Proposed draft — not law
PROPOSED draft language under legal review — not enacted law, not a filed bill — Illinois only.
Safety Monitoring Without Surveillance
Cameras count — they never identify. The BIPA firewall is written into the definition itself.
In plain language
Two of the numbers that matter most in a safety record — how many people were in the water, and how many trained staff were watching them — are exactly the ones nobody reliably writes down. The draft lets cameras produce them, under unusually strict limits.
A Video Safety Monitoring System ingests real-time video from a facility's cameras through a secure API and applies automated analysis solely to derive three things: aggregate bather load, the number of safety personnel on duty, and staffing and shift information. Numeric counts and status only.
The privacy limits are written into the statutory definition, not left to vendor policy: the system shall not create, store, or transmit any biometric identifier or biometric information as defined by Illinois's Biometric Information Privacy Act (740 ILCS 14), shall not perform facial recognition or otherwise identify any individual, and shall not retain the underlying video beyond the interval needed to derive the counts.
Under §11.3, a facility may satisfy its bather-load and staffing-verification requirements through an approved system — and only the derived counts, never the imagery, are transmitted to the Department. Derived shift data may be reconciled with the facility's own timekeeping system for staffing compliance.
What the July 2026 draft already covers
Both the §3.27 definition — including its hard BIPA firewall — and the §11.3 operative section are the base draft's work.
What Pure Water Ops adds
Nothing on this theme — Pure Water Ops made no changes to these sections. They are presented here because the redline builds on them.
What it means
For operators
Existing cameras can satisfy bather-load and staffing verification through an API connection — no manual headcounts, and no imagery ever leaves the facility's own system.
For regulators
Staffing compliance becomes verifiable against derived counts and timekeeping reconciliation instead of after-the-fact video review.
For the public
The pool's cameras cannot legally be turned into an identification system. The statute — not a privacy policy — says counts only: no faces, no retained footage.