City Council:
AN ORDINANCE AUTHORIZING AND ADOPTING
THE CITY OF MOUNT VERNON’S POLICY ON
SMART GLASSES USE, WEARABLE TECHNOLOGY,
AND CONNECTED RECORDING DEVICES
Whereas, by correspondence dated September 28, 2026, the Commissioner of the Department of Management Services has requested that the City Council adopt a City-wide Policy on Smart Glasses Use, Wearable Technology, and Connected Recording Devices, designated as Policy No. IN_1680_01; and
Whereas, the proposed Policy establishes City-wide standards governing the responsible use of smart glasses, wearable technology, and connected recording devices in connection with City business and operations; and
Whereas, smart glasses, wearable technology, and connected recording devices, including devices such as Meta Ray-Ban, Vuzix, and RealWear products, may possess capabilities to continuously or discreetly record audio, video, and images, perform artificial intelligence-enabled facial recognition or biometric analysis, and transmit or synchronize collected information to vendor-controlled cloud environments; and
Whereas, the City recognizes that the use of such technologies in the workplace presents considerations relating to privacy, information security, records management, workplace conduct, public transparency, protection of personally identifiable information, and the security of City facilities and critical infrastructure; and
Whereas, the City desires to establish a heightened internal standard governing the use of such technologies during City business to protect residents, employees, contractors, sensitive information, City facilities, and the integrity of City operations; and
Whereas, the proposed Policy prohibits unauthorized recording by City employees and contractors during City business, including the unauthorized capture of audio, video, images, biometric information, or other data, unless such use has been specifically authorized in writing in accordance with the Policy or is otherwise permitted by applicable law, City policy, or legal requirement; and
Whereas, the proposed Policy identifies circumstances and locations in which recording by City personnel is prohibited or restricted, including resident interactions, internal meetings, Human Resources and disciplinary matters, restrooms and locker rooms, court facilities, executive sessions, and communications or proceedings subject to legal privilege; and
Whereas, the proposed Policy establishes protections for Restricted Security Areas and Critical Infrastructure, including information technology server rooms, 911 and dispatch areas, evidence and records storage areas, utility control systems, and other designated secure locations, by restricting unauthorized recording, scanning, mapping, or other technological collection activities; and
Whereas, the proposed Policy prohibits the unauthorized capture of access credentials, identification badges, PINs, multi-factor authentication codes, and similar security information, and restricts livestreaming, facial recognition, biometric identification, and the use of built-in artificial intelligence assistants in connection with City business; and
Whereas, the proposed Policy establishes a written approval process for limited and legitimate operational uses, requiring appropriate review and documentation by the applicable Commissioner or Director, the Department of Management Services and/or Chief Information Officer, the Corporation Counsel, and Human Resources, as applicable; and
Whereas, the proposed Policy provides that data collected during City business is City property and establishes requirements concerning approved storage, records retention, disposition, and protection of such information; and
Whereas, the proposed Policy requires that vendor cloud synchronization be disabled and verified before any authorized use and requires authorized City data to be maintained within approved City-managed systems, including the City’s Microsoft 365 SharePoint and OneDrive environments, as applicable; and
Whereas, the proposed Policy establishes specific provisions applicable to the Mount Vernon Police Department, including clarification that smart glasses are not official police equipment and that their use is separate from, and shall be coordinated with, the Department's existing Body-Worn Camera Policy; and
Whereas, the proposed Policy establishes procedures for reporting incidents and data breaches, enforcement and consequences for violations, employee training, and the establishment of a standing Wearable Technology Review Committee to periodically evaluate the Policy and recommend updates as technology, operational needs, and applicable legal and regulatory requirements evolve; and
Whereas, the proposed Policy is intended to complement the City’s existing Acceptable Use Policy, Policy for Safeguarding Personally Identifiable Information, Breach Notification Policy, and Mount Vernon Police Department Body-Worn Camera Policy, with the more protective requirement prevailing in the event of a conflict, to the extent permitted by law; and
Whereas, nothing contained in the proposed Policy is intended to restrict lawful public recording, public access, freedom of information rights, or any other rights provided by applicable federal, state, or local law; and
Whereas, the Department of Management Services has recommended adoption of the Policy to establish a consistent City-wide framework for governing rapidly advancing wearable and connected recording technologies while protecting privacy, information security, City operations, and public trust; and
Whereas, the City Council has reviewed the proposed Policy and determined that adoption of the Policy is appropriate for the orderly administration and protection of City operations and resources;
NOW, THEREFORE, BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF MOUNT VERNON, NEW YORK, AS FOLLOWS:
Section 1. Adoption of Smart Glasses, Wearable Technology, and Connected Recording Devices Policy. The City Council of the City of Mount Vernon hereby adopts the City of Mount Vernon Policy on Smart Glasses Use, Wearable Technology, and Connected Recording Devices, designated as Policy No. IN_1680_01, as the official City-wide policy governing the use of smart glasses, wearable technology, and connected recording devices in connection with City business.
The Policy adopted pursuant to this Ordinance is incorporated herein by reference and shall be maintained by the Department of Management Services as an official City policy.
Section 2. Purpose and Scope. The purpose of the Policy is to establish uniform standards for the responsible use of smart glasses, wearable technology, and connected recording devices by City employees, officers, officials, contractors, consultants, and other persons acting on behalf of the City, to the extent applicable.
The Policy shall address privacy, information security, records management, workplace conduct, public transparency, protection of personally identifiable information, facility security, critical infrastructure, and responsible use of emerging technologies.
Section 3. Restrictions on Recording and Data Collection. No City employee, officer, official, contractor, consultant, or other authorized user shall use a smart glass, wearable technology, or connected recording device to record, capture, transmit, scan, map, analyze, or otherwise collect audio, video, images, biometric information, credentials, or other City-related information during City business except as specifically authorized by the Policy, another applicable City policy, or applicable law.
Recording and related technological activities shall be prohibited or restricted in the locations and circumstances identified in Policy No. IN_1680_01, including, as applicable, resident interactions, internal meetings, Human Resources and disciplinary matters, restrooms and locker rooms, court facilities, executive or legally privileged sessions, Restricted Security Areas, and Critical Infrastructure.
Section 4. Information Security and City Data. All information and data collected through an authorized use of smart glasses, wearable technology, or connected recording devices in connection with City business shall be treated as City information and shall be subject to applicable City information-security, records-management, privacy, retention, and disclosure requirements.
Unauthorized personal storage, personal cloud storage, vendor-controlled cloud storage, or other unapproved storage of City data is prohibited.
To the extent required by Policy No. IN_1680_01, vendor cloud synchronization shall be disabled and verified before an authorized device is used for City business. Authorized City data shall be maintained in approved City-managed systems, including the City’s Microsoft 365 SharePoint and OneDrive environments, as applicable.
Section 5. Written Approval for Authorized Use. Any limited operational use of smart glasses, wearable technology, or connected recording devices that is otherwise permitted under Policy No. IN_1680_01 shall be subject to the written approval procedures established therein.
Such approval may require review by the applicable Commissioner or Director, the Department of Management Services and/or Chief Information Officer, the Corporation Counsel, and Human Resources, as appropriate to the proposed use.
No approval shall authorize conduct prohibited by applicable law or supersede any mandatory legal, regulatory, records-management, privacy, labor, evidentiary, or law-enforcement requirement.
Section 6. Police Department Provisions. The Mount Vernon Police Department shall comply with the provisions of Policy No. IN_1680_01 applicable to smart glasses, wearable technology, and connected recording devices.
Smart glasses should not be considered official Mount Vernon Police Department equipment solely by virtue of their use by a member of the Department.
The use of any authorized wearable or recording technology by members of the Mount Vernon Police Department shall remain subject to applicable Department policies, procedures, evidentiary requirements, and the Department’s Body-Worn Camera Policy. Nothing herein shall be construed to replace, modify, or supersede the requirements governing officially issued body-worn cameras except as expressly provided by subsequent authorized policy or legislation.
Section 7. Incident and Data-Breach Reporting. Any unauthorized recording, collection, disclosure, transmission, loss, compromise, or suspected data breach involving a smart glass, wearable technology, or connected recording device used in connection with City business shall be reported in accordance with Policy No. IN_1680_01 and the City’s applicable incident-response and Breach Notification Policy.
The City shall take appropriate measures to preserve relevant records, secure affected information, investigate the incident, and provide any notices required by applicable law or City policy.
Section 8. Training and Compliance. The Department of Management Services, in coordination with the Chief Information Officer, Human Resources, Corporation Counsel, and affected City departments, as appropriate, shall establish or coordinate training and educational requirements necessary to implement Policy No. IN_1680_01.
Covered personnel shall comply with all applicable training, authorization, security, privacy, records-management, and operational requirements established under the Policy.
Section 9. Wearable Technology Review Committee. A standing Wearable Technology Review Committee is hereby authorized and established for purposes of periodically reviewing Policy No. IN_1680_01 and recommending appropriate revisions.
The Committee shall consider changes in technology, City operational needs, information-security risks, privacy requirements, records-management requirements, applicable laws and regulations, and other relevant developments.
Any amendment to the Policy that requires legislative approval shall be submitted to the City Council in accordance with applicable law.
Section 10. Relationship to Other City Policies. Policy No. IN_1680_01 shall be implemented in conjunction with the City’s Acceptable Use Policy, Policy for Safeguarding Personally Identifiable Information, Breach Notification Policy, Mount Vernon Police Department Body-Worn Camera Policy, records-retention requirements, and any other applicable City policy or procedure.
Where two or more applicable City policies address the same subject, the more protective requirement concerning privacy, information security, or protection of City information shall apply to the extent permitted by law, unless otherwise expressly provided by law or authorized City policy.
Section 11. Protection of Lawful Public Rights. Nothing in this Ordinance or Policy No. IN_1680_01 shall be interpreted or enforced in a manner that unlawfully restricts or interferes with lawful public recording, public access, freedom of information rights, protected speech, or any other right afforded under applicable federal, State of New York, or local law.
Section 12. Enforcement. Violations of Policy No. IN_1680_01 may result in appropriate administrative or disciplinary action, consistent with applicable law, collective bargaining agreements, civil service requirements, City personnel policies, and other governing authorities.
Nothing in this Ordinance shall limit any other remedy or enforcement authority available to the City under applicable law.
Section 13. Severability. If any provision of this Ordinance or Policy No. IN_1680_01, or the application thereof to any person or circumstance, is adjudged invalid by a court of competent jurisdiction, such determination shall not affect the validity of the remaining provisions or applications thereof, which shall remain in full force and effect.
Section 14. Implementation and Administration. The Commissioner or Director of Management Services, Chief Information Officer, Corporation Counsel, Human Resources, and all affected City departments are hereby authorized and directed to take such actions as are reasonably necessary to implement Policy No. IN_1680_01 and this Ordinance, consistent with applicable law and the authority granted herein.
Section 15. Effective Date. This Ordinance shall take effect immediately upon adoption.