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Flock Safety ALPR Policy

 

Regarding California Senate Bill 34 (SB 34): SB 34 defines types of parties involved in use of ALPR systems such as “end-users” and “operators” and has specific requirements for each. Flock Safety is not an “end-user” or an “operator” as currently defined in SB 34, but rather a technology developer and provider of ALPR systems. However, Flock Safety has adopted a usage and privacy policy meeting the requirements of SB 34 out of an abundance of caution. Flock Safety agrees with the California State Auditor in its February 2020 report where providers of ALPR technology were typically characterized as “third party vendors” who provide a “user interface” to customers such as law enforcement agencies who are the “operators” of the ALPR technology.

What is it: Automated License Plate Recognition (ALPR or LPR) captures and stores digital images of license plates, and uses character recognition to identify and store plate characters. The system creates a searchable computerized database, segmented by customer, resulting from the Flock Safety LPR cameras in use by Flock Safety customers. The ALPR system data includes license plate number as well the date, time and location when the image was collected.

Purpose: Identification of vehicles entering, exiting and traveling within the areas of interest  of Flock Safety customers will enhance security and safety of those areas. 

Training: LPR operators will receive initial training from the company (Flock Safety) on the procedure and proper use of the system prior to being granted access to the LPR system; each user will also receive annual refresher training from the assistant director or designee.

Access: Each Flock Safety customer will designate one or more “administrators” who are the custodians and head administrators of the ALPR systems and its operation. Each customer’s data is only accessible to the administrator(s) or administrator(s) designees of that customer. 

All logins and queries will be stored and monitored including:

  • Username
  • Date
  • Time
  • Purpose of query
  • License plate and other elements used to query the system

These data points will be stored in the Flock Safety system, and periodic audits will be conducted according to the policies of each Flock Safety customer to ensure access was made by authorized persons for legitimate purposes.

Information Collected: Information collected by the ALPR system is as follows:

For ALPR:

  • License plate image captured
  • Vehicle image captured
  • License plate number
  • License plate state
  • Date
  • Time
  • Location
Security: We use administrative, operational, technical and physical safeguards to protect ALPR information from unauthorized access, use, destruction, modification or

disclosure.

Administrative: Username and password protected access to the LPR system. Monitoring and auditing usage of database.

Operational: Training and proper use and secure practices when using LPR and its database.

Physical: Multi factor secured VPN access to database, and secure off-site database.

Technical: All information is encrypted in transit from camera to cloud storage and encrypted at rest in the cloud.

In the very unlikely event of an information breach, all individuals who are believed to be affected or have their information compromised will be notified by Matt Feury (CTO, Flock Safety) or Davis Lukens (Head of Product, Flock Safety).

Quality Assurance: ALPR is automated so the license plate images and details of collection are included in the system without review. Although infrequent, license plate translation may be incomplete or inaccurate. Users will confirm the computer translation prior to taking any action based on ALPR results.

Flock Safety, the ALPR vendor will store the data (data hosting) and ensure proper maintenance and security of data stored in their cloud-based system. Flock Safety will also be in charge of purging data at the end of the 30 days of storage.

Releasing ALPR Data: Information gathered or collected and records retained by the Flock Safety system on behalf of Flock Safety Customers will not be:

  • Sold, published, exchanged, or disclosed for commercial purposes.
  • Disclosed or published without authorization.
  • Disseminated to persons not authorized to access or use the information.

However, Flock may access, use, preserve and/or disclose the Footage to law enforcement authorities, government officials, and/or third parties, if legally required to do so or if Flock has a good faith belief that such access, use, preservation or disclosure is reasonably necessary to: (a) comply with a legal process or request; (b) enforce this Agreement, including investigation of any potential violation thereof; (c) detect, prevent or otherwise address security, fraud or technical issues; or (d) protect the rights, property or safety of Flock, its users, a third party, or the public as required or permitted by law, including respond to an emergency situation.

Data Retention: License plates will be stored in the system for no longer than 30 days. 

Privacy: This policy governs the Automated License Plate Recognition System (ALPR System or ALPR) provided by Flock Safety, and applies to our employees, customers, and camera and data hosting affiliates.

The images stored in the system are collected from areas visible to the public where there is no reasonable expectation of privacy. License plate image and affiliated data will be purged after a 30 day period.