Safeguards Summary – Flock ALPR
❖ The Oakland Police Department (OPD) did not participate in Nationwide Lookup which led to vulnerabilities in other agencies.
❖ Flock has de-activated the ability for any California (state and local) agency to participate in Nationwide Lookup to ensure compliance with state laws. ❖ Flock enacted rules wherebyFederal agencies and out of state agencies are unable to request to access to any California state agency, including OPD.
❖ OPD continues to have protocols in place where individual agencies are verified to be local or state agencies, in compliance with SB 34.
❖ All state and local agencies are required to be in compliance with SB 34 and SB 54. https://oag.ca.gov/news/press-releases/attorney-general-bonta-advises-california-law- enforcement-legal-uses-and
❖ OPD does not integrate Record Management System (RMS) data through the Flock Operating System, meaning that Personal Identifying Information is not accessible through Flock OS. OPD will not integrate RMS data into Flock OS.
❖ Protection of ALPR data is solidified in state law. In October of 2025, California’s Attorney General filed a lawsuit against the City of El Cajon for a refusal to follow state law.1 This demonstrates that the state is willing to commit resources to ensure the proper use of ALPR technology within California.
Contract Safeguards
❖ Data collected is the property of the City of Oakland and shall not be shared with any other entity without the consent of the City. Any violation of this clause would represent a breach of contract, allowing the Department/City to terminate the contract. ❖ As part of the proposed contract, Flock has agreed not to collect anonymized aggregated data for the purpose of machine learning.
Language within OPD’s proposed contract allows for a termination of the contract for the following:
❖ Federal Assumption. (In the event that the City is assumed, merged into, or otherwise placed under the direct control or administration of the United States Federal Government (a “Federal Assumption”), and as a result is no longer able to operate as an independent agency, performance of all Services under this Agreement shall be immediately suspended and qualify as a termination for cause.)
❖ Contract with a Federal Agency that invalidates or compromises the City’s sole ownership of City Data.
1 Attorney General Bonta Sues El Cajon for Illegally Sharing License Plate Data with Out-of-State Law Enforcement | State of California - Department of Justice - Office of the Attorney General