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CITY OF GLENDALE, CALIFORNIA
REPORT TO THE CITY COUNCIL
AGENDA ITEM
Report: Update on Flock Safety Automated License Plate Recognition System
1. Motion to note and file.
2. Motion to direct staff.
COUNCIL ACTION
Item Type: Action
Approved for September 22, 2026 calendar
EXECUTIVE SUMMARY
The Glendale Police Department (GPD) utilizes Flock Safety automated license plate recognition (ALPR) cameras as an investigative tool to assist personnel in identifying vehicles associated with criminal activity, developing investigative leads, and supporting ongoing criminal investigations. Questions concerning the Flock Safety cameras have arisen in recent months, and the City Council has requested a report on the Department’s Flock camera system, including some specific questions concerning data security and policy.
The remainder of this report is intended to provide greater detail regarding the Glendale Police Department’s use of the Flock Safety Automated License Plate Recognition System.
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RECOMMENDATION
It is recommended that City Council note and file the report.
ANALYSIS
The Glendale Police Department (GPD) utilizes Flock Safety automated license plate recognition (ALPR) cameras as an investigative and crime-prevention tool. The cameras are motion activated and capture images of vehicles traveling through public areas, recording the license plate, date, time, location, and associated vehicle image. The system does not identify the occupants of a vehicle or determine who owns the vehicle.
The Department has utilized Flock since 2020, with the network expanding incrementally based on funding availability. GPD currently has 82 Flock ALPR cameras and is in the process of replacing 40 pan/tilt/zoom cameras that did not meet the Department’s expectations with additional Flock ALPR cameras. GPD's existing Flock camera network generates approximately 1.2 million unique license plate reads per month.
Camera locations are strategically selected based on traffic patterns, ingress and egress points within the City, crime trends, and other investigative considerations, with input from investigators and crime analysts. The information captured by the cameras is maintained in a database, allowing investigators to identify vehicles that may be associated with specific criminal activity being investigated.
Flock data has become a significant investigative resource for GPD. The system has assisted investigators in a wide range of cases, including homicides, armed robberies, carjackings, shootings, fraud, and other serious crimes. In some cases, Flock information has helped detect otherwise difficult-to-identify vehicles, connect crimes occurring in multiple jurisdictions, and locate suspects. Flock software also has the ability to notify GPD personnel when a flagged vehicle (either by our agency or another agency) is detected on a camera in Glendale. This has enabled our field personnel to apprehend suspects wanted by other California law enforcement agencies, and likewise has assisted others in apprehending suspects wanted in connection with crimes committed in, and investigated by, GPD.
GPD maintains control over access to its Flock data. Data that is accessed by Department personnel and approved partner agencies requires entry of a case number/reason for entry and the offense type associated with an official investigation, allowing the Department to identify who accessed the information, when it was accessed, and the reason for the access. GPD currently limits its data-sharing partners to approved California law enforcement agencies and maintains a public transparency portal identifying those partners. The Department currently retains Flock data for 30 days, after which the images are no longer available through the system.
The following sections provide additional information regarding data retention, data security, sharing, auditing, camera deployment, contractual protections, and accountability measures.
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The following addresses the questions posed by the Council:
1. What are the types of Investigations for Which Partner Agencies May Access Shared Data?
GPD does not impose an investigation-based limitation on the specific category of criminal investigation for which an approved law enforcement partner may use shared Flock data, except where such use is prohibited by law or Department policy.
GPD does not authorize the use of Flock data for purposes prohibited by California law, including prohibited uses relating to reproductive health care or immigration enforcement. All participating agencies have an obligation to comply with applicable state and federal law governing the use of ALPR information.
2. What is the Data Retention Period?
GPD currently maintains Flock ALPR data for a 30-day retention period. This retention period was determined to provide a reasonable yet effective balance between investigative value and monetary costs. Storing data for a period longer than 30 days is cost prohibitive and storing data for less than 30 days greatly reduces the value of the camera system in solving crime.
Upon expiration of the 30-day retention period, the data is no longer available to GPD personnel or any of its sharing partners through the Flock system.
3. What Does It Mean to Say the Data Is "Irrevocably Deleted," and How Do We Know It Has Been Deleted?
Flock has represented to GPD that data is irrevocably deleted following expiration of the applicable retention period. Once the 30-day retention period has elapsed, GPD personnel are unable to retrieve or access the expired images through the Flock system. Flock has provided GPD with a white-paper explaining the Amazon Web Services’ S3 Lifecycle Policy and deletion process. In brief, automated deletions occur after the predetermined retention period has lapsed, and a record of that deletion activity is maintained in Amazon Web Service’s CloudTrail – providing an auditable history for the data that was deleted as scheduled.
The Department has independently observed this limitation through its routine use of the system. Detectives and other authorized personnel cannot retrieve images that are beyond the 30-day retention period.
Additionally, GPD is not aware of any instance in which data that should have been purged under the applicable retention period was subsequently located or made available after the retention period passed.
4. What jurisdictions does GPD Share Flock Data With?
GPD currently shares Flock data only with California law enforcement agencies.
This practice is consistent with applicable California law (Senate Bill 34) governing the use and sharing of ALPR information, and specifically prohibiting the sharing of ALPR 10e4
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data with federal and out-of-state agencies. The Department has published a transparency portal identifying agencies with which it has approved data-sharing relationships. An agency appearing on GPD's transparency portal (accessible via the Police Department’s Website under Office of the Chief/Transparency) as a sharing partner is an agency that has requested access to share data with GPD and whose request has been approved by the Chief of Police or his designee.
Data sharing is therefore not an unrestricted or automatic feature available to any agency. Sharing relationships are established through the Department's approval process.
5. How Many Cameras are Deployed and Who Determines Their Locations? GPD currently has 82 Flock cameras deployed throughout the City and is in the process of installing an additional 40 cameras which will replace existing Pan/Tilt/Zoom cameras.
Camera locations are determined through an operational and investigative assessment.
The Special Investigations Bureau (SIB) Lieutenant is responsible for determining proposed camera locations, taking into consideration input from detectives, investigators, and crime analysts.
The process may consider factors such as:
Locations and patterns of reported criminal activity;
Investigative needs and known crime trends;
Traffic patterns and roadway characteristics;
Areas where ALPR technology may provide a significant investigative benefit; and
Input from personnel who have direct knowledge of ongoing criminal investigations and crime patterns.
Proposed deployments are subject to command staff approval.
6. Regular Data Audits, Responsibility for Audits, and Reporting of Results GPD currently conducts audits of Flock system activity every two weeks.
The audits are conducted by the Special Investigations Bureau Lieutenant and are intended to identify potential misuse or activity inconsistent with Department requirements. The Department utilizes Flock’s audit assistance tools as well, which can identify abnormalities in the system’s usage that may justify further analysis. To date, GPD has not identified any instances of misuse or misconduct through these audits.
The results of individual audits are maintained internally and are not published publicly.
This practice is consistent with the Department's treatment of internal audits involving other law enforcement databases and information systems. 10e5
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7. Are There Consequences for Policy Violations by GPD Personnel and Third- Party Agencies?
GPD personnel who are suspected of misusing the Flock system or ALPR data are subject to the Department's established internal affairs process, in the same manner as allegations involving the misuse of other official law enforcement databases, systems, or resources.
Depending upon the circumstances and findings of an investigation, confirmed misconduct may result in disciplinary action, up to and including termination of employment.
If the Department determines that alleged misuse may constitute criminal conduct, the matter may also be referred to the appropriate prosecutorial authority, including the Los Angeles County District Attorney's Office, Justice System Integrity Division, when appropriate.
Approved law enforcement sharing partners are likewise expected to comply with applicable laws and restrictions governing the use of Flock data. If GPD becomes aware that a sharing partner has misused Flock data, including misuse of GPD data or other data made available through the Flock network—the Department may terminate that agency's status as an approved sharing partner and revoke its access as a sharing partner.
8. Are There Contractual Protections and Restrictions on Flock's Use of Data? GPD is currently operating under existing contractual agreements with Flock. Those agreements establish provisions governing the collection, use, retention, access, security, and disclosure of information collected through the Flock system. Specifically, the contracts confirm that the data is owned by the Department. The only exception to this ownership and control of the data pertains to the anonymized collection of customer data, rendered to be non-identifiable, which may then be used by Flock for the training of machine learning algorithms, to improve and enhance the services for other development, diagnostic and corrective purposes, and for other Flock offerings.
Flock does not own and shall not sell the anonymized data as described above. Current contractual language provides the Department with the ability to cancel existing agreements with 30 days’ notice provided to Flock.
9. Data Security and Storage – Amazon Web Services (AWS) Flock utilizes Amazon Web Services (AWS) as its cloud infrastructure provider for the storage and processing of Flock data. AWS is one of the world's largest cloud service providers and is widely used by government agencies, as well as major corporations, to store and process sensitive information. AWS also maintains dedicated government cloud infrastructure designed to meet heightened security and compliance requirements.
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Flock’s customer data stored within its AWS environment is encrypted both in transit and at rest, and customer data is maintained within the United States. Flock also utilizes access controls and other security measures designed to restrict unauthorized access to customer information.
The Department recognizes that utilizing AWS does not, by itself, eliminate all security risks. Cloud security operates under a shared-responsibility model, with AWS responsible for the underlying infrastructure and Flock responsible for the security and configuration of its application, data, and access controls.
Overall, the use of AWS provides GPD with the security infrastructure of a major enterprise cloud provider that is utilized extensively by government agencies and organizations handling sensitive information.
Summary of Current Safeguards
GPD's current Flock program incorporates multiple layers of oversight and control, including:
1. 30-day data retention period;
2. Restricted access to authorized personnel and approved sharing partners;
3. Data sharing is limited to approved California law enforcement agencies;
4. Prohibition on uses that violate applicable California law;
5. Departmental approval of camera locations;
6. Audits of system activity every two weeks;
7. Internal affairs investigations for suspected employee misuse; Potential discipline up to and including termination for confirmed misconduct; Potential criminal referral when appropriate;
8. Revocation of data-sharing privileges for agencies that misuse shared Flock information.
9. Cancelation of Flock contract should they violate terms of the agreement or be found to have misused Glendale data.
These controls are intended to ensure that Flock ALPR technology remains an investigative resource used for legitimate law enforcement purposes while limiting unnecessary retention, access, and dissemination of the information collected by the system.
STAKEHOLDERS/OUTREACH
Not applicable.
FISCAL IMPACT
There is no fiscal impact associated with this report.
ENVIRONMENTAL REVIEW (CEQA/NEPA)
This item is considered a ministerial activity and therefore, not subjected to CEQA/NEPA review. There is no possibility that the acceptance of this award may have a significant 10e7
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effect on the environment. (14 Cal. Code Regs. § 15061(b)(3))
CAMPAIGN DISCLOSURE
This item is exempt from campaign disclosure requirements.
ALTERNATIVES TO STAFF RECOMMENDATION
None.
ADMINISTRATIVE ACTION
Submitted by:
Robert William, Police Chief
Prepared by:
Jason Ross, Police Captain
Approved by:
Roubik R. Golanian, P.E., City Manager
EXHIBITS/ATTACHMENTS
None