St Louis, MO Board Bill Number 185 2023-24

Require the Board of Aldermen to approve any procurement or use of surveillance technology by City Entities, detailing requirements for Surveillance Use Plans. Enforce disclosure, reporting, and public involvement. Mandate protections against discriminatory impacts, audits, and whistleblower protections.

  • Authority: St. Louis, MO
  • Parent authority: Local governments
  • Jurisdiction: United States
  • Collections: U.S. state and local documents
  • Most recent activity: Enacted
  • Most recent activity date: 2024-05-06

Risk subdomain coverage

Good coverage — Comprehensive governance measures or mitigations with clear procedures relating to the risk subdomain are explicitly described.

  • Unfair discrimination and misrepresentation
  • Unequal performance across groups
  • Compromise of privacy
  • AI system security vulnerabilities
  • Disinformation, surveillance, and influence at scale
  • Governance failure
  • Lack of transparency or interpretability

Minimal coverage — Brief mention but no specific mitigations, recommendations or governance measures relating to the risk subdomain are described.

  • Fraud, scams, and targeted manipulation
  • Overreliance and unsafe use
  • Loss of human agency and autonomy

All other risk subdomains had no coverage in this document.

Risk Coverage Summary

The document has good coverage of approximately 8-10 subdomains, with strong focus on privacy compromise (2.1), security vulnerabilities (2.2), disinformation and surveillance (4.1), fraud and manipulation (4.3), overreliance and unsafe use (5.1), loss of agency (5.2), unfair discrimination (1.1), unequal performance (1.3), and governance failure (6.5). Coverage is concentrated in privacy, security, malicious actor prevention, human-computer interaction, and governance domains.

Sector coverage

Good coverage — Comprehensive governance measures or mitigations with clear procedures relating to the sector are explicitly described.

  • Public Administration (excl. National Security)

Minimal coverage — Brief mention but no specific mitigations, recommendations or governance measures relating to the sector are described.

  • Health Care & Social Assistance

All other sectors had no coverage in this document.

Sectors Summary

This ordinance primarily governs Public Administration (excluding National Security), as it regulates surveillance technology procurement and use by City of St. Louis government entities including police departments, city agencies, and municipal offices. It does not regulate private sector entities or other economic sectors.

Legislative Status

Hard Law

Legislative Status Summary

This is a binding municipal ordinance with mandatory compliance requirements, enforcement mechanisms including civil legal proceedings and disciplinary actions, and explicit penalties for violations.

Actors

Proposer

  • Entity Types: AI_Governance_Actor
  • Entities: Board of Aldermen of St. Louis, MO
  • Summary: The document is a Board Bill introduced to the Board of Aldermen, which is the municipal legislative body proposing this surveillance technology governance ordinance.

Target

  • Entity Types: AI_Governance_Actor, AI_Deployer
  • Entities: City Entity (any agency, department, bureau, unit, or commission of the City of St. Louis); St. Louis Metropolitan Police Department; Real-time crime centers (RTCC)
  • Summary: The ordinance applies to all City Entities that seek to acquire, use, or deploy surveillance technology including AI-enabled surveillance systems. City Entities are the regulated parties who must obtain approval and comply with surveillance use plans.

Enforcer

  • Entity Types: AI_Governance_Actor
  • Entities: Board of Aldermen; Committee (of the Board of Aldermen); Courts of competent jurisdiction; Civil Rights Enforcement Agency (CREA); Division of Civilian Oversight
  • Summary: The Board of Aldermen has approval authority and oversight responsibility. Courts have enforcement authority through civil legal proceedings. The CREA and Division of Civilian Oversight may provide review and recommendations. City Entities themselves must enforce disciplinary actions against employees.

Monitor

  • Entity Types: AI_Governance_Actor
  • Entities: Board of Aldermen; Committee; Civil Rights Enforcement Agency (CREA); Division of Civilian Oversight; Information Technology Department; City Counselor's Office; Lead City Entity (for multi-entity surveillance technology)
  • Summary: Multiple entities have monitoring responsibilities including the Board of Aldermen through annual reports, the Committee through hearings, and various city agencies through review and oversight. Lead City Entities are responsible for ensuring compliance with surveillance use plans.

AI Lifecycle Stages

Lifecycle stages covered by the documents, as defined in the OECD Framework for the Classification of AI Systems

  • Plan and Design
  • Collect and Process Data
  • Verify and Validate
  • Deploy
  • Operate and Monitor

AI Lifecycle Summary

The document primarily covers the Deploy and Operate and Monitor lifecycle stages, with substantial requirements for deployment approval processes and ongoing monitoring through annual reports. It also addresses aspects of Plan and Design through the Surveillance Use Plan requirements, and Verify and Validate through required auditing and oversight mechanisms.

Technical Scope

Terms relating to technical scope that are mentioned or implicitly referenced in the document

  • AI Systems
  • Predictive AI

Technical Scope Summary

The document explicitly mentions AI systems and surveillance technology that includes Artificial Intelligence. It defines AI broadly consistent with federal definitions and specifically includes 'technology that includes Artificial Intelligence to deploy, direct, execute, analyze, or engage in surveillance' within the scope of regulated surveillance technology. The document does not distinguish between different types of AI models or systems beyond this general definition.

https://www.stlouis-mo.gov/government/city-laws/upload/legislative/BoardBills/support-documents/BB185CS%20Clean%20Copy.pdf
https://agora.eto.tech/instrument/2035
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Document data from AGORA, CSET Emerging Technology Observatory.