the proposed use, its governmental purpose, expected benefits, alternatives considered, the general nature of the information collected and the principal safeguards. Some details could be withheld to protect privacy, cybersecurity, investigations, public safety or city operations.
Residents could comment using the council’s normal public-comment procedures. However, the meeting would not constitute a separate public hearing, and the council would not vote to approve or reject the technology.
Final authority over high-impact surveillance would remain with the city manager, who would consider the review board’s recommendation and feedback from the public and council. Lower-risk surveillance could be approved through delegated administrative authority.
That division of authority is one of the proposal’s most consequential features. It provides public notice and an opportunity to comment on high-impact surveillance, but it does not require public or legislative approval.
Contracts would limit vendor use of city data
Separate procurement guidelines would incorporate the policy into city contracting practices.
Under those guidelines, the city generally could not sign or renew a contract, accept binding online terms, issue a purchase order or begin operational use until the required authorization had been documented. The city could solicit proposals before authorization, but vendors would have to be told that any award was contingent on approval.
Contracts involving surveillance data would have to address:
- City ownership or legally enforceable control of the data.
- Security and cybersecurity incidents.
- Data retention, deletion and return.
- Subcontractor access.
- External data sharing.
- Changes to a vendor’s surveillance capabilities.
- Information needed for city reviews and annual reporting.
- Suspension or termination when safeguards fail.
- The city’s public records and transparency obligations.
The proposal would prohibit vendors from independently selling, licensing, monetizing or commercially exploiting city surveillance data. Vendors also could not use the data for advertising, commercial profiling or unrelated product development.
The purchasing guidelines separately state that surveillance data could not be used for commercial artificial-intelligence model training without city authorization.
Limited testing could occur without prior approval
The draft would allow demonstrations, evaluations and limited proof-of-concept tests to proceed for as long as 90 days without prior approval, provided they do not become operational deployments or establish an ongoing surveillance use.
The accompanying procurement guidelines add that an approval-free evaluation could not collect, retain or use personally identifiable information. Trials outside those conditions would require authorization before beginning.
Case-specific searches would generally be excluded
“Incident-based access” would generally fall outside the policy.
The draft defines that as isolated, case-specific access to information associated with an incident, complaint, investigation, legal requirement or another legitimate governmental need. Repeated access would not automatically turn individual searches into a surveillance program.
The policy also says the city could not characterize planned, systematic or standardized surveillance as incident-based access simply to avoid review.
The distinction could determine whether repeated searches of an outside database or technology platform receive advance review and appear in public reporting.
Emergency use would be permitted
The city could temporarily use available technology or information without prior review during an emergency when immediate action is necessary and obtaining approval is impracticable.
Emergency use would have to be lawful, documented and limited to what is reasonably necessary. Continued or recurring use after the immediate circumstances ended would require normal review and authorization.
Approved uses would receive annual reviews
City departments would be responsible for ensuring approved surveillance programs remain within their authorized purposes and conditions.
Each approved use will receive an annual review examining whether it remains compliant with city policy, applicable law and vendor obligations. The review would also assess whether the technology continues to provide the operational, public safety or service benefits that justified its approval.
The city manager could order an independent assessment or audit in response to significant risks, compliance concerns, security incidents or other material circumstances. The policy does not require routine independent audits for every high-impact system.
If an essential safeguard failed, the affected use generally would have to be suspended or restricted until the problem was resolved. The city manager or a designee could allow temporary continued operation if effective interim protections were put in place.
City will publish an annual surveillance report
The city would provide an annual report to the Fort Collins City Council and publish it on the city’s website.
The report would summarize approved surveillance uses, their general governmental purposes and their principal safeguards. It would also address significant approvals, high-impact notifications, material changes, discontinued uses, compliance findings and corrective actions when applicable.
The city could limit disclosures that might compromise individual privacy, cybersecurity, public safety, investigations, critical infrastructure, protected information or operational security.
The draft does not specify precisely how much detail the city must provide about each technology, how it would explain information withheld from the public, or whether the report would include statistics on uses classified as incident-based access.
Existing technology raises implementation questions
Although the draft applies to technology already in use, it does not include a specific public timeline for identifying, classifying and reviewing existing systems.
The city would still need to develop internal workflows, standard contract language, solicitation materials and review checklists. City information technology staff, purchasing officials and the City Attorney’s Office would be responsible for that implementation work.
The absence of an implementation schedule leaves open how quickly residents could expect a complete inventory of existing surveillance uses or when legacy systems would receive review under the new framework.
How to review the proposal and submit comments
The city is asking residents to read the draft governance policy and the accompanying procurement and contracting guidelines before submitting feedback.
Provide your comments on the draft policy here.
Documents in English
- Draft Surveillance Technology Governance Policy
- Draft Surveillance Technology Procurement and Contracting Guidelines
Documentos en español
- Borrador: Política sobre Gobernanza de la Tecnología de Vigilancia
- Borrador: Directrices para la Adquisición y Contratación de Tecnología de Vigilancia
The comment form asks residents:
What questions, comments or feedback do you have about the draft Surveillance Technology Governance Policy?
Comments will be accepted until Thursday, Nov. 12.
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