CITY OF BELMONT
CITY COUNCIL AND BELMONT FIRE
PROTECTION DISTRICT BOARD OF
DIRECTORS
www.belmont.gov
1. ROLL CALL
2. ITEMS OF BUSINESS
3. STUDY SESSION
A. Automated License Plate Readers (ALPRS)
CITY COUNCIL SPECIAL MEETING AGENDA
Tuesday, June 27, 2023
6:30 PM
City Council Chambers
City Hall, One Twin Pines Lane, Belmont, California
The meeting will be broadcast live to Belmont residents on Comcast Cable Channel 27, streamed live via the City’s website at www.Belmont.gov. The public may also attend the meeting in the City Council Chambers and address the council from the chambers.
PUBLIC COMMENT:
To maximize time for live public comment, we encourage members of the public to provide comments by joining the City Council meeting via Zoom : For web, visit https://belmont-gov.zoom.us/ select “Join” and enter Meeting ID: 95745673035. Use the Raise Hand feature to request to speak. You may rename your profile if you wish to remain anonymous.
For dial- in comments, call *67 1-(669) 900-6833 (your phone number will appear on the live broadcast if *67 is not dialed prior to the phone number), enter Meeting ID: 95745673035, and press *9 to request to speak. All public comments are subject to a 3-minute time limit unless otherwise determined by the Mayor.
If you wish to submit written public comment, you may send an email to [email protected] before the council considers the item. Please indicate the agenda item topic or agenda item number you wish to comment on in your email’s subject line. Any public comment regarding agenda items that are received from the publication of the agenda through the meeting date will be made part of the meeting record, but will not be read during the Council meeting.
Persons wishing to orally address the Council on the items of business listed below will be given an opportunity to do so before or during the Councils consideration of the item.
Recommendation: Discussion and Direction for Acquisition of Automated License Plate 1 4. ADJOURNMENT
Readers (ALPRs)
Attachment(s):
Staff Report
Policy
If you need assistance to participate in this meeting, please contact the City Clerk at (650) 595-7413.
Notification in advance of the meeting will enable the City to make reasonable arrangements to ensure accessibility to this meeting. Meeting information can also be accessed via the internet at: www.belmont.gov.
All staf reports will be posted to the web in advance of the meeting, and any writings or documents provided to a majority of the City Council/District Board or Commission regarding any item on this agenda will be made available for public inspection in the City Clerk's Of ice, One Twin Pines Lane, during normal business hours and at the Council Chambers at City Hall, Second Floor, during the meeting. 2
Automated License Plate Readers (ALPR) Staff Report
STAFF REPORT
Meeting Date: June 27, 2023
Agency: City of Belmont
Staff Contact: Ken Stenquist, Police Department (650) 595-7404, [email protected] Agenda Title: Automated License Plate Readers (ALPRs)
Agenda Action: Discussion & Direction
Recommendation
Discussion and Direction for Acquisition of Automated License Plate Readers (ALPRs).
Strategic Focus Area
Public Safety
Background
The use of Automated License Plate Readers (ALPR) by the Police Department was first presented on and discussed at the Council’s July 11th, 2022, Public Safety Committee meeting. The Police Department then conducted a second presentation at the Council’s April 3rd, 2023, Public Safety Committee meeting, where it was agreed upon to move the topic to the full council for discussion and direction..
ALPR systems consist of cameras directed towards lanes of traffic which are equipped with software to manage the data. The system is designed to take a photograph of a license plate to compare each plate against a database of stolen and/or wanted vehicles. The information is uploaded through to a secured cloud-based storage system. Additionally, the system stores the photo of the license plate along with date, time and location data for retrieval during criminal investigations for a limited amount of time.
California Penal Code Section 832.19 bans facial recognition and biometric surveillance technology within the state. The software used by ALPR technology is specifically designed to not collect any facial recognition data.
The data collected from ALPR systems would be owned by the City of Belmont and managed by the Belmont Police Department therefore will not be disseminated to federal agents as required by the California Values Act (California Government Code Sections 7284 et seq).
Analysis
The current policing reality is that the overall numbers of officers on the street is on the decline. ALPR technology can greatly assist law enforcement, while helping to mitigate the lack of presence of officers on the street. The use of ALPR cameras helps community, businesses, and law enforcement work together to eliminate crime, protect privacy and mitigate bias. In addition to allowing law enforcement to quickly identify the suspects of a crime, the use of ALPR has enabled local law enforcement to deter crime and recover property quickly.
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Automated License Plate Readers (ALPR) Staff Report
Use of ALPR technology in other San Mateo County cities stimulated robust and health community conversation that has helped shape local policies that incorporate best practices promoted by civil rights advocates. In the fifteen cities within San Mateo County that have adopted these polices and implemented ALPR, the systems have been of great benefit and well received by the public. The following cities are using the technology with great success: Atherton, Brisbane, Burlingame, Colma, Foster City, Hillsborough, Menlo Park, Millbrae, Redwood City, San Bruno, San Carlos, San Mateo, South San Francisco, Woodside and Portola Valley.
While each city and law enforcement agency in San Mateo County has notable success stories, the following are examples of how other agency’s ALPR technology has helped the City of Belmont:
November 2021 – Residential Burglary - Cipriani neighborhood. A residential burglary occurred and surveillance video from the area provided a vehicle description. Detectives coordinated with other agencies and determined the same suspect vehicle was likely used in several burglaries in the jurisdiction of the San Mateo County Sheriff’s Office. The Sheriff’s Office located ALPR captures of the suspect vehicle near several of their burglaries which led to the identification of the vehicle and suspect.
May 2022 – Robbery / Shooting – Valerga Drive. This shooting occurred between two armed men on Valerga Avenue (Next to Carlmont High School) while school was in session. Belmont Investigators learned that the involved suspect vehicle had unique features and a subsequent search of San Mateo PD ALPR data identified the vehicle and put it near the city limits 15 minutes prior to the shooting. The ALPR data, in combination with great detective work identified the involved parties soon thereafter. A local ALPR system would have provided additional evidence more closely linking the suspects and vehicle to the crime scene much earlier in the investigation.
August 2022 – Assault w/ Deadly Weapon - Ralston and US Hwy 101. Officers responded to the overpass on a victim who had been shot multiple times. At the time of the incident, there were no witnesses or evidence located at the scene. During the course of the investigation, it was determined that the associated vehicle to this crime was observed on multiple ALPRs in the City of San Mateo.
This information was not obtained until nine days after the officers were originally dispatched to the call. An ALPR in the City would have reduced that time to within minutes of the original call for service.
In the following examples the Belmont Police Department was unable to identify involved suspect(s) and the use of this technology would have been useful to prevent or solve these crimes. These calls for service illustrate how ALPR technology would have helped investigations if it were available to the City.
July 2020 – Robbery / Shooting - Island Parkway. A confrontation between two parties, both associated with separate vehicles, occurred near the Belmont Sports Complex. Grainy video and witness accounts provided vehicle descriptions, but lacked the information needed to identify any of the involved vehicles or parties. An ALPR system would have been extremely useful in this case to identify the involved vehicles that fled. This case remains unsolved and is the only unsolved shooting in recent Belmont history. 4
Automated License Plate Readers (ALPR) Staff Report
June 2022 – Armed robbery/burglary vehicle. A stolen vehicle known to have been involved in numerous violent felonies in the previous days entered Belmont and committed a series of crimes before one was witnessed and reported to police. ALPR system as proposed would have detected the vehicle and alerted officers prior to the commission of any crimes and allowed patrol to start safe intervention measures.
The benefit of having ALPR technology to protect the public is both needed and believed to be a community desire based on the request for more enforcement within the City of Belmont. A strong policy for usage, coupled with the privacy and governmental controls that ensure the proper use of the technology will help reduce community concern and gain acceptance. To ensure the community’s privacy rights, while providing the highest level of safety to the residents, staff proposes that use of ALPR technology in Belmont be subject to the following:
• ALPR data may not be sold and only shared with local law enforcement partners for use in criminal investigations.
• ALPR data is retained for 30 days then automatically deleted to ensure that all data not associated with a crime is deleted and unrecoverable.
• The data will be encrypted to ensure unauthorized parties do not gain access. • User must provide a search reason for audit trail purposes. • Data may not be used for predictive policing.
• Data may not be used for facial recognition purposes. • Personally Identifiable Information (PII) may not be contained in ALPR System. • May not be used for traffic enforcement.
• ALRP plate information will only be used to search registration and owner database information as part of a criminal investigation.
• Transparency portal on department webpage with policy and data usage information Alternatives
1. Return for further discussion.
2. Take no action.
Attachments
A. Belmont Police Department Policy 469 – Automated License Plate Readers (ALPRs) Fiscal Impact
☒ No Fiscal Impact
☐ Funding Source Confirmed:
Source: Purpose: Public Outreach:
Staff Discretionary Action Posting of Agenda
5 Policy
469
Belmont Police Department
Belmont PD Policy Manual
Copyright Lexipol, LLC 2023/06/20, All Rights Reserved.
Published with permission by Belmont Police Department ***DRAFT*** Automated License Plate Readers (ALPRs) - 1 Automated License Plate Readers (ALPRs)
Effective Date: 07/01/2023
Revised Date:
Issuing Authority:
Chief Stenquist
469.1 PURPOSE AND SCOPE
The purpose of this policy is to provide guidance for the capture, storage and use of digital data obtained through the use of Automated License Plate Reader (ALPR) technology. 469.2 DEFINITIONS
(a) Automated License Plate Reader (ALPR): A device that uses cameras and computer technology to compare digital images to lists of known information of interest. (b) ALPR Operator: Trained Department members who may utilize ALPR system/ equipment. ALPR operators may be assigned to any position within the Department and the ALPR Administrator may order the deployment of the ALPR systems for use in various efforts.
(c) ALPR Administrator: The Chief's designee, serves as the ALPR Administrator for the Department.
(d) Hot List: A list of license plates associated with vehicles of interest compiled from one or more databases including, but not limited to, NCIC, CA DMV, Local BOLs, etc. (e) Vehicles of Interest: Includes, but is not limited to, vehicles which are reported as stolen; display stolen license plates or tags; vehicles linked to missing and/or wanted persons and vehicles flagged by the Department of Motor Vehicle Administration or law enforcement agencies.
(f) Detection: Data obtained by an ALPR of an image (such as a license plate) within public view that was read by the device, including potential images (such as the plate and description of vehicle on which it was displayed), and information regarding the location of the ALPR system at the time of the ALPR read. (g) Hit: Alert from the ALPR system that a scanned license plate number may be in the National Crime Information Center (NCIC) or other law enforcement database for a specific reason including, but not limited to, being related to a stolen car, wanted person, missing person, domestic violence protective order or terrorist-related activity. 469.3 POLICY
The policy of the Belmont Police Department is to utilize ALPR technology to capture and store digital license plate data and images while recognizing the established privacy rights of the public 6 Belmont Police Department
Belmont PD Policy Manual
Automated License Plate Readers (ALPRs)
Copyright Lexipol, LLC 2023/06/20, All Rights Reserved.
Published with permission by Belmont Police Department ***DRAFT*** Automated License Plate Readers (ALPRs) - 2 All data and images gathered by the ALPR are for the official use of this department. Because such data may contain confidential information, it is not open to public review.
The Belmont Police Department does not permit the sharing of ALPR data gathered by the City or its contractors/subcontractors for purpose of federal immigration enforcement, pursuant to the California Values Act (Government Code § 7282.5; Government Code § 7284.2 et seq) – these federal immigration agencies include Immigrations and Customs Enforcement (ICE) and Customs and Border Patrol (CPB).
469.4 ADMINISTRATION
The ALPR technology, also known as License Plate Recognition (LPR), allows for the automated detection of license plates along with the vehicle make, model, color and unique identifiers through the Belmont Police Department's ALPR system and the vendor's vehicle identification technology.
The technology is used by the Belmont Police Department to convert data associated with vehicle license plates and vehicle descriptions for official law enforcement purposes, including identifying stolen or wanted vehicles, stolen license plates and missing persons. It may also be used to gather information related to active warrants, suspect interdiction and stolen property recovery.
All installation and maintenance of ALPR equipment, as well as ALPR data retention and access, shall be managed by the Professional Services Division Commander. The Professional Services Division Commander will assign members under his/her command to administer the day-to-day operation of the ALPR equipment and data.
469.4.1 ALPR ADMINISTRATOR
The Professional Services Division Commander shall be responsible for developing guidelines and procedures to comply with the requirements of Civil Code § 1798.90.5 et seq. This includes, but is not limited to (Civil Code § 1798.90.51; Civil Code § 1798.90.53):
(a) Only properly trained sworn officers, crime analysts, communication operators, records clerks and police assistants are allowed access to the ALPR system or to collect ALPR information.
(b) Ensuring training requirements are completed for authorized users. (c) ALPR system monitoring to ensure the security of the information and compliance with applicable privacy laws.
(d) Ensuring that procedures are followed for system operators and to maintain records of access in compliance with Civil Code § 1798.90.52.
(e) The title and name of the current designee in overseeing the ALPR operation is maintained.
(f) Continually working with the Custodian of Records on the retention and destruction of ALPR data.
(g) Ensuring this policy and related procedures are conspicuously posted on the department's website.
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Belmont PD Policy Manual
Automated License Plate Readers (ALPRs)
Copyright Lexipol, LLC 2023/06/20, All Rights Reserved.
Published with permission by Belmont Police Department ***DRAFT*** Automated License Plate Readers (ALPRs) - 3 469.5 OPERATIONS
Use of an ALPR is restricted to the purposes outlined below. Department members shall not use, or allow others to use the equipment or database records for any unauthorized purpose (Civil Code § 1798.90.51; Civil Code § 1798.90.53).
(a) An ALPR shall only be used for official law enforcement business. (b) An ALPR may be used in conjunction with any routine patrol operation or criminal investigation. Reasonable suspicion or probable cause is not required before using an ALPR.
(c) Partial license plates and unique vehicle descriptions reported during major or serial crimes should be entered into the ALPR system in an attempt to identify suspect vehicles.
(d) No member of this department shall operate ALPR equipment or access ALPR data without first completing department-approved training.
(e) No ALPR operator may access department, state or federal data unless otherwise authorized to do so.
(f) Every officer should verify an ALPR response through the California Law Enforcement Telecommunications System (CLETS) before taking enforcement action that is based solely on an ALPR alert. Once an alert is received, the operator shall confirm the observed license plate from the system matches the license plate of the observed vehicle. Before any law enforcement action is taken because of an ALPR alert, the alert will be verified through a CLETS inquiry via MDC or through dispatch. Members will not take any police action which restricts the freedom of any individual based solely on an ALPR alert unless it has been validated. Because the ALPR alert may relate to a vehicle and may not relate to the person operating the vehicle, officers are reminded they need to have reasonable suspicion and/or probable cause to make an enforcement stop of any vehicle. (For example, if a vehicle is entered into the system because of its association with a wanted individual, Officers should attempt to visually match the driver to the description of the wanted subject prior to making the stop or should have another legal basis for making the stop.)
(g) Hot Lists. Designation of hot lists to be utilized by the ALPR system shall be made by the ALPR Administrator or his/her designee. Hot lists shall be obtained or compiled from sources as may be consistent with the purposes of the ALPR system set forth in this policy. Hot lists utilized by the Department's ALPR system may be updated by agency sources more frequently than the Department may be uploading them and thus the Department's ALPR system will not have access to real time data. Occasionally, there may be errors in the ALPR system's read of a license plate. Therefore, an alert alone shall not be a basis for police action (other than following the vehicle of interest). Prior to initiation of a stop of a vehicle or other intervention based on an alert, Department members shall undertake the following:
1. Verification of status on a Hot List. An officer must receive confirmation, from a Belmont Police Department or allied agency communications Dispatcher or 8 Belmont Police Department
Belmont PD Policy Manual
Automated License Plate Readers (ALPRs)
Copyright Lexipol, LLC 2023/06/20, All Rights Reserved.
Published with permission by Belmont Police Department ***DRAFT*** Automated License Plate Readers (ALPRs) - 4 other department computer device, that the license plate is still stolen, wanted, or otherwise of interest before proceeding (absent exigent circumstances).
2. Visual verification of license plate number. Officers shall visually verify that the license plate of interest matches identically with the image of the license plate number
captured (read) by the ALPR, including both the alphanumeric characters of the license plate, state of issue, and/or vehicle descriptors before proceeding.
Department members alerted to the fact that an observed motor vehicle license plate is entered as a Hot Plate (hit) in a specific BOL (be on the lookout) list are required to make a reasonable effort to confirm a wanted person is actually in the vehicle and/or that a reasonable basis exists before a Department member would have a lawful basis to stop the vehicle.
3. Department members will clear all stops from hot list alerts by indicating the positive ALPR Hit, i.e., with an arrest or other enforcement action. If it is not obvious in the text of the call as to the correlation of the ALPR Hit and the arrest, then the Department member shall update the dispatcher and original person and/or a crime analyst inputting the vehicle in the hot list (hit).
4. General Hot Lists (SVS, WPS, NCIC) will be automatically downloaded into the ALPR system a minimum of once a day with the most current data overwriting the old data.
5. All entries and updates of specific Hot Lists within the ALPR system will be documented by the requesting Department member within the appropriate case report. As such, specific Hot Lists shall be approved by the ALPR.
Administrator (or his/her designee) before initial entry within the ALPR system.
The updating of such a list within the ALPR system shall thereafter be accomplished pursuant to the approval of the Department member's immediate supervisor. The hits from these data sources should be viewed as informational; created solely to bring the officer's attention to specific vehicles that have been associated with criminal activity. All Hot Plates and suspect information entered into the ALPR system will contain the following information as a minimum (a) Entering Department member's name
(b) Related report number.
(c) Short synopsis describing the nature of the originating call (h) Training. No member of this Department shall operate ALPR equipment or access ALPR data without first completing Department-approved training. (i) Login/Log-Out Procedure. To ensure proper operation and facilitate oversight of the ALPR system, all users will be required to have individual credentials for access and use of the systems and/or data, which has the ability to be fully audited. (j) Permitted/Impermissible Uses. The ALPR system, and all data collected, is the property of the Belmont Police Department. Department personnel may only access and use the ALPR system for official and legitimate law enforcement purposes consistent with this Policy. The following uses of the ALPR system are specifically prohibited:
9 Belmont Police Department
Belmont PD Policy Manual
Automated License Plate Readers (ALPRs)
Copyright Lexipol, LLC 2023/06/20, All Rights Reserved.
Published with permission by Belmont Police Department ***DRAFT*** Automated License Plate Readers (ALPRs) - 5
1. Invasion of Privacy: Except when done pursuant to a court order, such as a search warrant, it is a violation of this Policy to utilize the ALPR to record license plates except those of vehicles that are exposed to public view (e.g., vehicles on a public road or street, or that are on private property, but whose license plate(s) are visible from a public
road, street, or a place to which members of the public have access, such as the parking lot of a shop or other business establishment).
2. Harassment or Intimidation: It is a violation of this policy to use the ALPR system to harass and/or intimidate any individual or group.
3. Use Based on a Protected Characteristic. It is a violation of this policy to use the ALPR system or associated scan files or hot lists solely because of a person's, or group's race, gender, religion, political affiliation, nationality, ethnicity, sexual orientation, disability, or other classification protected by law.
4. Personal Use: It is a violation of this Policy to use the ALPR system or associated scan files or hot lists for any personal purpose.
5. First Amendment Rights. It is a violation of this policy to use the ALPR system or associated scan files or hot lists for the purpose or known effect of infringing upon First Amendment rights. Anyone who engages in an impermissible use of the ALPR system or associated scan files or hot lists may be subject to:
(a) Criminal prosecution,
(b) Civil liability, and/or
(c) Administrative sanctions, up to and including termination, pursuant to and consistent with the relevant collective bargaining agreements and Department policies.
469.6 DATA COLLECTION AND RETENTION
The Professional Services Division Commander is responsible for ensuring systems and processes are in place for the proper collection and retention of ALPR data. Data will be transferred from vehicles to the designated storage in accordance with department procedures.
All ALPR data uploaded to the server should be stored for no longer than one year (Government Code § 34090.6) and in accordance with the established records retention schedule. Thereafter, ALPR data should be purged unless it has become, or it is reasonable to believe it will become, evidence in a criminal or civil action or is subject to a discovery request or other lawful action to produce records. In those circumstances the applicable data should be categorized for a longer retention period consistent with the records retention schedule or moved to a separate media storage system and booked into evidence.
The ALPR vendorwill store the data (data hosting) and ensure proper maintenance and security of data stored in their data facilities. The ALPR vendor will purge their data at the end of the 30 days of storage. However, this will not preclude BPD from maintaining any relevant vehicle data obtained from the system after that period pursuant to the established City of Belmont retention 10 Belmont Police Department
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Automated License Plate Readers (ALPRs)
Copyright Lexipol, LLC 2023/06/20, All Rights Reserved.
Published with permission by Belmont Police Department ***DRAFT*** Automated License Plate Readers (ALPRs) - 6 schedule mentioned above or outlined elsewhere. Relevant vehicle data are scans corresponding to the vehicle of interest on a hot list or involved in a department investigation.
Restrictions on use of ALPR Data: Information gathered or collected, and records retained by the ALPR vendor cameras or any other BPD ALPR system will not be sold, accessed, or used for any purpose other than legitimate law enforcement or public safety purposes. 469.7 ACCOUNTABILITY AND SAFEGUARDS
All data will be closely safeguarded and protected by both procedural and technological means.
The Belmont Police Department will observe the following safeguards regarding access to and use of stored data (Civil Code § 1798.90.51; Civil Code § 1798.90.53):
(a) All ALPR data downloaded to a mobile workstation and in storage shall be accessible only through a login/password-protected system capable of documenting all access of information by name, date and time (Civil Code § 1798.90.52). (b) Members approved to access ALPR data under these guidelines are permitted to access the data for legitimate law enforcement purposes only, such as when the data relates to a specific criminal investigation or department-related civil or administrative action.
(c) Such ALPR data may be released to other authorized and verified law enforcement officials and agencies for legitimate law enforcement purposes. (d) All non-law enforcement requests for access to stored ALPR data shall be processed in accordance with applicable law.
(e) Every ALPR detection browsing Inquiry must be documented by either the associated Belmont Police Department case number or incident number and/or a reason for the inquiry.
For security or data breaches, see the Records Release and Maintenance Policy. 469.8 ALPR DATA DETECTION AUDITS
It is the responsibility of the Professional Services or the Chief's designee to ensure an audit is conducted of ALPR detection browsing inquiries at least once during each calendar year. The Department will audit a sampling of the ALPR system utilization from the prior 12-month period to verify proper use in accordance with the above- authorized uses. The audit shall randomly select at least 10 detection browsing inquiries conducted by department employees during the preceding six-month period and determine if each inquiry meets the requirements established in this policy.
The audit shall be documented in the form of an internal department memorandum to the Chief of Police. The memorandum shall include any data errors found so any such errors can be corrected.
After review by the Chief of Police, the memorandum and any associated documentation shall be filed and retained.
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Belmont PD Policy Manual
Automated License Plate Readers (ALPRs)
Copyright Lexipol, LLC 2023/06/20, All Rights Reserved.
Published with permission by Belmont Police Department ***DRAFT*** Automated License Plate Readers (ALPRs) - 7 469.9 RELEASING ALPR DATA
The ALPR data may be shared only with other law enforcement or prosecutorial agencies for official law enforcement purposes or as otherwise permitted by law, using the following procedures:
(a) The agency makes a written request for the ALPR data that includes:
(a) The name of the agency.
(b) The name of the person requesting.
(c) The intended purpose of obtaining the information.
(b) The request is reviewed by the Professional Services Division Commander or the authorized designee and approved before the request is fulfilled. (c) The Chief of Police or the authorized designee will consider the California Values Act (Government Code § 7282.5; Government Code § 7284.2 et seq), before approving the release of ALPR data. The Belmont Police Department does not permit the sharing of ALPR data gathered by the City or its contractors/subcontractors for purpose of federal immigration enforcement, these federal immigration agencies include Immigrations and Customs Enforcement (ICE) and Customs and Border Patrol (CPB).
(d) The approved request is retained on file.
The ALPR data may be shared with other law enforcement agencies, for legitimate law enforcement purposes or as otherwise permitted by law, when a data sharing agreement exists between the law enforcement agency and the Belmont Police Department. Any data sharing agreements shall be signed by the Chief of Police and should be periodically reviewed to ensure the agreement is meeting the needs of the respective agencies and the intent of the agreement.
Requests for ALPR data by non-law enforcement or non-prosecutorial agencies will be processed as provided in the Records Maintenance and Release Policy (Civil Code § 1798.90.55). 469.10 TRAINING
The Training Manager should ensure members receive department-approved training for those authorized to use or access the ALPR system (Civil Code § 1798.90.51; Civil Code § 1798.90.53). 12