City of Culver City Administrative Policy Statement
Policy Number: AP VI-06
Effective Date: March 13, 2026
Subject: Artificial Intelligence (“AI”) Governance Policy
Source/Authority: Information Technology Department through the City Manager’s Office
Statement of Policy:
Purpose:
This policy establishes a comprehensive, yet flexible, governance structure for AI systems used by, or on behalf of, the City of Culver City (“City”). This policy enables the City to use AI systems for the benefit of the community while safeguarding against potential harms.
The key objectives of the AI Policy are to:
- Provide guidance that is clear, easy to follow, and supports decision-making for staff (full-time, part-time), interns, consultants, contractors, partners, and volunteers who may be purchasing, configuring, developing, operating, or maintaining the City’s AI systems or leveraging AI systems to provide services to the City;
- Ensure that when using AI systems, the City or those operating on its behalf, adhere to the Guiding Principles that represent values with regards to how AI systems are purchased, configured, developed, operated, or maintained.
- Define roles and responsibilities related to the City’s usage of AI systems.
- Establish and maintain processes to assess and manage risks presented by AI systems used by the City;
- Align the governance of AI systems with existing data governance, security, and privacy measures in accordance with polices APVI-2 (Electronic Communications), AP VI-03 (Internet Use), and AP VI-04 (Network Access).
- Define prohibited uses of AI systems;
- Establish “sunset” procedures to safely retire AI systems that no longer meet the needs of the City;
- Define how AI systems may be used for legitimate City purposes in accordance with applicable local, state, and federal laws, and existing agency policies.
The City defines “Artificial Intelligence” or “AI” to be a machine-based system that can, for a given set of human-defined objectives, make predictions, recommendations, or decisions influencing real or virtual environments. AI systems use machine- and human-based inputs to perceive real and virtual environments; abstract such perceptions into models through analysis in an automated manner; and use model inference to formulate options for information or action.
The City defines an “AI system” to be any data system, software, hardware, application, tool, or utility that operates in whole or in part using AI. The City’s AI systems and the data contained therein will be purchased, configured, developed, operated, and maintained using the City’s AI Policy Handbook.
The City recognizes the utility of AI in enhancing operational efficiency. However, the City also recognizes that the use of AI involves risks, including but not limited to safety, security, privacy, bias, and accuracy.
All AI use must conform to the conditions set forth in this policy and any other City policies.
Scope of Policy
This policy applies to:
- All AI tools, including services, systems and any other processes that use AI technology deployed by the City. This policy applies only to AI usage performed while conducting official City duties using City systems or resources. Use of AI on personal devices, while off-duty, or in connection with labor-representation activities is not governed by this policy unless City data or systems are accessed.
- All City employees regardless of rank or title, interns, volunteers, and consultants, contractors, partner agencies, who may purchase, configure, develop, operate, or maintain the City’s AI systems may only use AI to promote public provided services and support the City’s mission.
- This policy applies to all work produced for the City, or associated in any way with the City, whether or not the work is produced using City equipment or resources.
- This policy sets the minimum standards expected of City employees. Individual departments may set stricter rules based on their specific needs.
- No employee shall be exempted from these minimum standards without the expressed written permission from the City Manager.
Guiding Principles for Responsible AI Systems
These principles describe the City’s values with regards to how AI systems are purchased, configured, developed, operated, or maintained.
- Human-Centered Design: AI systems are developed and deployed with a human-centered approach that evaluates AI powered services for their impact on the public.
- Security & Safety: AI systems maintain confidentiality, integrity, and availability through safeguards that prevent unauthorized access and use. Implementation of AI systems is reliable and safe, and minimizes risks to individuals, society, and the environment.
- Privacy: Privacy is preserved in all AI systems by safeguarding personally identifiable information (PII) and sensitive data from unauthorized access, disclosure, and manipulation.
- Transparency: The purpose and use of AI systems is proactively communicated and disclosed to the public. An AI system, its data sources, operational model, and policies that govern its use are understandable and documented.
- Equity: AI systems support equitable outcomes for everyone. Bias in AI systems is effectively managed with the intention of reducing harm for anyone impacted by its use.
- Accountability: Roles and responsibilities govern the deployment and maintenance of AI systems, and human oversight ensures adherence to relevant laws and regulations.
- Effectiveness: AI systems are reliable, meet their objectives, and deliver precise and dependable outcomes for the utility and contexts in which they are deployed.
- Workforce Enablement: Staff are supported in integrating AI into their roles through targeted education, hands-on training, and collaborative initiatives that promote participation and opportunity.
Roles & Responsibilities
Several roles are responsible for enforcing this policy, outlined below.
- With regards to this policy, the Chief Information Officer (CIO) is responsible for directing City technology resources, policies, projects, services, in coordination with other City departments.
- The CIO shall coordinate with departments to designate resources to actively ensure AI systems are used in accordance with City polices APVI- 2 (Electronic Communications), AP VI-03 (Internet Use), and AP VI-04 (Network Access) and adhere to all departmental policies. All City AI policies shall comply with all applicable laws and regulations, including, but not limited to, applicable transparency laws and regulations.
- The IT Security Analyst is responsible for overseeing the enterprise security infrastructure, cybersecurity operations, updating security policies, procedures, standards, guidelines, and monitoring policy compliance.
- The CIO is responsible for overseeing the enterprise digital privacy practices, data processing practices, and responsible usage of technologyin compliance with the City’s privacy standards. The CIO is responsible for overseeing the privacy practices of AI systems used by or on behalf of the City departments.
- City departments are responsible for following this policy and following updates to this policy and the AI Policy Handbook and shall check compliance with these documents at least annually.
- The CIO, or designee, shall notify City departments when an update to this policy or the AI Policy Handbook is released.
- The City Attorney’s office is responsible for advising regarding any legal issues or risks associated with AI systems usage by or on behalf of the City departments.
- The Appointing Authority or designee may, at their discretion, inspect the usage of AI systems and require the alteration or cease departmental usage of AI systems or a partner’s usage of AI systems on behalf of the department.
- The Information Technology Department and the Finance Department are responsible for overseeing the procurement of AI systems and assuring, via the use of appropriate contract terms, that vendors comply with City policy standards.
Purchasing Policy
When purchasing, configuring, developing, operating, or maintaining AI systems, the City will:
- Uphold the Guiding Principles for Responsible AI Systems; and
- Conduct an AI Review to assess the potential risk and anticipated employee impact of AI systems. As detailed in the AI Policy Handbook, the CIO is responsible for coordinating review of AI systems used by the City; and
- Obtain technical documentation about AI systems using the AI Procurement Fact Sheet or create equivalent documentation if internally developing the AI system. The Information Technology Department is responsible for requiring vendors to complete the AI Procurement Fact Sheet; and
- Require contractors to comply with the Requirements for AI Systems Addendum overseen by the City Attorney’s Office; and
- In the event of an incident involving the use of the AI system, the City will follow an Incident Response Plan as detailed in the AI Incident Response Plan. The IT Security Analyst is responsible for overseeing the security practices of AI systems used by or on behalf of the City departments.
Prohibited Uses
The City expressly prohibits any AI use which discriminates against any individuals, including but not limited to any individuals on the basis of the
individual’s race, religion, creed, color, national origin, ancestry, physical disability, mental disability, medical condition, genetic information, marital status, sex, gender, gender identity, gender expression, age, sexual orientation, reproductive health decision-making, or military and veteran status.
The use of certain AI systems is strictly prohibited due to the sensitive nature of the information processed and severe potential risk. This includes the following prohibited purposes:
- Real-time and covert biometric identification.
Example definition: The live identification of an individual using technologies including, but not limited to, facial recognition and iris scanning, without that individual's knowledge or meaningful consent.
- Emotion analysis, or the use of computer vision techniques to classify human facial and body movements into certain emotions or sentiment (e.g., positive, negative, neutral, happy, angry, nervous).
Example definition: The use of computer vision techniques to classify human facial expressions, body movement, or language into emotions or sentiment (e.g. positive, negative, neutral, happy, angry).
- Fully automated decisions that do not require any meaningful human oversight but substantially impact individuals.
- Social scoring, or the use of AI systems to track and classify individuals based on their behaviors, socioeconomic status, or personal characteristics.
Example definition: A "Social Scoring System" refers to artificial intelligence or algorithmic systems that aggregate and interpret an individual's personal data to assign a quantifiable score or rating that ranks them against other individuals and impacts their access to services, opportunities, or societal privileges. These systems are characterized by their use of data related to behavior, preferences, interactions, financial transactions, and other personal attributes which are not directly linked to the application of the score. They can be part of a comprehensive profile that is used to make significant decisions about an individual's rights, opportunities, or social standing.
- Cognitive behavioral manipulation of people or specific vulnerable groups.
Example Definition: "Cognitive behavioral manipulation" refers to AI- driven tools or algorithms designed to influence or alter an individual's decision-making process or belief system. These systems use psychological, behavioral, or emotional data to create targeted strategies that can manipulate thoughts, feelings, or actions, particularly focusing on vulnerable groups or individuals.
- Autonomous weapons systems.
Example Definition: Autonomous Weapons Systems refer to weapon systems that, once activated, can select, engage, and apply lethal and sub- lethal force to targets without human intervention.
- “Deepfake” Material.
Example Definition: A “deepfake” is an image, video, or audio record that has been digitally altered to replace one person’s likeness with another person, or a computer-generated image or video of a person doing or saying something the person never did or said.
Duty to Report Harm Caused by AI
If individuals become aware of an instance where an AI system has caused harm, the incident shall be immediately reported to their supervisor and the City Manager’s office.
Sunset Procedures
If an AI system operated by the City or on its behalf is determined to have ceased to provide positive utility to the City’s residents, then, after review and concurrence regarding that determination by the City Attorney’s Office, the use of that AI system must be halted unless express exception is provided by the Appointing Authority or if governed by statutory obligations . If the abrupt cessation of the use of that AI system would significantly disrupt the delivery of City services or impair public safety, usage of the AI system shall be gradually phased out over time.
Public Records
The City is subject to the applicable Public Records Act policy. City employees shall follow all current procedures for records retention and disclosure.
Policy Enforcement
All staff and agents of the City, regardless of status (e.g., permanent or temporary, interns, volunteers, contractors, consultants, vendors, and other third parties, etc.) operating AI systems on behalf of the City are required to abide by this Policy and the associated AI Policy Handbook.
Violations of the AI Policy
Violations of any section of this AI Policy, including failure to comply with the City’s AI Policy Handbook, may be subject to disciplinary action, up to and including termination. No employee shall be subject to discipline for outcomes or analytical inaccuracies generated by an AI system when the employee uses the system in good faith and in accordance with City policies, regulatory standards, and training. Violations made by a third party while operating an AI system on behalf of the City may result in a breach of contract and/or pursuit of damages. Violations of local, state, federal or international law may be referred to the proper authorities.
Terms & Definitions
Artificial Intelligence: “Artificial intelligence” or “AI” is defined to be a machine- based system that can, for a given set of human-defined objectives, make predictions, recommendations, or decisions influencing real or virtual environments. Artificial intelligence systems use machine- and human-based inputs to perceive real and virtual environments; abstract such perceptions into models through analysis in an automated manner; and use model inference to formulate options for information or action.
Algorithm: A series of logical steps through which an agent (typically a computer or software program) turns particular inputs into particular outputs.
AI system: Any system, software, sensor, or process that automatically generates outputs including, but not limited to, predictions, recommendations, or decisions that augment or replace human decision-making. This extends to software, hardware and algorithms used to automate large-scale processes, generate large data sets and/or analyze large data sets.
Appointing Authority: The City Council, the City Manager, the department head, division heads and/or other body of officials or individual official having, under law, the power to make an appointment to a position. Routine functions of the appointing authority may be delegated to accomplish the purposes set forth in this policy, but the appropriate appointing authority shall be responsible for the actions or functions of such delegation or designee.
Additional terms and definitions are provided in the AI Policy Handbook.
Acknowledgement
The initial draft of this policy was developed through the coordinated efforts of over 150 state and local agencies in the GovAI Coalition who are dedicated to the responsible and purposeful use of AI that benefits all members of the community.