TO: Palo Alto City Council
CC: City Manager Ed Shikada
Chief James Reifschneider, PAPD
FROM: Michael Gennaco, Stephen Connolly & Teresa Magula Auditing Team for ALPR Review
DATE: August 11, 2026
RE: City of Palo Alto’s Review of Automated License Plate Recognition Program
Background
OIR Group has been advised that Council intends to hold a session on August 24, 2026, and potentially request us to conduct an audit of PAPD’s use of its Automated License Plate Recognition (ALPR) Program. We have been also advised of the Council’s intention to provide input on the scope of that audit.
To assist in that process, we have framed potential topics that could be considered as the audit’s parameters are discussed at that meeting. These suggestions are based on our familiarity with issues of concern and our related review projects involving ALPR systems for the Counties of Santa Clara and Santa Cruz, the City of Pasadena, and other jurisdictions with which we have been engaged. We look forward to the discussion and Council’s ultimate direction.
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OIR Group – Proposed Topics for Palo Alto ALPR Review
Potential Focus Areas for Audit Review
1. Concerns About the Current ALPR System in Palo Alto
How PAPD arrived at the current situation
Data sharing concerns
Other concerns about ALPR installation, placement, and use Concerns regarding Flock’s remediation efforts
2. Internal Access and Appropriate Use
Who has access to the system and whether access is appropriately restricted Whether queries are tied to a legitimate law enforcement purpose Use of case numbers and offense types to validate searches How the system is used in practice (e.g., investigative tool vs. broader exploratory use)
3. Data Sharing and External Access
Which outside agencies have access to Palo Alto data and under what agreements
Whether current MOUs adequately define and limit access and use Whether partner agencies are conducting their own audits or oversight Whether additional safeguards (e.g., reciprocal audit requirements) are feasible What searches are outside agencies conducting using Palo Alto data
4. Data Retention and Storage
Current retention period and whether it aligns with policy and best practices How and where data is stored (e.g., cloud environment) Whether data deletion practices are automatic, verified, and consistently applied
OIR Group – Proposed Topics for Palo Alto ALPR Review
5. System Security and Auditability
What security controls are in place to protect data (e.g., authentication, access restrictions)
Whether audit logs are complete, reliable, and sufficient to monitor system use Whether the system allows for identifying and addressing errors or misuse
6. Vendor Governance and Platform Evolution
Significant platform changes, upgrades, and new features implemented during the review period
How product changes may have affected data sharing, access controls, retention, auditing, or security
How Flock communicates product updates, policy changes, identified issues, and compliance-related developments to customers
Whether Palo Alto has adequate processes for reviewing and responding to vendor communications
Review of contracts, amendments, and other agreements related to:
o Data ownership
o Retention
o Audit rights
o Security requirements
o Notification obligations
o Compliance with California law
Evaluation of vendor-provided reporting, auditing, and oversight tools available to the City
Review of significant vendor-identified issues, corrective actions, and resulting safeguards
Assessment of whether City governance practices keep pace with platform changes and evolving capabilities
7. Policy, Procedures, and Oversight
Whether existing policies and procedures adequately govern system use, access, and sharing
OIR Group – Proposed Topics for Palo Alto ALPR Review
Whether training, supervision, and internal audit practices are in place and effective
Alignment with applicable legal requirements and best practices
8. Effectiveness and Value
How the system is being used across different types of cases Whether it contributes meaningfully to investigative outcomes (e.g., arrests, recoveries)
Distinction between cases where ALPR use is central vs. supplemental Overall assessment of the system’s value relative to its use and impact(s)
9. Best Practices and Benchmarking
Identification of opportunities to strengthen safeguards, accountability, and effectiveness