City Council
Staff Report
From: City Manager
Report Type: INFORMATION REPORTS
Lead Department: Police
Meeting Date: May 4, 2026
Report #:2604-6298
TITLE
Update on Flock Automated License Plate Recognition Technology
BACKGROUND AND ANALYSIS
Recognizing public interest in this topic, the Palo Alto Police Department (PAPD) will begin proactively posting on a monthly cadence partially redacted Flock search logs on the City’s Automated License Plate Recognition (ALPR) webpage1. These logs include information concerning ALPR queries performed by PAPD users, as well as queries performed by other agencies, that has not previously been released pursuant to a legal exemption. The first logs, covering July of 2023 (when the first Flock camera was installed in Palo Alto) thru March of 2026, were posted on April 21, 2026. Additionally, the City continues to use best practices to secure Palo Alto ALPR data, including a 30-day limit on data retention, requiring MOUs with other agencies for data sharing, and internal policy controls.
In 2023, unbeknownst to many users including PAPD, Flock added a new “Nationwide Lookup” search feature. Using this feature, an out-of-state local law enforcement or federal agency could perform a broad search of data from Flock’s entire nationwide network of over 6000 cameras, including the 20 cameras then-deployed in Palo Alto. The feature did not enable targeted searches of any specific agency’s data. These searches could only be performed system-wide when a full 7-digit license plate number was known and only based on the articulation of a legitimate law enforcement purpose.
PAPD was first made aware of this issue in December 2025 and subsequently learned that Flock had already disabled the feature for PAPD by late October 2024 and for all California law enforcement agencies by March 2025.
1 City of Palo Alto’s Automated License Plate Recognition (ALPR) webpage; https://www.paloalto.gov/Departments/Police/Public-Information-Portal/Automated-License-Plate-Recognition- ALPR
While its data was included in the “Nationwide Lookup” searchable dataset during this period, PAPD has worked with Flock to confirm that no PAPD data (i.e., license plates captured by Palo Alto cameras) was actually received by any out-of-state agency or federal agency as a result of any “Nationwide Lookup” search. In other words, PAPD had no records that matched the “Nationwide Lookup” searches performed by out of state or federal agencies.
Even though no PAPD data was shared, PAPD reviewed a sampling of the searches performed by out-of-state local law enforcement and federal agencies via the “Nationwide Lookup” feature. The searches we reviewed all appeared to be linked to legitimate law enforcement investigations (e.g., burglary, vehicle theft, assault).3 Additionally, PAPD found that no searches had been performed by ICE, Customs and Border Patrol, or the Department of Homeland Security; keyword searches did not identify any searches that appeared to be associated with immigration enforcement or reproductive rights enforcement.
In January 2026, the Department added initial information on this issue to this ALPR webpage and previously updated the information in February 2026.
PAPD has been in contact with Flock’s executive leadership to share the City’s concerns and, in response to PAPD’s suggestion, Flock has expressed a strong willingness to pursue third party verification that this issue has been resolved. While the City Auditor is unable to perform this task, work is underway to identify an alternate auditor. The goal of this review would be to conduct a technical as well as operational review to confirm that Flock’s practices address the City’s expectations for security, transparency, and reporting of system features and changes.
The Department is confident that its training, Surveillance Use Policy, 30-day data retention period, and requirement of an MOU for each agency with which it shares, meet or exceed industry standards. With that, as recommended by the City Council’s Policy & Services Committee, PAPD has discussed with the Independent Police Auditor a review of its internal policies and procedures with an eye toward areas where we may be able to do even better.
Staff anticipates reporting to Council in early June 2026 with further updates on this topic.
FISCAL/RESOURCE IMPACT
Flock is already contracted with the City and this update did not incur any additional expenses.
ENVIRONMENTAL REVIEW
The City’s contract with Flock is categorically exempt under CEQA regulation 15321 for enforcement actions.
APPROVED BY:
James Reifschneider, Police Chief
3 Search logs capture the search reason provided by the user at the time of the search.