Fullerton Police Department
Fullerton City Council – October 6, 2026
Flock ALPR Program
Fullerton’s Flock ALPR Program
17 + 2
CAMERAS
17 fixed cameras plus 2 mobile cameras in our current deployment. ~$236,000 across equipment, subscriptions, repairs, and maintenance. 5 yrs
OPERATING HISTORY
We installed our first Flock cameras in January 2021.
30 days
RETENTION WINDOW
Our data is automatically and permanently deleted after 30 days unless preserved as evidence.
PROGRAM TIMELINE
2007 City Council approval of grant-funded ALPR (UASI) 2019 Vigilant Solutions deployment in Parking Enforcement vehicles as part of the Downtown Paid Parking Program 2021 Flock LPR added under Chief Dunn within purchasing policy guidelines Now Flock and Vigilant both utilized by FPD
There are 135 active FPD users
Fullerton PD’s ALPR Program Predated SB 34
2007
ALPR program established
November 20, 2007 City Council approved a grant-funded ALPR system through UASI.
Fullerton PD began operating ALPR before SB 34 took effect.
JAN 1, 2016
SB 34 effective
Fullerton PD’s ALPR program was already in place.
SB 34’s public-comment language applies before implementing an ALPR program; it does not expressly address retroactive re-approval of a pre-2016 program. 2021
Flock added as technology provider
Fullerton PD added Flock ALPR
The department continued its existing ALPR program and public-safety purpose.
The 2021 action was a vendor addition, not implementation of a new ALPR program.
FULLERTON PD’S POSITION
Because our ALPR program was already operating before SB 34 became effective, our 2021 addition of Flock ALPR did not constitute implementation of a new ALPR program.
SB 34 does not expressly require a second public-comment meeting solely because an existing ALPR program changes or adds vendors.
The California DOJ guidance does not create a vendor-change trigger; it explains that SB 34 does not address pre-2016 programs.
WHAT STILL APPLIES TODAY
Maintain a written, publicly available ALPR usage-and-privacy policy.
Maintain reasonable security procedures and access records.
Govern authorized purposes, users and training, audits, sharing, accuracy, retention, and deletion.
Bottom line: Fullerton PD had ALPR before SB 34. In 2021, we changed technology providers—we did not launch a new ALPR program.
In 2021, Fullerton PD added a technology vendor to an ALPR program that was already operating—not a new ALPR program.
Fullerton PD’s ALPR Policy
Key Points
ALPR shall only be used for official law enforcement purposes, in conjunction with any routine patrol operation or criminal investigation.
ALPR data may be shared only with a California state or local agency as otherwise permitted by law (Civil Code 1798.90.55); out-of-state or federal agencies are prohibited.
A related case number and reason must be entered prior to using the ALPR search function.
All authorized users shall complete ALPR training prior to having access to the system.
ALPR audits will be conducted quarterly by the Crimes Property Sergeant and reviewed by the Support Services Commander. 30-day retention period for all ALPR data; system access information shall be retained indefinitely.
Fullerton PD Policy 428: Automated License Plate Readers (ALPRs) 428.2 POLICY: The policy of the Fullerton 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. All data and images gathered by the ALPR for the official use of this department. Because such data may contain confidential information, it is not open to public review.
FPD Policy 428 is publicly available to view here (Fullerton PD CA Policy Manual): https://www.cityoffullerton.com/government/departments/police/about-fpd/policies-procedures
Fullerton PD’s ALPR Policy
Fullerton PD’s ALPR Policy
Fullerton PD’s ALPR Policy
Required ALPR Training
Prior to access authorization, officers must complete a department-led training on the use of the system and policy.
At any time, officers can complete additional training through the Flock Academy website. An example of one such training is “Law Enforcement- Search Certification.” Training
Required Disclaimer
Every time an authorized user logs into Flock they are required to accept the disclaimer that their use is within the FBI CJIS Security Policy and that unauthorized or improper use may lead to disciplinary action and/or criminal and/or civil penalties.
Legal Precedent for ALPR
Court Cases
United States v. Diaz-Castaneda, 494 F.3d 1146 (9th Cir. 2007): The Ninth Circuit held that officers’ computerized check of a license plate did not constitute a Fourth Amendment search. The court reasoned that the plate was displayed publicly and that the computerized inquiry was not sufficiently intrusive to implicate a reasonable expectation of privacy.
An ALPR system can automate what an officer could otherwise do manually: observe plate → run plate → determine whether vehicle is wanted/stolen.
United States v. Yang, 958 F.3d 851 (9th Cir. 2020): The Ninth Circuit has declined to hold that warrantless ALPR use categorically violates the Fourth Amendment and has upheld an ALPR-related search under the particular circumstances presented.
ALPR does not equate automatically unconstitutional warrantless tracking.
ACLU Foundation of Southern California v. Superior Court, 11 Cal.App.5th 295 (2015): Concluded that CRPA law-enforcement exemption applies to ALPR data since ALPR is an established law-enforcement investigative technology.
A single ALPR observation of a vehicle in public right of ways is materially different from prolonged, comprehensive tracking. (United States v. Jones, 565 U.S. 400 (2012) Fourth Amendment
How is Flock’s Data Processed?
Detect
The camera captures a license plate and vehicle characteristics in public view. →
→
→
Transmit
The camera transmits the captured data over its network connection using TLS 1.2+ encryption.
Store
Data stored encrypted in Flock’s cloud infrastructure hosted on Amazon Web Services (AWS).
Database
Flock’s cloud/ machine-learning systems process the imagery and generate searchable vehicle data.
Data is automatically deleted according to the customer’s retention period.
Flock uses proprietary machine-learning technology to identify:
license plate information, vehicle type, vehicle characteristics, other attributes such as roof racks & bumper stickers
Flock ALPR- Data Security, Storage & Recovery Standards Overview
Fullerton IT has determined that Flock security protocols incorporate industry-recognized security standards, government compliance frameworks, independent third-party assessments, strong access controls, encryption, audit logging, and geographically redundant backup and recovery capabilities.
Flock ALPR- Data Security, Storage & Recovery Standards Data Storage & Segregation- CJIS-capable GovCloud Infrastructure US-based AWS infrastructure; AWS GovCloud for applicable CJIS workloads.
Public, multi-tenant GovCloud environment; City/customer data is logically segregated.
Segregation uses dedicated storage, access controls, network segmentation and encryption safeguards.
Data, backups and disaster-recovery environments remain in the US.
Access Controls
Role-based access controls (RBAC) determine camera/network and user privileges.
Least privilege: users receive no permissions until assigned by an administrator.
Multi-factor authentication is enforced on all law-enforcement accounts.
California agency safeguards include automatic disabling of certain national discoverability and filtering controls.
Flock ALPR- Data Security, Storage & Recovery Standards Backup & Disaster Recovery
Resources operate across multiple geographically separated AWS availability zones.
Data replicated across availability zones; separate AWS sites maintain backup copies.
Automated database backups run daily; restoration/redundancy mechanisms tested annually.
Encrypted backups are segregated from production.
Audit & Monitoring
Organization Audit Log: organization-level actions.
Network Audit Log: camera-network activity and shared access.
Event Log: logins, downloads, queries and administrative changes.
SOC 2 Type II: maintained
ISO 27001: certified
Independent penetration testing conducted by Bishop Fox in 2026.
Penetration-test vulnerability/remediation reports and executive summary are available through Flock’s security resources.
The Flock ALPR Program in Fullerton Produces Vehicle Leads, Not Personal Profiles
WHAT IT DOES
Captures still photos of license plates and vehicle attributes visible from public roads.
Compares plates with authorized hotlists to generate investigative leads.
Capture video.
Use facial recognition, biometrics, names, DOBs, SSNs, addresses, or DMV identity data.
Continuously track people, issue traffic citations, or predict who will commit a crime.
Immigration enforcement, traffic enforcement, harassment or intimidation, usage based solely on a protected class, and personal use are expressly prohibited.
WHAT IT DOES NOT DO
What Our Officers See
What Our Officers See
Fullerton CCTV Security Cameras vs ALPR
CCTV
FPD’s Flock Cameras only capture still photos.
Detects license plates and compares against “hot lists.” Immediate notification to officers when a plate matches a wanted vehicle.
Data used to locate vehicles associated with crimes.
30-day data retention.
19 Cameras
FLOCK ALPR
Captures video in public right of ways.
2-year data retention.
432 total cameras:
413 police
19 traffic
CCTV Cameras Recording View
Not specific to license plate and vehicle characteristics
ALPR Programs
Flock
CAMERAS
Fixed & mobile camera options
ALPR data processing/analytics occurs in Flock’s AWS cloud environment.
Flock network allows customer-to-customer sharing subject to permissions, within CA for FPD.
ALPR, Security Camera products, Drone as First Responder program, gunshot detection. $51,000/year for 19 cameras
Axon
Vigilant
There are 135 active FPD users
Fixed & mobile camera options
Camera performs plate reading/alerting locally and uploads records to Axon Evidence.com cloud.
Axon can integrate multiple ALPR sources through Fusus; working on data sharing among CA agencies.
Offers ALPR, body worn cameras, tasers, evidence, records, Fusus, Drone as First Responder program. $51,278.50/year for 19 cameras
Fixed & mobile camera options
Detection data is transmitted to Vigilant/Motorola hosted infrastructure.
Vigilant operates a large multi-source detection data network (all customers’ camera data available to search).
Law enforcement ALPR and commercial ALPR.
DATA
NETWORK
ALL PRODUCTS
CAMERAS
CAMERAS
DATA
DATA
NETWORK
NETWORK
ALL PRODUCTS
ALL PRODUCTS
PRICING
PRICING
Questions?