City Council
Staff Report
From: City Manager
Report Type: STUDY SESSION
Lead Department: Police
Meeting Date: June 1, 2026
Report #:2605-6381
TITLE
Study Session on Flock Automated License Plate Recognition Technology; CEQA status – categorically exempt.
BACKGROUND
In April 2023, the City Council approved a three-year contract with Flock Safety (hereinafter “Flock”) for the deployment of twenty fixed automated license plate recognition (ALPR) cameras, as well as the associated Surveillance Use Policy.1 Based on the success of the first twenty ALPR cameras deployed, and the identification of specific areas where additional cameras would be useful, in December of 2024, the Council approved a five-year contract, which deployed ten additional ALPR cameras and extended the term of the contract for all thirty cameras thru December of 2029.2
In mid-2023, unbeknownst to many law enforcement agencies including PAPD, Flock had 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 belonging to more than 4000 agencies, 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 and only when a full 7-digit license plate number was known. All searches required articulation of a legitimate law enforcement purpose.
1 City Council, April 3, 2023; Agenda Item #11; SR2301-0741, https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=82232&dbid=0&repo=PaloAlto&searchid=35d2643 9-835f-4015-b198-79ecd7231a2e
2 City Council, December 2, 2024; Agenda Item #11; SR #2408-3360, https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83107&dbid=0&repo=PaloAlto&searchid=06637a23 -cd9f-4a28-be10-dbc21253f3c9&cr=1
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.
ANALYSIS
Overview
Automated License Plate Recognition (ALPR) technology uses a combination of cameras and computer software to scan the license plates of passing vehicles. The cameras, which are mounted to fixed infrastructure (e.g., lamp posts or street signs), capture computer- readable images that allow law enforcement to compare plate numbers against plates of known stolen vehicles or vehicles associated with missing persons or individuals wanted on criminal charges. When a match is found, a real-time alert is generated, notifying police of the location where the image of the stolen or wanted vehicle was captured. ALPR data is also used by investigators, after a crime has been committed, to identify and locate associated vehicles.
PAPD Use
The deployment of Flock fixed ALPR cameras in Palo Alto began in July of 2023, with the first twenty cameras operational by November of 2023, and a total of thirty cameras operational by March of 2025. The Department has used these cameras to great effect. Real-time alerts generated by the ALPR cameras have resulted in the recovery of dozens of stolen vehicles and stolen license plates, and the apprehension of numerous wanted persons. In addition, ALPR has been used to safely locate multiple missing persons. Data captured by the ALPR cameras has also assisted investigators in the after-the-fact identification and arrest of numerous felony suspects. Just a few notable examples to illustrate the variety of successful applications of Flock ALPR in Palo Alto over the past 22 months include:
An elderly man, who suffers from dementia, was discovered to have taken his caregiver’s vehicle without permission and was missing. Flock data was used to determine his path of travel and, ultimately, locate him safely within the hour; A despondent teenager suffering from a mental health crisis had made threats of suicide before leaving home in a vehicle. Flock data was used to determine their path of travel and a Flock real-time alert allowed officers to locate them safely and ensure they received appropriate care;
Two suspects committed an armed robbery in Palo Alto after having just committed an armed robbery in another city. A Flock real-time alert allowed officers to locate the vehicle’s direction of travel within minutes, and additional Flock alerts in another city aided officers as they pursued the vehicle, apprehended the suspects, and recovered multiple firearms;
Two suspects committed a robbery at a shopping center and injured a police officer during their escape. Palo Alto Flock data was used to identify the suspects and Flock data in other cities enabled PAPD detectives to locate the suspect vehicle and, ultimately, arrest both suspects within 24 hours.
A suspect was arrested in connection with a series of felony retail thefts in Palo Alto and other cities throughout the region. Investigators were able to strengthen their case by combining Flock data from Palo Alto and other cities to confirm that the suspect’s vehicle had, in fact, been in the area of each of the thefts at the times of the thefts.
Two suspects, responsible for dozens of residential burglaries throughout the region (including multiple occupied burglaries in Palo Alto), were identified and arrested through the investigative use of Flock data captured in multiple jurisdictions. The suspects were ultimately located and arrested in another city with the help of Flock data.
A Flock real-time alert notified officers of the presence in Palo Alto of a vehicle wanted in connection with a shooting homicide in another city. PAPD officers located the vehicle and arrested the homicide suspect.
To derive maximum benefit with the fewest cameras needed, the Department has placed its cameras at strategically selected locations based on several factors: crime statistics, common vehicular ingress and egress points, and traffic volume. The cameras at these locations have proven to be effective at providing officers with real-time alerts when vehicles of interest enter or flee the City via the most common ingress and egress points.
The cameras are placed on roadways with high traffic volume, with an emphasis on ingress and egress routes and commercial and retail areas.
Applicable Law and Policy
California Civil Code § 1798.90.55 expressly prohibits sharing ALPR data with out of state or federal agencies. Additionally, California Government Code § 7284 et seq. (known as the California Values Act) prohibits the use or sharing of ALPR for immigration enforcement purposes.
Beyond the restrictions imposed by California law, the Department’s Fixed ALPR surveillance use policy, approved by the City Council in 2023,5 provides in relevant part:
Data is only accessible to trained PAPD staff with a legitimate law enforcement need, and all queries are logged and subject to audit.
5 Approval of the policy is available at: City Council, April 3, 2023, Action Minutes, https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=43006 The Department only shares its data with other local law enforcement agencies with whom an MOU is in place, and does not share data with any non-law enforcement entities.
Data not saved as evidence in a specific criminal investigation is purged after 30 days.
The Department makes accessible to the public, via its ALPR webpage,7 relevant policies as well as information concerning the number of cameras deployed, the data retention period, and the names of law enforcement agencies with whom it shares data by agreement. Flock Safety also maintains a publicly accessible Transparency Portal8 containing much of the same information.
Palo Alto Data Sharing
While its data was unknowingly included in the “Nationwide Lookup” searchable dataset for a period of time ending in October 2024, 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 it 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.
Flock Updates
Flock has implemented several feature changes in response to concerns regarding potential improper use.9 Among those changes:
Disabling the “Nationwide Lookup” feature for all California agencies; Prohibiting any sharing agreements between California and non-California agencies; 7 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
8 Flock Safety, Palo Alto Police Transparency Portal webpage; https://transparency.flocksafety.com/palo-alto-ca-pd 9 Flock Safety, Flock Algins License Plate Reader Technology with State-Specific Legal Frameworks Blog, 2026; https://www.flocksafety.com/blog/flock-aligns-license-plate-reader-technology-with-state-specific-legal-frameworks Requiring a documented FBI National Incident-Based Reporting System (NIBRS) case type for all searches to make auditing easier;
Filtering and blocking, by keyword, prohibited searches involving immigration or reproductive healthcare. If a search containing a blocked keyword is attempted, California agency data will not be queried and no data will be returned.
Flock has also expanded its compliance team to ensure that new features are thoroughly vetted for state-specific legal compliance. In addition, Flock is in the process of implementing updated processes for notifying customers of new system functionality and any changes to user settings.
Regional Use of Flock
ALPR technology is widely used throughout Santa Clara County, with Flock being the predominant vendor. Nearly all agencies – as well as most agencies in adjoining counties – share their ALPR data with one another. ALPR data sharing among local law enforcement partners allows agencies to collaboratively investigate, identify and apprehend multi- jurisdictional offenders, or those who commit crimes in one jurisdiction but reside in another. No other fixed-ALPR vendor has significant market share in California.
With that, as a result of recent concerns, several Santa Clara County jurisdictions have re- examined their continued use of Flock ALPR cameras.
The City of Mountain View and Town of Los Altos Hills elected to discontinue use of Flock.
The Santa Clara County Board of Supervisors aborted its planned roll-out of Flock ALPR cameras and is, instead, exploring alternative ALPR vendors. In the interim, the Sheriff’s Office has also ceased accessing Flock cameras owned by the contract cities of Saratoga and Cupertino.
On the other hand, the city councils of San Jose and Sunnyvale recently approved the continued used of Flock ALPR with some minor policy modifications, and the cities of Santa Clara, Milpitas, Morgan Hill, Gilroy, and Los Gatos-Monte Sereno have continued to use Flock ALPR without interruption. The Town of Los Altos has indicated that it intends to continue its use of Flock ALPR and has a pending informational session scheduled for its city council. The City of Campbell is the lone city in the county that has been using an ALPR vendor other than Flock.
In the greater Bay Area region, where Flock is similarly the predominant ALPR vendor, notably, the cities of San Francisco, Oakland, Richmond, Berkeley and East Palo Alto have recently approved the continued use of Flock ALPR, while Santa Cruz has discontinued use.
Menlo Park, Atherton, and Redwood City continue to use Flock ALPR uninterrupted.
Nationwide, nearly 6000 law enforcement agencies in 49 states currently use Flock ALPR cameras, including more than 300 law enforcement agencies in California. In total, fewer than 70 agencies (about 1% of user agencies) nationwide have discontinued their use of Flock (for any reason) since 2025, with fewer than 10 of those in California (about 3% of CA user agencies).
Internal Procedures Updates
The Department continues to use best practices to secure Palo Alto ALPR data, including a 30-day limit on data retention, individual user log-in credentials, mandatory dual authentication, individual MOUs with other agencies for data sharing, and other internal policy controls. Previously, on a quarterly basis, the Department had been reviewing a random sampling of PAPD user searches for compliance with applicable law and policy.
These reviews have not revealed any instances of misuse. In April of 2026, the Department began conducting these PAPD user reviews on a monthly cadence. Additionally, the Department has begun conducting a monthly review of a random sampling of outside agency searches for compliance with applicable law, and a monthly hand-check to ensure that searches have only been conducted by agencies with whom PAPD has a sharing MOU.
Publication of Palo Alto Search Logs
In January 2026, the Department added initial information on this issue to its ALPR webpage and updated that information in February and April 2026, respectively. Also, recognizing public interest in this topic, the Department has posted partially-redacted Flock search logs to its ALPR webpage. 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.
Going forward, the Department will proactively post these logs on a monthly cadence.
Third Party Assessment
PAPD has discussed the City’s concerns with Flock’s executive leadership team and, in response to PAPD’s suggestion, Flock has expressed a strong willingness to cooperate with a third party assessment. While the City Auditor was unable to perform this task, the City has enlisted the Independent Police Auditor (IPA) to address this topic in a special report, which staff anticipates will be presented to Council after the summer recess. The goal of the IPA’s review will be to conduct an operational assessment of Flock’s policies and procedures around security, transparency, sharing compliance, and reporting of system features and changes. In addition, while 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, the IPA will also assess PAPD’s internal policies and procedures with an eye toward areas where it may be able to do even better.
FISCAL/RESOURCE IMPACT
Flock is already contracted with the City. The IPA will complete its review within the terms and funding allocated to its existing annual contract.
Under the terms of the City’s contract with Flock, the City may terminate the contract for convenience, subject to a removal fee of $500 per unit of Flock Hardware. Alternatively, the City may terminate for material breach of the contract, but only after giving 30 days notice and opportunity to Flock to cure the breach. In either case, Flock will refund a pro-rata portion of prepaid fees.13
If the City chose to pursue an alternative ALPR vendor, it is estimated that the process of soliciting proposals, executing a contract, and facilitating installation of new equipment would take 6-12 months. Currently, one-third of the cost of the Flock contract is paid via State of California Organized Retail Theft grant funding; it is unknown if that grant funding could be re- purposed for a different ALPR vendor.
ENVIRONMENTAL REVIEW
The City’s contract with Flock is categorically exempt under CEQA regulation 15321 for enforcement actions.
ATTACHMENTS
Attachment A: Council-approved surveillance use policy for Fixed ALPR Technology APPROVED BY:
James Reifschneider, Police Chief
13 City Council, April 3, 2023, Item #11, SR #2301-0741, Attachment A, p.68 Sections 6.2 and 6.3 of Exhibit J in Contract S23187316 between the City of Palo Alto and Flock Group, Inc.; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=82232&dbid=0&repo=PaloAlto