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A communication transmitted from Yi-An Huang, City Manager, relative to a Surveillance Technology Impact Report (STIR) for SMS Non-Emergency Alert Notifications requested by the Communications & Community Engagement Department.
SURVEILLANCE TECHNOLOGY IMPACT REPORT
Department:
Executive
Division or Unit
(if applicable):
Communications Office
Submitted by:
Jeremy Warnick
Date:
4/9/26
Surveillance
Technology:
SMS Non-Emergency Alert Notifications
1. Describe how the proposed Surveillance Technology will work, including how it
will collect Surveillance Data.
A mass notification system can enable the City to create and issue strategic
communications to residents and distribute them for consumption based on
residents’ preferences. We are looking to explore platforms that would allow the
City -- via the Communications and Community Engagement Office -- the ability to
conduct outreach via SMS/text messaging.
The Communications and Community Engagement Office currently has no way of
conducting SMS outreach for non-emergency related communications. It is reliant
on CodeRed, Tip411 and other public safety-related tools.
Adding SMS/text messaging for non-emergency situations could serve as a critical
tool and complement the City’s existing digital, print, and in-person outreach.
The Communications and Community Engagement Office is interested in
conducting a no-cost pilot to measure the effectiveness of this tool. If proven
effective, the Office would look to extend the service agreement.
The platform functions as a managed communications delivery service — not a
surveillance, analytics, or data aggregation system. The system operator would not
independently collect, track, or harvest constituent data (e.g. no location data, no
device metadata, no behavioral tracking, no passive data collection). The platform
operates exclusively on information that users voluntarily provide through City and
system-operator hosted webforms (e.g. name, email and/or mobile phone number,
communications preferences). The system operator would not sell, share, or use
constituent data for any purpose beyond delivering the contracted communications
services.
2. What is the purpose of the Surveillance Technology?
• Analyzing and managing communications service delivery;
• Targeting communications to verified residents and responding to any
questions, issues or concerns sent via the system (e.g. resident seeks
additional details on a road closure or extended event notice);
• Amplifying and optimizing communication with community members,
particularly at a hyper-targeted level. Ideally, this would help the
Communications and Community Engagement Office test potential impact
(both the application and notifications at a broader scale) by leveraging a
platform for targeted outreach in some defined areas where there are issues
or opportunities (e.g. residents whose preference is not email or social
media; with residents where there was low parking ban compliance during
the Snow Emergency Parking Ban).
3. Where will the Surveillance Technology be deployed? When?
The web application would initially be housed on three accounts in the
Communications and Community Engagement Office. It could be downloaded to
other accounts in the Communications and Community Engagement Office with
Department head approval. A pilot could be available for use anytime in the first
half of 2026 following onboarding and training sessions.
4. What privacy impact will the Surveillance Technology have?
The web application will initially include resident phone/SMS contact data that is
sourced by the web application company and then layered on top of publicly
available voter registration data in Cambridge.
While residents are initially opted in to receive the SMS/text message for the pilot
and any extended service agreements, they would have the option to opt-out from
any future SMS/text messages sent by the City at any time.
This meets the Telephone Consumer Protection Act (TCPA), passed by Congress in
1991, which protects consumers from unwanted marketing calls and text
messages1. Furthermore, it also meets the Cellular Telecommunications Industry
Association (CTIA) messaging guidelines used by mobile carriers.
Any other data would be associated with inbound communications from users who
respond to messages from the City (e.g. mobile phone number from which a reply
was sent, text content of the reply message, and a timestamp of a reply). The
Communications and Community Engagement Office would address these privacy
impacts by limiting access to designated employees in the office. Access would be
password protected, and the employees would receive detailed training on best
practices for protecting personal information.
5. What are the fiscal costs of the Surveillance Technology, including initial costs,
ongoing maintenance and personnel costs, and source of funds?
• Initial costs - 10,000 text credits would be provided for free for the pilot.
• Ongoing maintenance - If the Communications and Community Engagement
Office were to extend service after the pilot following analysis of its
effectiveness, the City could have access to unlimited text credits each year for
$9,500.
• Source of funds – If extended, the initial annual cost would be addressed under
E-Gov and then integrated into the Communications and Community
Engagement Office’s Operating costs thereafter, if evaluations prove its value as
anticipated.
1 Under TCPA rules, companies must respect a person’s request to stop receiving marketing texts.