Our Flock of Alpr Cameras Properly Tended?

Recommendations 9

• R1
  The ALPR operator should conspicuously post the current version of their ALPR Policy as required by Civil Code sections 1798.90.51(a)–(b).
• R2
  The ALPR operator with outdated ALPR policies should revise those policies to accurately reflect current operational practices.
• R3
  The ALPR operator currently identified as sharing ALPR data with private university security entities should obtain and retain a written legal and factual determination that the recipient is a “public agency” under Civil Code section 1798.90.5(f), or that the sharing is otherwise permitted by law; if no lawful basis exists, the operator should terminate the sharing relationship.
• R4
  The ALPR operator should prepare audit reports in accordance with the frequency stated in the operator’s published ALPR policy.
• R5
  The audit reports produced by the ALPR operator should substantiate compliance with applicable California law and the operator’s published ALPR policy.
• R6
  Upon contract renewal, the ALPR operator should incorporate contractual language requiring vendor compliance with applicable California law and prohibiting vendors from disclosing ALPR data to unauthorized third parties. Operators should consider provisions similar to those contained in the Town of Colma contract with Flock.
• R7
  The ALPR operator should update its ALPR policy to accurately reflect the process used to approve ALPR data-sharing relationships.
• R8
  The ALPR operator should include in their ALPR policies written criteria governing the approval, denial, periodic review, and termination of in-state ALPR network-sharing relationships.
• R9
  The ALPR operator should update their ALPR policy or Flock contract terms, as necessary, so that the stated retention rule accurately reflects operations.