Policy Text
Santa Clara County Office of the Sheriff
Inmate Tablet Monitoring
Surveillance Use Policy
Santa Clara County
Sheriff s Office
Custody Bureau
Santa Clara County Office of the Sheriff Custody Bureau
Surveillance Use Policy - Inmate Tablet MonitoringPage I of6
October 2019 (v3)
1. Purpose
The Inmate Tablet Services Platform (ITSP) provided by Legacy Long Distance Int'l Inc.
(Legacy) records inmate tablet activity, which is monitored to assess safety and security
issues within jail facilities. ITSP has an optional feature for inmate messaging, which shall
not he enabled until Legacy provides a technological solution to ensure that Privileged
Communication is not recorded or monitored by the County or Sherifls personnel. To
monitor tablet activity, Legacy will provide the Office of the Sheriff s administrative
accounts with access to a mobile device management system. This system shall be used to
help the Sheriff s Office assess risk to the Correctional Facilities based on information shared
by inmates during messaging that indicate security violations of inmates, introduction of
contraband, escape plans, intentions to attack staff or others, attempts to direct, control, or
participate in criminal behavior, or plans to adversely impact the jail's operation.
2. Authorized and Prohibited Uses
A Monitoring/Recording notice shall be prominently displayed on the tablets advising
inmates that their tablet usage is being monitored or recorded.
A.Authorized uses for the mobile device management system shall include only the
following:
1. Tablet Manasement
a. Remote lock/disable device
b. Remote Device Wipe
c. Device Factory Reset
d. Application Install and Removal
e. Control Network Access
f. Reassignment of Device to New User
g. Emergency Shutdown
h. Equipment Upgrades
i. App Upgrades
2. Inmate Intemal Controls
a. Translation - automatically translate inmate messages or requests into
English
b. Flagging - flag hot words, even misspellings, with e-mail or admin portal
notifications
c. Quarantines - block messages with hot words like "escape" before they
are sent
d. Link Analysis - analyze connections to external contacts and other inmates
e. "Cut & Pqste" detection - prevent or flag communication through outside
sources with detection of messages cut and pasted to other recipients
f. Filtered Searches - limit any search to a specific location or charge
Santa Clara County Office of the Sheriff Custody Bureau
Surveillance Use Policy - Inmate Tablet MonitoringPage 2 of 6
October 2019 (v3)
3. Tablet Monitorine
a. Listening to or monitoring in-progress ITSP calls and messaging
b. Reviewing recorded ITSP calls and messaging
c. Evidence collection from tablets
d. Other law enforcement, custody, or first responder uses not prohibited by
law
All uses not authorized above shall be prohibited. The mobile device
management system shall not be used for personal or non-official purposes. It
shall be used in alegal manner, and shall not be used to harass, intimidate, or
discriminate against any individual or group.
The Sheriff s Office shall not listen to, read, or record a communication known by
the listener, reader, or recorder to be privileged. Privileged communication shall
be defined as attorney-client communication, physician-patient communication,
and clergy-penitent communication. Any inadvertent recording of a privileged
communication (e.g., a communication by an inmate to the inmate's attorney)
shall be deleted upon discovery and ifthe recording has been copied, all copies
shall be deleted immediately.
DIf communication is made to the Adult Custody Office of the Ombuds (ACOO),
formerly known as the Jail Observer Progtam, the communication shall not be
observed, listened to or recorded.
3. Data Collection
A. It shall be permissible for the following data to be obtained through the mobile
device management system for each tablet:
a. Monthly Usage Reports by inmate or facility
o Courses completed
o Certificates Issued
o Points Eamed
o Peak Usage Times
b. Inmate's User Identification
c. User activity
o Content Viewed
o Progress on educational componentsB
C
Santa Clara County Office of the Sheriff Custody Bureau
Surveillance Use Policy - Inmate Tablet MonitoringPage 3 of6
October 2019 (v3)
. Aggregate Tablet Usage information
d. Number dialed by the inmate
e. Duration and content of call or messaging
f. Exact tablet the call or message was placed on
g. Submission details and tracking for Grievances, Requests, and
Commissary Orders
h. Actions taken by Sheriff s Office administrativs users to limit or restrict
inmate access
4, Data Access
Access to the mobile device management system data shall be limited to authorized Sheriff s Office
personnel in writing, which includes the Sheriff s Classification Unit, Intel Unit, Programs Unit,
Facility Commanders, Sheriff s persorurel conducting a specific criminal or administrative
investigation; and the vendor (Legacy) for only the purposes of maintaining their system
(maintenance, updates, quality control, etc.).
5. Data Protection
The County's contract for tablet monitoring shall require that data from the mobile device
management system shall be maintained securely. Currently, Legacy provides secure hard
drives located at its Cypress headquarters, to securely store all data captured by the mobile
device management system. The data shall be made available to the Classification Unit through
a secure web-based management portal, hosted by Legacy. All authorized staff with access to
the Legacy management portal shall observe all required security measures to ensure that
access to the mobile device management system is limited to authorized personnel only.
6. Data