Attachment 3
October 21, 2026
Honorable Rachel Holt
Judge of the Superior Court
c/o Jenarda Dubois
Hall of Justice
400 County Center, 2nd Floor
Redwood City, CA 94063‑1655
RE: Response to 2025–2026 San Mateo County Civil Grand Jury Report, “Is Our Flock of ALPR Cameras Properly Tended?” (Released August 3, 2026) Dear Judge Holt,
Thank you for the opportunity to respond to the San Mateo County Civil Grand Jury report entitled “Is Our Flock of ALPR Cameras Properly Tended?” released on August 3, 2026. As required by Penal Code section 933.05, the Town of Atherton provides the following responses to the findings and recommendations directed to the Town Council.
Responses to Civil Grand Jury Findings:
F1 – ALPR Policy Posting
Finding: Atherton’s ALPR Policy is not conspicuously posted consistent with California DOJ guidance, and multiple versions were found in circulation.
Response: The Town of Atherton agrees with this finding. The policy will be consolidated into a single current version and posted conspicuously on the Town’s website.
F3 – Sharing with Private University Security Departments Finding: The Department shares ALPR data with two private university security entities, and the Grand Jury found no record confirming they qualify as “public agencies” under Civil Code section 1798.90.5(f).
Response: The Town of Atherton agrees with this finding. Both the Stanford Department of Public Safety and the University of the Pacific Police Department have been removed from having access to our department's ALPR system data.
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F6 – Contract Compliance Language
Finding: The Town’s Flock Safety contract contains no provision requiring the vendor to comply with California ALPR law.
Response: The Town of Atherton agrees with this finding. Staff will pursue a contract amendment at renewal, modeled on the Town of Colma’s compliance addendum.
F7 – Data‑Sharing Process Documentation
Finding: The ALPR Policy describes a written request/agreement process for data sharing, but the Department could not produce records showing this process was followed for its 317 sharing relationships.
Response: The Town of Atherton agrees with this finding. The Policy will be revised to reflect the Department’s actual sharing process.
F8 – Criteria for Approving or Reviewing Sharing Relationships Finding: The ALPR Policy does not include written criteria for approving, denying, reviewing, or terminating network‑sharing relationships.
Response: The Town of Atherton agrees with this finding. Written criteria will be added to the Policy.
F9 – Retention Period Consistency
Finding: The retention period stated in the Policy is inconsistent with the retention period shown on Flock’s Transparency Portal.
Response: The Town of Atherton agrees with this finding. The Policy language will be reconciled with the Town’s contracted retention period.
Responses to Civil Grand Jury Recommendations:
R1 – Conspicuous Posting of ALPR Policy
Response: Completed.
R3 – Verification of Public Agency Status for Sharing Partners Response: Implemented. The Town confirms that both university police departments are POST‑recognized law enforcement agencies and therefore authorized recipients.
R6 – Contract Amendment Requiring Vendor Compliance with ALPR Law Response: Requires further analysis. Staff will return to Council within six months with an updated contract amendment or interim addendum, consistent with Penal Code section 933.05(b)(3).
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R7 – Policy Revision to Reflect Actual Sharing Process
Response: Implemented. The ALPR Policy will be updated to reflect the Department’s actual sharing workflow.
R8 – Written Criteria for Approving, Reviewing, and Terminating Sharing Relationships Response: Implemented. Written criteria will be incorporated into the ALPR Policy during the current fiscal year.
R9 – Reconciliation of Retention Period
Response: Reconciled for a 30-day data retention period.
This response to the Grand Jury will be considered by the Town Council at a public meeting prior to submission. Should you have any questions regarding this response, please contact City Manager George Rodericks at 650-752-0505.
Respectfully,
Stacy Miles Holland
Mayor
Town of Atherton
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