1. The CCOPS Model: How It Works
The Community Control Over Police Surveillance (CCOPS) campaign was launched by the ACLU in 2016. Over 26 jurisdictions have enacted CCOPS laws or equivalent ordinances. The core principle: police departments should not acquire, fund, or deploy surveillance technology without community knowledge and elected official authorization.
Pre-Acquisition Approval
Mandatory council vote before acquiring or deploying surveillance technology.
Surveillance Impact Report
Public release at least 21 days before any hearing. Includes civil liberties assessment, capabilities, and data practices.
Surveillance Use Policy
Defines authorized uses, retention limits, sharing agreements, and audit mechanisms.
Annual Public Reporting
Usage data, geographic deployment, complaints, audit results, and costs, published publicly.
Enforcement Mechanisms
May include private right of action, exclusionary rule, and employee discipline.
Not every city adopts every element. The framework is modular. Our proposal draws from the strongest elements across multiple cities.
Source: ACLU CCOPS Campaign
2. Comparison Matrix
How existing city frameworks compare to our proposal for Overland Park.
| Provision | Oakland | Seattle | Lawrence, KS | Providence | Nashville | Our OP Proposal |
|---|---|---|---|---|---|---|
| Pre-Acquisition Council Approval | Yes | Yes | Yes | Yes | Yes | Yes (Sec. 1) |
| Civilian Oversight Body | Privacy Advisory Commission | Working Group | Proposed | Civilian review | Review Board | Advisory Panel (Sec. 4) |
| Facial Recognition | Banned | Restricted | Banned | Banned | Restricted | Banned (Sec. 13) |
| Surveillance Impact Reports | Yes | Yes | Yes | Yes | Yes | Yes (Sec. 2) |
| Annual Transparency Reports | Yes | Yes | Yes | Yes | Yes | Yes, 10+ metrics (Sec. 19) |
| Data Retention Limits | Yes | Yes | Yes | Yes | Yes | Tiered: 30d LPR, 90d video (Sec. 18) |
| Vendor NDA Prohibition | Yes | No | Unclear | No | No | Via data ownership (Sec. 6) |
| Private Camera Registry | No | No | No | No | No | Yes, quarterly (Sec. 10) |
| Parallel Access Prohibition | No | No | No | No | No | Yes (Sec. 11) |
| Neighbor Notification (Field of View) | No | No | No | No | No | Yes (Sec. 12a) |
| Data Broker Restrictions | No | No | No | No | No | Yes, court order req. (Sec. 9) |
| AI / Algorithmic Verification | No | No | No | No | No | Yes, human corroboration (Sec. 15) |
| Active Incident Framework | No | No | No | No | No | Yes (Sec. 5) |
| Evidentiary Exclusion | Partial | No | Unclear | No | No | Yes (Sec. 22) |
| Derived Data Addressed | No | No | No | No | No | Yes, defined & deletion-tracked (Sec. 0, 18) |
| Vendor Deletion Verification | No | No | No | No | No | Yes, certified hard-deletion (Sec. 6) |
| Retention Ceiling | No | No | No | No | No | Yes, 3/7 year max (Sec. 18) |
| Private Right of Action | Yes | No | No | No | No | Yes, modeled on Oakland (Sec. 23) |
| Environmental Impact Analysis | No | No | Yes | No | No | No |
| Racial Equity Toolkit | No | Yes | No | No | No | Via geographic analysis |
Key takeaway: Our proposal incorporates the strongest elements from the national CCOPS movement while adding several provisions that go beyond what any single city has adopted: private camera registry, parallel access prohibition, neighbor notification, data broker restrictions, AI verification, derived data deletion, vendor deletion certification, retention ceilings, and a private right of action modeled on Oakland's. These additions reflect the specific technology Overland Park is deploying (Fusus, Flock, DFR drones) and the unique circumstances of the 2026 FIFA World Cup.
3. City-by-City Breakdowns
Oakland, CA
Gold Standard Enacted 2018Oakland's framework is widely considered the most comprehensive CCOPS model in the country. The Privacy Advisory Commission (PAC) reviews every proposed surveillance technology before it can go to City Council. Oakland bans facial recognition and predictive policing outright, prohibits vendor NDAs, and, critically, gives residents a private right of action to sue for violations. Our proposal's Section 23(a) is modeled directly on Oakland's approach, giving the framework enforcement teeth that don't depend on the City prosecuting itself.
What Worked
- Structured public process builds legitimacy for approved tech
- NDA prohibition forces genuine transparency
- Private right of action gives the ordinance real teeth
Limitations
- Does not address private camera integration
- No AI verification or algorithmic corroboration
- Enforcement depends on individual citizens suing
Source: Oakland Municipal Code Ch. 9.64
Seattle, WA
Enacted 2017Seattle's framework is notable for two innovations: it required a retrospective audit of technologies already in use, and it applies a Racial Equity Toolkit to all surveillance proposals. The Community Surveillance Working Group requires at least 5 of 7 members from communities historically subject to disproportionate surveillance.
What Worked
- Retrospective review caught previously unexamined tech
- Racial equity lens creates structured disparate-impact analysis
- Community composition requirement ensures representation
Limitations
- No facial recognition ban (restricted but not prohibited)
- No NDA prohibition
- Working Group is advisory only
Source: Seattle Municipal Code Ch. 14.18
Lawrence, KS
Draft KansasThe Lawrence Transparency Project formed in response to the Lawrence Police Department's deployment of Fusus, the same platform Overland Park is deploying. Their draft ordinance operates under the same state legal framework: Kansas Home Rule authority, K.S.A. 45-217 ALPR exemptions, and no state preemption. It requires written MOUs for all camera access, bans facial recognition, and proposes a public dashboard.
What Worked
- Demonstrates Kansas communities can organize on this
- Public dashboard goes beyond annual reporting
- MOU requirement creates clear legal documentation
Limitations
- Still in draft form, not yet enacted
- Does not address parallel access through vendor portals
- No framework for drone governance
Source: Lawrence Transparency Project
Providence, RI
Enacted
Enacted a CCOPS-style ordinance with a facial recognition ban and council approval for new surveillance technologies. Demonstrates that mid-sized cities, not just major metros, can adopt comprehensive frameworks.
Nashville, TN
Enacted (partial)
Community Review Board issues public reports specifically on Fusus usage, creating a Fusus-specific accountability mechanism most cities lack. Directly relevant to the same platform OP is deploying.
Additional Cities of Note
San Francisco, CA: First major US city to ban facial recognition (2019)
Boston, MA: Banned facial recognition; council approval required
Portland, OR: Broadest ban: covers both public and private use
Denver, CO: $100K/violation penalties; customized Flock contract
Madison, WI: Comprehensive CCOPS with data retention emphasis
Berkeley, CA: Sanctuary contracting ordinance restricting vendor relationships
Fusus-Specific Oversight
Columbia, MO: Rejected Fusus 4-3 in 2022 after community opposition
Buncombe County, NC: Officers must log access reasons with auditing
Cleveland, OH: Community Police Commission has final policy authority
4. Cities That Rejected or Restricted Surveillance Technology
At least 23 jurisdictions have canceled or rejected Flock Safety contracts as of January 2026.
| City | Action | Reason |
|---|---|---|
| Austin, TX | Canceled | Privacy and oversight concerns |
| Denver, CO | Added restrictions | $100K/violation penalties |
| Santa Cruz, CA | Rejected | Comprehensive surveillance ban |
| Cambridge, MA | Rejected | Civil liberties concerns |
| Flagstaff, AZ | Canceled | Privacy concerns |
| Columbia, MO | Rejected Fusus (4-3) | Community opposition |
| Berkeley, CA | Added restrictions | Sanctuary contracting ordinance |
Note: Rejecting or restricting surveillance technology is not an anti-police position. These are cities making informed decisions about which tools serve their communities. That is exactly the kind of decision-making our proposal enables for Overland Park.
5. What Worked, What Didn't, and Lessons for Overland Park
What Works Across Frameworks
- Pre-acquisition council approval is the single most effective provision. Once technology is deployed, restricting it becomes exponentially harder.
- Public reporting requirements create accountability even when technologies are approved. Public debate changes how departments use the tools.
- Facial recognition bans have proven durable and politically achievable across ideological lines.
- Civilian advisory bodies work best with defined roles, access to real data, and a clear reporting relationship to Council.
What Doesn't Work or Has Gaps
- Advisory-only bodies without data access become rubber stamps. Our proposal gives audit log access (Sec. 17).
- No existing framework addresses parallel access through vendor portals. Our Section 11 fills this gap.
- No framework addresses neighbor notification for private cameras. Our Section 12a is a new provision.
- Most frameworks predate AI analytics. Our AI verification rule (Sec. 15) and technology update trigger (Sec. 3) address current capabilities.
- Enforcement is the weakest link. Our evidentiary exclusion (Sec. 22) and private right of action (Sec. 23) create both systemic and individual mechanisms.
Lessons for Overland Park Specifically
Ordinance Over Policy
Every city where oversight has been effective codified it in ordinance, not department policy. Policies can be changed unilaterally by the Chief. Ordinances require a public vote.
Kansas Home Rule Is an Asset
Article 12, Section 5 of the Kansas Constitution grants cities power over local affairs. No Kansas statute prohibits local regulation of ALPRs, drones, or surveillance tech.
No Preemption = Opportunity + Fragility
Without state-level protections, local ordinances are the only safeguard. Getting it right locally is critical.
Timing Matters
Cities that enacted governance before or during deployment have stronger frameworks. OP's RTIC launches April 2026. The window is now.
6. How Our Proposal Compares
Our proposal incorporates the strongest elements from the national CCOPS movement while adding provisions that address the specific technology Overland Park is deploying.
Adopted from National Models
- ✓ Council authorization with periodic review (Oakland, Seattle, Lawrence)
- ✓ Civilian advisory panel (Oakland PAC model, adapted)
- ✓ Facial recognition ban (Oakland, SF, Boston, Portland, Lawrence)
- ✓ Surveillance Impact Reports (standard CCOPS)
- ✓ Annual Transparency Reports (standard CCOPS)
- ✓ Data retention limits (multiple cities)
- ✓ Evidentiary exclusion (Oakland concept, adapted)
- ✓ Private right of action (Oakland model, Sec. 23)
New for Overland Park
- ★ Private Camera Registry (Sec. 10): No existing CCOPS ordinance requires this
- ★ Parallel Access Prohibition (Sec. 11): Closes the vendor-portal loophole
- ★ Neighbor Notification (Sec. 12a): Field-of-view disclosure for private cameras
- ★ Data Broker Restrictions (Sec. 9): Court order required for commercial data
- ★ AI Verification Rule (Sec. 15): Human corroboration before enforcement
- ★ Active Incident Framework (Sec. 5): Structured emergency operations
- ★ AI Training Prohibition (Sec. 6): Vendors cannot use data for model training
- ★ Technology Update Trigger (Sec. 3): Proactive vendor change notification
- ★ Derived Data Deletion (Sec. 0, 18): AI-generated metadata follows source deletion schedule
- ★ Vendor Deletion Certification (Sec. 6): Proof data is actually destroyed
- ★ Retention Ceiling (Sec. 18): 3/7 year max prevents indefinite storage