Sabha, Tamer
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Jen Collins
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Sabha, Tamer; Gao, Beilei; Diaz, Eligio
Public Comment, Public Safety Committee Meeting March 18, 2026 [ I ] CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content is safe. Report phish using the Phish Alert Button. For more information about the Phish Alert Button view article "KB0011474" on the DolT portal.
Good afternoon, members of the Public Safety Committee, I am a Pasadena resident in District 5, writing to you in advance of your discussion of the Pasadena Police Department's review of their use of Flock Safety Automatic License Plate Readers.
Here is a sample of American cities that have ended their contracts with Flock within the last three months: Cambridge, Massachusetts; Flagstaff, Arizona; Mountain View, California; Ithaca, New York; and Eugene and Springfield, Oregon.
Notably, these actions were taken after August 2025, when the state of Illinois discovered that US Customs and Border Protection had accessed its ALPR data, in violation of state privacy protections.
That situation resulted in Flock being compelled to tighten its security, which may have provided reassurance to some local governments. Nevertheless, due to privacy, legal, and governance concerns that continue despite those changes, cities are still electing to stop working with Flock.
Thank you for your time and consideration of this matter.
Sincerely,
Jennifer Collins
Sources
Cambridge:
https://www.thecrimson.com/article/2025/12/10/cambridge-ends-flock-contract/ Flagstaff:
https://www.kjzz.org/business/2025-12-17/flagstaff-cancels-contract-with-fLock-safety-cameras Mountain View:
https://localnewsmatters.org/2026/03/01/mountain-view-ends-flock-safety-license-plate-reader- contract/
Ithaca:
https://www.wrvo.org/2026-03-05/ithaca-common-council-votes-to-end-contract-with-flock-safety Oregon:
https://www.opb.org/article/2025/12/06/eugene-springfield-end-flock-cameras/ Illinois:
https://apnews.com/articLe/immigration-abortion-license-plates-cameras- cc5f29df94a29ee2c6c2feb2151 c8f5e
Sabha, Tamer
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humaira afzal <
Tuesday, March 17, 2026 5:58 PM
Rivas, Jessica; Hampton, Tyron; Jones, Justin; Madison, Steve; Sabha, Tamer Email 1 on Public Safety Committee item 4 (3/18/26) Flock [ I ] CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content is safe. Report phish using the Phish Alert Button. For more information about the Phish Alert Button view article "KB0011474" on the DolT portal.
This is email #1 of 3 emails on Item 4 - Flock
Members of the Public Safety Committee,
Cities and counties across the country are terminating or significantly changing their Flock contracts in response to concerns about privacy, mass surveillance and the security of data. Pasadena needs to join them. Despite repeated assurances, the Pasadena Police Department, the data from the Flock automated license plate readers (ALPRs) can never be sufficiently safe. There have been many documented examples (including in California) of out-of-state and federal agencies getting access to ALPR data in states in which data sharing is against state taw. No matter how conscientiously PPD controls access locally, it cannot control the actions of users at the hundreds of other agencies that have access to Pasadena data on the Flock network. And the PPD doesn't exactly have a strong track record of properly securing ALPR data. In 2020, for example, the PPD was sharing ALPR data with ICE'S Homeland Security Investigations at the same time that it was promisingdty Council that it has "robust policies and procedures" in place to prevent immigration authorities from getting access (see email #2). PPD cannot even keep its written policy on ALPRs in the Policy Manual remotely up to date (see email #3). You'll find nothing about this in PPD's various reports or presentations because unfavorable information is never acknowledged or included.
This document is a partial compilation of (1) cities and counties that have terminated or reduced Flock use, and(2) cities and counties (including many in CA) that have have had federal or out-of-state agencies access their data in violation of state law.
It is way beyond time that City Council start taking public concerns seriously and have a comprehensive and in-depth public discussion about the future of Flock and other surveillance technology in Pasadena.
Some recommendations:
Request a comprehensive analysis and assessment of the Flock ALPRs from the Community Police Oversight Commission (CPOC) and require that it include presentations by experts from the ACLU and from privacy and surveillance technology experts.
Do not buy any more surveillance equipment or technology or extend or renew any contracts without comprehensive analysis and assessment by CPOC, the Public Safety Committee, and the City Council.
Require that the PPD provide detailed data and analysis of the use of ALPR data for solving crime that includes statistics and a cost-benefit analysis. (Anecdotal data is not analysis. "Success stories" aren't analysis.
Proclaiming "What would have happened if we'd had cameras" is not analysis.) Prohibit PPD from activating any new, upgraded, or additional features or capabilities of the Flock cameras (such as facial recognition or integration with other platforms) without approval from CPOC, Public Safety Committee and City Council.
Request that City Staff present detailed information on existing ALPR contracts, the options for terminating existing contracts early, and the options for not renewing current contracts.
Disclose all campaign contributions made to City Council members from individuals, organizations or other entities (including PACs and unions) with an economic or other interest in increasingthe use of surveillance technology by Pasadena PD and other law enforcement agencies.
Examine the role of Flock Safety in directly or indirectly providing data to federal or out-of-state agencies involved in detaining or deporting immigrants, tracking people seeking health care, or in surveilting people who are exercising constitutionally protecting rights.
While re-evatuatingthe use of Flock and other ALPR systems in Pasadena, require that PPD Completely rewrite and update the ALPR policy (Policy 462) in the PPD Policy Manual within 30 days.
o Acknowledge and address the documented examples of federal and out-of-state agency access to CA ALPRdata.
o Acknowledge and address the fact that Pasadena PD has previously shared data with federal and out- of-state agencies in violation of state taw.
o Respond to ati public records requests regarding Flock or other surveillance technology contracts and communications with Pasadena PD, the City of Pasadena, or affiliated organizations within 10 business days
o Require more detailed info for the reasons for ALPR queries. "Investigation," "call for service," "wanted," and just the case number in the Reason column are meaningless and not transparent. o Dramatically reduce the retention time for Pasadena ALPR data on the Flock network. New Hampshire data only stays in the system for 3 minutes!
0 Post a map of alt City of Pasadena ALPR cameras prominently on the city website. o Present a comprehensive inventory of technology equipment (including software and Al) and contracts (with dates) at least annually and also as part of any new PPD request to purchase new technology equipment services or to extend or renew existing contracts or replace existing equipment.
Humaira Afzal
Pasadena - District 7
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Sabha, Tamer
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humaira afzal •
Tuesday, March 17, 2026 6:01 PM
Rivas, Jessica; Hampton, Tyron; Jones, Justin; Madison, Steve; Sabha, Tamer Email 2 on Public Safety Committee item 4 (3/18/26) Flock Some people who received this message don't often get email fromLearn why this is important [ l ] CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content is safe. Report phish using the Phish Alert Button. For more information about the Phish Alert Button view article "KB0011474" on the DolT portal.
This is email #2 of 3 emails on Item 4 - Flock
Members of the Public Safety Committee,
The Pasadena Police Department repeatedly neglects to acknowledge or mention that its "robust policies and procedures" have failed to prevent data sharing multiple times. PPD also routinetyfails to mention that many other CA agencies that have access to Pasadena ALPR data have shared data with federal and/or out-of-state agencies.
PPD also habitually omits or downplays very relevant information about data security issues from its reports and presentations.
This document is a partial compilation of (1) cities and counties that have terminated or reduced Flock use, and (2) cities and counties (including many in CA) that have have had federal or out-of-state agencies access their data in violation of state law.
The "brief history" betow shows a pattern: PPD asks for more ALPR equipment. Community members and privacy and civil rights organizations object because of the risks to privacy and data security. The new equipment is approved anyway. The things that people warned about happen. PPD asks for more ALPRs and doesn't mention data sharing violations in its report or presentation. People again warn about the risks. PPD gets more ALPR equipment approved. The things that people warned about happen again.
September 2020
PPD asks for $80,000 for 3 new ALPRs. Pasadena Privacy for ALL and other community members oppose the acquisition and express concern that out-of-state agencies federal immigration authorities will get access to the information. PPD assures the Committee that "robust policies and procedures are in place to prevent the system and the information it gathers from being used inappropriately or differently from its intended purpose." The Public Safety Committee approves the request.
December 2020
The local chapter of the ACLU obtains documents showing that, as of 11/2/2020, Pasadena PD was sharing data with Homeland Security Investigations (HSI). PPD states that it had started sharing ALPR data with HSI four months earlier to help "restrict the flow of funding that supports criminal enterprises." PPD stopped sharing License plate info when it realized HSI was affiliated with ICE. PPD was actively sharing data with ICE'S home agency at the same time that it was assuring the Public Safety Committee that it won't share data with ICE.
Apparently the "robust policies and procedures" did not include looking up what other federal agencies an entity is affiliated with before sharing data.
PPD promises to "review the matter in detail to ensure that no inadvertent contacts are made with ICE through which they might gain access to City information through some back door or information sharing program." Meanwhile, PPD continues sharing ALPR data with the CA Joint Regional Intelligence Center (Norwalk "Fusion Center"), which partners with the Department of Homeland Security (home agency of ICE and CBP) and shares information widely with federal law enforcement agencies.
January 2022
PPD requests $165,000 to purchase 11 fixed ALPR cameras. The Police Department's Agenda Report does not mention the PPD's sharing of ALPR data with Homeland Security Investigations in 2020. Following discussion (and extensive public and written comments against the purchase), City Council unanimously approves the request.
May 2023
Pasadena Police Department is among the departments violating state lawonALPR data sharing. An investigation by the Electronic Frontier Foundation (EFF) reveals that many CA police departments are sharing records containing detailed data from ALPRs to out-of-state agencies. The ACLU, along with other organizations, sends demand letters telling these police departments to stop.
July 2023
PPD asks for over $630,000 to lease and install additional ALPR cameras. The report does not mention the PPD's sharing of ALPR data with Homeland Security Investigations (in violation of state law) in 2020orthe EFF's investigation and ACLU demand Letter from 2 months earlier. The PPD's request is approved unanimously.
January 2024
In a Letter to CA Attorney General Rob Bonta,theACLU and EFF List the Pasadena Police Department as one of the agencies that has either refused to stop sharing ALPR information with other states' agencies or has failed to respond to their requests.
May 2025
PPD requests approval to lease an additional $34,000 worth of ALPR cameras and support hardware. The PPD's Agenda Report does not include information on any of the previous data sharing (which was in violation of state law) with federal and out-of-state agencies referenced above. Privacy experts object. The request is approved.
August 2025
PPD'sALPRadministratorassurestheCommunity Police Oversight Commission that the department only shares data with local and in-state agencies. He does not include any information on the previous data sharing violations with federal and out-of-state agencies referenced above or mention the vast volume of documented evidence that federal and out-of-state agencies are getting unauthorized access to ALPR data in CA and other states with similar laws.
October 2025
CA Attorney Rob Bonta files a lawsuit against the City of EL Cajon Police Department over its refusal "to comply with state law prohibitingthe sharing of license plate data with federal and out-of-state law enforcement agencies." The lawsuit states that the El Cajon has "knowingly and repeatedly" violated CA law by sharing ALPR data with 26 different states. E( Cajon has access to Pasadena PD'sALPR data.
January 2026
A news release dated Jan. 30 from the Mountain View CA Police Department states, "From August to November 2024, several federal law enforcement agencies accessed Mountain View's Flock Safety ALPR system for one camera via a 'nationwide' search setting that was turned on by Flock Safety. This setting was enabled without MVPD's permission or knowledge." Mountain View turns soon joins a growing number of CA cities and counties cancelling their contracts with Flock Safety. A March PPD presentation will refer to this serious security issue as a "vendor-identified issue".
February 2026
Several members of City Council raise concerns about the security of Pasadena's ALPR data. Chief Harris assures City Council (and the public) that PPD does not share information with federal or out-of-state agencies. He does not mention any information about the previous data sharing (in violation of state law) with federal and out-of- state agencies referenced above.
March 2026
The PPD's report on "Flock Safety Automated License Plate Reader Overview and Data Sharing" includes no information about the Department's previous data sharing with federal and out-of-state agencies referenced above. The euphemistically phrased "vendor-identified issue" was actually weaknesses/flaws in the Flock network system and architecture that allowed out-of-state and federal agencies to access CA ALPR data in violation of state law. The report also makes no mention of the many cities and counties across the country that have cancelled or not renewed their Flock contracts in 2025 and 2026 because of unauthorized data access and public concerns about privacy and surveillance.
Just this brief overview raises serious concerns about the soundness and reliability of PPD assurances about data privacy and security.
Sincerely,
HumairaAfzal
Pasadena-District 7
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Sabha, Tamer
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humaira afzal <
Tuesday, March 17, 2026 6:04 PM
Rivas, Jessica; Hampton, Tyron; Jones, Justin; Madison, Steve; Sabha, Tamer Email 3 on Public Safety Committee item 4 (3/18/26) Flock 2026 03 18 updated South Pasadena police ALPR policy.pdf; Pasadena Police ALPR Policy manual.pdf
Some people who received this message don't often get email fromLearn why this is important [ l ] CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content is safe. Report phish using the Phish Alert Button. For more information about the Phish Alert Button view article "KB0011474" on the DolT portal.
This is email #3 of 3 emails on Item 4 - Flock
Members of the Public Safety Committee,
It is difficult to take Pasadena Police Department's assurances about the security and privacy of the data from the city's Flock automated license plate reader (ALPR) cameras seriously when the department has not even updated the ALPR section of the Pasadena_PoUce,Depar^^ to reflect major changes in equipment used, the amount of data collected, or California state Law. At the 2026 February 23 City Council meeting, Chief Harris assured Council (and the public) that the PPD has "done an exhaustive review to make sure that we are abiding by the laws and policies and to ensure that our information is not being shared." Clearly that exhaustive review did not include checking to see if the Policy Manual section on ALPRs is accurate.
According to PPD Policy Manual (2025/10/13 edition) section 106.1, "the manual is a statement of the current policies, rules and guidelines of this department," but the section on ALPRs (Policy 462) was obviously written when the PPD used mobile, vehicle-attached ALPRs and therefore does not reflect changes in equipment types (from mobile to fixed ALPRs) or the exponential increase in the amount of data collected. There are multiple indications that the policy was written for the old equipment. For example, section 462.4 references "ALPR- equipped cars" and 462.5 notes that "data will be transferred from vehicles." It is very significant to note that the older mobile ALPRs scanned substantially fewer license plates and collected far less data because the camera scanning capacity was limited by the movement and time on the road of the vehicles to which theywere attached.
However, the fixed ALPRs (which PPD has had since at Least early 2022) collect data 365/24/7 and record the plate and vehicle characteristics for every single vehicle travelling through an intersection. According to the Flock Irans^areQC^PQnaUQLPPD.., Flock brand fixed ALPRs record vehicle data over 950,000 times every month; in the 30 days prior to March 15, Pasadena's Flock ALPRs recorded vehicle data 985,057 times. The exponential increase in the amount of data collected by the fixedALPRs should have triggered a complete rewrite of the ALPR section of the PPD Policy Manual.
The Policy Manual - which is supposed to be the statement of current policies, rules, and guidelines - also differs substantially from information that PPD has provided in recent years and includes glaring contradictions between stated policy and written policy.
Examples of contradictions between stated policy and written policy
1. Electronic surveillance as a use. AccordinQ to the PPD's 3/18/2026 presentation, ALPRs are not used for "surveillance of individuals," but 462.3 in the manual lists "electronic surveillance" as a use forALPR technology. (The distinction between surveilling vehicles and surveilling individuals is meaningless since PPD can almost instantly connect vehicles to their owners and other household members.)
2. Independent contractor access to ALPRs and their data. PPD has repeatedly stated that only authorized and trained PPD personnel have access to the ALPR data, but 462.3.1 (a) references "independent contractors who are authorized to use or access the ALPR system or to collect ALPR information."
3. Volunteer operators ofALPRs. 462.4.1 describes operations by volunteer operators. This is obviously an outdated section since the PPD no longer operates ALPR equipped vehicles. It is troubling that privacy protections were so lax in the past that volunteers were allowed to operate ALPR equipment, and that there is still language in the policy permitting volunteers to access ALPR equipment.
4. Retention of ALPR data for 2 years. According to the PPD 3/18/2026 and previous presentations, data is retained for 30 days unless saved as evidence for a case. 462.5 states that "All ALPR data downloaded to the server should be stored for a minimum of two years in accordance with the City's established records retention schedule." This is a reference to the older, mobile ALPRs. There is no mention of a 30 day (or any other) retention period for data from the fixed ALPRs.
5. ALPR data can be used for non-criminal investigation actions. PPD emphasizes the use of ALPRs for criminal investigations but, according to 462.6, data can also be accessed for department-related civil or administrative action. 462.7 references the process for handling "requests forALPR data by non-law enforcement or non-prosecutorial agencies." No information is provided on what these civil or administrative actions or non-law enforcement or non-prosecutorial agencies would be, and this opens the door to a much wider range of queries and correlating privacy and data security concerns.
6. Procedure for release ofALPR data with other law enforcement or prosecutorial agencies has no explicit restriction on sharing with federal or out-of-state departments. According to PPD presentations, data is not shared with out-of-state agencies or with federal investigative agencies. However, there is no explicit prohibition to this in the written ALPR policy, nor are relevant CA laws referenced. 462.7 states that "the ALPR data may be shared only with other law enforcement or prosecutorial agencies for official law enforcement purposes." 462.3 lists "homeland security" as a use for ALPR data! ICE and CBP are both part of the federal Department of Homeland Security.
The PPD Policy Manual section on ALPRs also provides no information on the use of data from Pasadena Parking Division's ALPR cameras. According to the Parking Divjsion^ item 3, ALPR data may "be shared with the Pasadena Police Department in accordance with their ALPR policy," but it is unclear what part of the outdated written policy applies to PPD use of Parking Division data. Item 7 of the Parking Division policy also states that their ALPR data "may be released to other law enforcement or prosecutorial agencies for official law enforcement purposes." There is no explicit exclusion from sharing Parking Division ALPR data with out-of-state or federal agencies.
The South Pasadena Police Department recently updated their ALPR policy (attached) to reflect current SPPD practices and the guidance of the Attorney General and California state law. New provisions, procedures and safeguards were also added to further protect privacy and the security of the data. hlaving such an outdated and inaccurate policy section on ALPRs in the Pasadena Police Department Policy Manual is unacceptable and unprofessional. Considering the many valid concerns about privacy and security of the ALPR data, the PPD written policy should also be much more detailed and thorough. It's hard to trust the privacy and security of ALPR data to a department that does not even keep written policy up to date to reflect current practices, equipment, or law. I have additional issues with the FlockALPRs that I will share separately.
Sincerely,
HumairaAfzal
Pasadena-District 7
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DATE:
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City Council
Agenda ReportITEM NO. 20
March 18,2026
Todd Hileman, City Manager
Derek Elmore, Chief of Police
Roxanne Diaz, City Attorney
Davit Ghazaryan, Management Analyst
Andrew DuBois, Police Sergeant
CONSIDERATION TO DISCUSS AN UPDATED INFORMATIONAL
REPORT ON THE CITf'S CONTRACTS WITH FLOCK GROUP
INC., FOR THE AUTOMATED LICENSE PLATE READER (ALPR)
SYSTEM, THE SOUTH PASADENA POLICE DEPARTMENT'S
UPDATED ALPR POLICY AND PROVIDE DIRECTION REGARDING
CONTRACT OPTIONS FOR THE ALPR SYSTEM
Recommendation
It is recommended that the City Council review and discuss this updated informational report on the City's contracts with Flock Group Inc. dba Flock Safety and provide direction on next steps in relation to the Automated License Plate Reader system program and City's contracts with Flock Safety.
Executive Summary
At the February 18, 2026, City Council meeting, the City Council received a presentation and report regarding the South Pasadena Police Department's (SPPD) use of the Flock Safety Automated License Plate Reader (ALPR) system. Concerns were brought forward regarding the Flock ALPR system related to data retention, data sharing and the aggregation of data.
Staff was directed to review these issues as well as the contract and provide an update to the City Council. The report is to inform the Council about the exact expiration dates for both Flock Safety contracts (the 2022 and 2024 agreements), provide an update regarding UASI 2021 grant funds that were used to lease the ALPR equipment in relation to the 2024 agreements, provide contract termination projections for both contracts and present SPPD's newly updated ALPR policy for City Council's review.
Background
Beginning in 2013, SPPD implemented mobile, or vehicle mounted ALPR technology. In support of expanding this capability, the City's Adopted Budget for Fiscal Year 2022 -23 included a $30,000 appropriation to implement and fully migrate to a stationary ALPR system.
In November 2022, the Police Department partnered with Flock Safety as part of a regional initiative to enhance crime prevention through strategic technology investments utilizing the Department's General Funds.
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On November 16, 2022, the City Council approved a two-year agreement with Flock Safety for the installation of 13 stationary ALPR cameras. To fund the first year's installation and operational expenses of $30,000, an additional $ 9,550 was appropriated from the City's General Funds to the Police Department's Contract Services account to cover the full cost of installation and annual operations.
On February 14, 2024, the Urban Area Security Initiative (UASI) 2021 grant enabled the Police Department to expand its ALPR network by adding 14 cameras to the existing system, raising the total to 27 cameras. UASI is a reimbursement-based grant and there is a multiyear lag between grant approval and the actual disbursement of funds. Following the grant award, in which Flock Safety was designated as a pre-approved sole- source vendor, the Department efficiently implemented the expansion to further enhance its public safety and investigative capabilities.
Analysis
The City has 27 ALPR fixed cameras strategically placed at key ingress and egress points throughout the City. The ALPR cameras continuously scan and record images of vehicle license plates, including the license plate number, images of vehicles and its characteristics (i.e. color and make), along with the date, time, and GPS location when a vehicle drives through the area where the fixed ALPR camera is located. The vehicle license plate number is automatically cross-referenced with law enforcement databases and the Department of Motor Vehicles. This enables the identification of vehicles that may be stolen or associated with criminal investigations or missing person alerts The ALPR cameras are designed to capture still images of vehicles, meaning that the cameras cannot and do not follow the vehicle as it travels through the City, unless of course the vehicle passes through the area where another fixed ALPR camera is located.
The City of South Pasadena is a subrecipient of the UASI grant through the mayor's office of the City of Los Angeles. In advance of Staff's presentation of the ALPR program on the July 16, 2025, City Council meeting, staff contacted the City's UASI representatives to verify whether the funds used to lease the ALPR equipment in 2024 would need to be repaid if the contract with Flock is terminated and the equipment is returned to Flock. The grant specialists at the City of Los Angeles mayor's office stated that the funds would need to be repaid, however they requested that we contact them if an actual decision regarding termination was to be made. According to the representatives, repayment was dependent on the specific case, the reasons for returning the equipment and they stated this would mark the first time that a subrecipient would be returning equipment purchased or leased with UASI funds.
On February 18, 2026, City Council meeting, the Council directed staff to confirm the grant repayment provisions with the UASI representatives. Accordingly, the City had a virtual meeting with the UASI grant specialists on March 3, 2026. The representatives stated that no UASI funds would need to be returned in this case because the equipment was leased and the grant performance period was fulfilled. Therefore, if the City decided to terminate its second contract with Flock and return the 14 additional ALPR cameras leased in 2024, the grant funds did not need to be repaid. This contract was initially set to auto-renew on 03/19/2026 for 24 months but staff was able to have Flock hold off on processing the renewal and was granted an informal extension of 30 days to seek directions from the Council.
Thus, if the City chooses to terminate its 2024 contract with Flock and notifies the company by 04/19/2026, it will only need to pay the camera removal/termination of convenience fee which 285
is $500 per camera and totals $7,000.00 for this contract.
Per the City Manager's suggestion and the City Council's directive, staff was instructed to explore other ALPR providers within the next 6 months and present suggestions in relation to the possibility of incorporating a hybrid model (keeping Flock Safety and adding another ALPR vendor) and present potential alternative vendors on the City Council meeting of August 19, 2026. In the meantime, staff was requested to present options regarding potential termination fees in association with both Flock contracts.
Option A:
The City would cancel the second contract for 14 cameras, due to expire on 03/19/2026, without having to renew it and pay $7,000 for the removal of cameras The City would continue with the first contract for 13 cameras for the next 5 months, while exploring potential vendors and researching the feasibility of incorporating a hybrid ALPR system consisting of two ALPR vendors
Costs:
$7,000 - Camera Removal Fee -14 cameras
$39,000-Annual Contract Payment- 13 cameras (to be invoiced in April, 2026) Option B:
The City would keep the original 2022 contract of 13 cameras for 1 year The City would keep the second 2024 contract of 14 cameras for the next 5 months, while exploring and vetting alternative ALPR providers
Costs:
$39,000 -Annual Contract Payment- 13 cameras (to be invoiced in April, 2026) $42,000 - Annual Contract Payment - 14 cameras (to be invoiced in March, 2026) Option C:
The City would cancel both contracts and not have an ALPR system for the next 5 months while SPPD is conducting research and is able to provide a list of potential alternative vendors Costs:
$6,500 - Camera Removal Fee -13 cameras
$7,000 - Camera Removal Fee -14 cameras
Updated ALPR Policy
Per the City Council's directive from the February 18, 2026, meeting, SPPD has updated its ALPR Policy (Attachment No. 1 ). The updated ALPR Policy reflects current SPPD practice as well as updates the policy to reflect the guidance of the Attorney General as well as compliance with Senate Bill 54, which prohibits law enforcement from using their resources for immigration enforcement. New provisions have been added regarding prohibited uses of the ALPR System as well as detailed safeguards with respect to the use of the ALPR System, including annual training and monthly audits. Last, a new procedure has been included with 286
respect to sharing ALPR data with other California law enforcement agencies including the requirement of a data sharing agreement.
Fiscal Impact
After reviewing both contracts and as confirmed with Flock Safety, staff verified that both contracts contain identical provisions concerning early termination and reimbursement for unused service periods.
Currently, the 2022 contract is set to be renewed for another 2-year period on 03/30/2027, with an annual contract cost of $39,000.
The 2024 contract is set to be renewed on 04/19/2026, unless canceled by the City, with an annual contract cost of $42,000 annually.
If the City chooses to cancel either of the contracts during the contract term, Flock will provide a pro-rated reimbursement unused service and the City will be responsible for a removal fee of $500 per camera. Please see Attachment No. 2 for a more detailed breakdown of potential termination costs.
Attachment:
Attachment No 1 - Updated South Pasadena Police Department Police 429 Automated License Plate Reader ALPR System
Attachment No. 2 - Termination Costs
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Attachment No. 1
Updated South Pasadena Police Department Policy 429: Automated License Plate Reader (ALPR) System(s)
429.1 PURPOSE AND SCOPE
This policy provides guidance for capturing, storing, and using digital data obtained through the use of Automated License Plate Recognition (ALPR) Systems. ALPR technology supports public safety by identifying stolen vehicles, wanted persons, and missing individuals, and assisting criminal investigations. The South Pasadena Police Department (SPPD) is committed to protecting privacy and civil liberties and ensuring compliance with SB 34 (Civil Code § 1798.90.5 et seq.) and SB 54 (Government Code § 7284 et seq.).
429.2 DEFINITIONS
"ALPR Administrator" means a sworn officer of the South Pasadena Police Department that is designated by the Chief of Police as set forth in Section 429.3.1. The ALPR Administrator is responsible for the implementation of this Policy. "ALPR Data" or "Data" means the data gathered through the use of an ALPR System.
Data includes the recorded images. All ALPR Data collected within South Pasadena is the exclusive property of the City of South Pasadena.
"ALPR System" means a searchable computerized database resulting from the operation of one or more fixed cameras, combined with computer algorithms, to record, read and convert images of vehicle license plates and the characters they contain into computer-readable data. The cameras do not record any sound. 429.3 ADMINISTRATION
The ALPR System enables automated detection of license plates. The SPPD uses the ALPR System to convert vehicle license plate data for official law enforcement purposes. ALPR System equipment installation, maintenance, ALPR Data retention, and access is managed by the assigned ALPR Administrator. The ALPR Administrator may assign members under his or her command to administer the day-to-day operation of the ALPR System, who shall oversees daily operations of the ALPR System, including the Data.
429.3.1 ALPR ADMINISTRATOR
The Chief of Police will designate and assign a sworn officer of the SPPD , who has the minimum rank of Sergeant, to serve as the ALPR Administrator. The ALPR Administrator is responsible for the implementation of this Policy, including monitoring the ALPR System(s) for compliance with State and Federal laws. The ALPR Administrator is authorized to assign members under his or her command to administer the day-to-day operation of the ALPR System.
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The ALPR Administrator shall be responsible for developing guidelines and procedures to comply with the requirements of State and Federal laws and Civil Code § 1798.90.5 et seq. This includes but is not limited to Civil Code § 1798.90.51 and Civil Code § 1798.90.53.
a. A description of the job title or other designation of the members and independent contractors who are authorized to use or access the ALPR system or to collect ALPR information.
b. Training requirements for authorized users.
c. A description of how the ALPR system will be monitored to ensure the security of the information and compliance with applicable privacy laws. d. Procedures for system operators to maintain records of access in compliance with Civil Code § 1798.90.52.
e. The title and name of the current designee in overseeing the ALPR operation. f. Working with the ALPR vendor(s) and the Custodian of Records on the retention and destruction ofALPR data in compliance Department policy. g. Ensuring this policy and related procedures are conspicuously posted on the SPPD website.
1. Ensuring the ALPR Transparency Portal to share usage statistics and audit results is posted and accessible to the public.
429.3.2 ALPR SYSTEM USERS
Only authorized SPPD personnel may access theALPR System and ALPR Data for an authorized purpose. Access is granted based on job function and operational need, and only after the completion of SPPD approved training and upon the approval of the ALPR Administrator or Chief of Police. Each user shall have individual credentials for access and use of the ALPR System and ALPR Data. The ALPR Administrator shall maintain a list of SPPD authorized users. The ALPR Administrator shall revoke the credentials for any user that has left SPPD.
429.4 OPERATIONS
ALPR Data collected from the ALPR System is the property of the City of South Pasadena. SPPD personnel shall only access and use the ALPR System for official and legitimate law enforcement or public safety purposes consistent with this Policy and any applicable laws, including California Civil Code 1798.90.5 et. seq. (as amended from time to time).
Use of the ALPR System and ALPR Data is restricted to the purposes outlined below.
1. The use ofALPR System and ALPR Data is restricted to official law enforcement business only, with access granted to those with both lawful authority and a specific investigative purpose.
2. ALPR Data may be used to identify stolen or wanted vehicles, wanted persons and missing individuals and for legitimate law enforcement or public safety 2 289
purposes such as but not limited to, criminal investigations, active warrants, missing persons investigations, suspect interdiction, and the recovery of stolen property.
3. When possible, Officers must verify an ALPR alert through the California Law Enforcement Telecommunication System (CLETS) before taking enforcement action. Once a vehicle alert is received, SPPD personnel shall visually confirm that the license plate from the ALPR system matches the license plate of the observed vehicle.
4. If an alert is received on an incorrect letter or number on a license plate, SPPD personnel shall correct the number received on the hit for accurate information if the correct information is available. (Civil Code § 1798.90.51 (b)(2)(F)). 429.4.1 COMPLIANCE WITH CIVIL CODE 1798.90.52
For each search inquiry, SPPD shall maintain a record of access to the ALPR Data which shall include the following:
1. The date and time the information is accessed.
2. The license plate number or other data elements used to query the ALPR System.
3. The username of the person who accesses the information, and, as applicable, the organization or entity with whom the person is affiliated.
4. The purpose for accessing the information.
429.4.2 PROHIBITED USES
The following uses oftheALPR System and/orALPR Data are prohibited:
1. To use or allow others to use the ALPR System, including its equipment, orALPR Data for any unauthorized purpose (See, Civil Code § 1798.90.51; Civil Code § 1798.90.53).
2. To use the ALPR System or Data for the purpose of engaging in immigration enforcement. This includes sharing ALPR Data with US Immigration and Customs Enforcement (ICE), Border Patrol, or any other law enforcement agency for the purpose of enforcing immigration laws, as required by California Government Code 7284.6 (California Values Act-SB 54). As set forth in the California Values Act, no local resources or data may be used to assist federal immigration authorities.
3. To use the ALPR System or Data to track or identify individuals or groups seeking or providing reproductive health services.
4. To use the ALPR System or Data for surveillance of individuals exercising their right to protest or assemble or for the purpose or intended effect of unlawfully infringing upon any other First Amendment rights of any person or group. 3 290
5. To use the ALPR System or Data in a discriminatory manner and/or to target a person or group's protected characteristics, including race, color, religion, gender, gender identity, political affiliation, national origin, ethnicity, sexual orientation, disability, or other legally protected classification of any person or group.
6. To use the ALPR System or Data to harass and/or intimidate any individual or group.
7. To use the ALPR System or Data, including any hot lists, for any personal purpose.
8. To indiscriminately view Data without investigative or administrative need.
9. To allow the use of the ALPR System or share ALPR Data with any private entities or out-of-state or federal agencies, including out-of-state and federal law enforcement agencies, including any federal task forces.
10.To sell anyALPR Data obtained or received by SPPD.
Nothing in this Policy, including the provisions of this section, is intended to create an independent right of action in any person or group.
429.5. DATA COLLECTION AND RETENTION
The ALPR Administrator is responsible for ensuring systems and processes are in place for the proper collection and retention ofALPR Data.
1. All non-hit ALPR Data will be deleted after 30 days from the date is was collected unless theALPR data has been downloaded and is being used as evidence in a criminal investigation.
2. All other ALPR Data determined to be evidence or is reasonable to believe it will become evidence in a criminal action, shall be downloaded from theALPR System and stored in SPPD's secured records management system. Unless, the Data is determined to be evidence attached to a specific criminal investigation, the ALPR Data shall be deleted after one year from the date the Data has been downloaded.
3. When ALPR Data is retained as evidence as part of an investigation, the Data shall be kept as part of the case file in SPPD's secured records management system.
4. Nothing herein shall preclude SPPD from maintaining anyALPR Data if it is subject to a lawful warrant, subpoena, court order, litigation hold, discovery request or other lawful action that requires the production of such Data in compliance with applicable laws.
These provisions are in addition to the ALPR System vendor's policy wherein ALPR Data is stored for 30 days, however the vendor deletes such Data on a rolling 30 day basis.
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429.6 ACCOUNTABILITY AND SAFEGUARDS
All data will be closely safeguarded and protected by both procedural and technological means. The SPPD will observe the following safeguards regarding access to, and use of the ALPR System including ALPR Data (Civil Code § 1798.90.51; Civil Code § 1798.90.53).
a. Data shall not be shared with federal or out-of-state agencies without a federal or California court-issued search warrant or order.
b. No default access to out-of-state or national databases is permitted on the third- party vendor platform. In-state, agency-to-agency sharing must be manually authorized by the Chief of Police or the ALPR Administrator. c. SPPD authorized users must provide a specific reason for every search. This includes providing under the ALPR System drop-down menu the mandatory "offense type" and reason for the search, and a specific case number for audit purposes. Generic terms such as "investigation" are strictly prohibited. d. Access to the ALPR System must utilize dual-factor authentication or equivalent security measures to prevent unauthorized data breaches. e. Data will only be shared with local agencies that have acknowledged and signed an interagency agreement mandating compliance with SPPD's terms and conditions, including a specific acknowledgement prohibiting the user from sharing SPPD data with unauthorized third parties as set forth in this Policy.
Before sharing data with another California agency, the requesting agency must provide a written "Authorized Purpose" statement and sign a data-sharing agreement affirming they will not share the data further with federal or out-of- state entities.
f. The ALPR Administrator shall conduct a monthly audit of the ALPR System to ensure proper oversight into the use of the system and adherence to this Policy, including compliance with applicable privacy laws (Civil Civil Code § 1798.90.51 (b)(2)(C)). The audit will include review of system usage and data sharing agreements to confirm compliance and identify any unauthorized access and/or usage.
g. The ALPR Administrators shall advise the Chief of Police of their findings from the monthly audits.
h. SPPD will maintain a public ALPR Transparency Portal to share usage statistics and audit results.
Unauthorized access or sharing ofALPR data is a violation of SPPD policy and may result in disciplinary action, up to and including termination, and subject the violator to civil and criminal penalties.
429.7 POLICY
The policy of the SPPD is to utilize ALPR technology to capture and store digital license plate data and images while recognizing the established privacy rights of the public. All data and images gathered by the ALPR System are for the official use of the SPPD and 5 292
owned by the city of South Pasadena. Because such data may contain confidential information, it is not open to public review.
429.8 TRAINING
The Training Sergeant shall ensure that all SPPD personnel receive SPPD-approved training for those authorized to use or access the ALPR system. a. No SPPD personnel shall access theALPR System, including the Data, without completing SPPD-approved training that specifically covers privacy rights, state law compliance (SB 34 and SB 54), and the technical operation of the ALPR System. (Civil Code § 1798.90.51; Civil Code § 1798.90.53). b. SPPD authorized users shall receive the training described herein prior to having access to theALPR System and thereafter on an annual basis. c. The ALPR Administrator shall keep training logs to ensure adherence to these provisions.
d. Access to the ALPR System will be automatically suspended for any accounts inactive for 12 months. All users must undergo annual policy review and recertifi cation.
429.9 RELEASING ALPR DATA
The ALPR data may be shared only with other law enforcement or prosecutorial agencies for official law enforcement purposes or as otherwise permitted by law, using the following procedures in compliance with SPPD policy, Civil Code § 1798.90.55, and a signed interagency agreement:
The law enforcement agency's request for access to SPPD'sALPR data shall include:
a. The name of the agency.
b. The name of the person requesting.
c. The offense type
d. The case number associated with the request
The request is reviewed by the ALPR Administrator and approved before the request is fulfilled. The approval request and logging of search queries will be maintained in the ALPR System for audit purposes.
Requests forALPR data by non-law enforcement or non-prosecutorial agencies (Public Records Act requests) will be processed as provided in the Records Maintenance and Release Policy (Civil Code § 1798.90.55).
429.9.1 THIRD PARTY SHARING - CALIFORNIA PUBLIC AGENCIES In accordance with Civil Code Section 1798.90.55(b) and California Department of Justice Bulletin 2023-DLE-06, SPPD may share its ALPR Data with another public agency, and only as otherwise permitted by law. A public agency, however, is limited 6 293
to California state or local agencies, including law enforcement agencies (collectively "California Agency or Agencies"). This occurs through a third-party vendor hosting platform.
Accordingly, SPPD shall only share ALPR Data with other California Agencies that have executed an interagency data sharing agreement with SPPD ("Data Sharing Agreement"). Any California Agency that requests access to SPPD ALPR Data must submit a request to the ALPR Administrator, which shall include an "authorized purpose" statement as to why the California Agency seeks access to ensure access is for legitimate law enforcement purposes.
If approved by the Chief of Police or ALPR Administrator, the California Agency shall be required to execute SPPD's Data Sharing Agreement. The Data Sharing Agreement shall require compliance with all applicable California laws with respect to the Data, including that the California Agency shall not share Data with private entities or out-of- state or federal agencies, including out-of-state and federal law enforcement agencies, in accordance with Senate Bill 34. The Data Sharing Agreement shall also require compliance with the prohibited uses provisions of this Policy. SPPD shall reserve the right to restrict or revoke access for noncompliance.
A copy of the Data Sharing Agreement shall be retained by the ALPR Administrator. 429.9 ALIGNMENT WITH STATE LAW
This Policy 429 aligns with Civil Code Section 1798.90.5, et. seq., with the guidance promulgated from the California Attorney General, as set forth in Bulletin 2023-DLE-06 (California Automated License Plate Reader Data Guidance) and Bulletin 2023-01-CJIS (Updated California Values Act's Database Guidance).
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Attachment No. 2
Flock Safety Inc. Contracts: Termination Projections
The tables below provide a breakdown of one-time early termination costs and reimbursement amounts based on potential cancellation dates:
2022 Contract (General Fund - 13 cameras) - Renewal Date - 03/30/2027 Termination Costs
Termination of convenience fee
(camera removal fee)
$500
Total $6,500(500x13)
Contract Term Fee/annually \ $39,000
Amount to be refunded for
unused service (pro-rated per
day)
$106.85
Potential contract termination
date: 05/1/2026 06/1/2026 07/1/2026 08/1/2026 09/1/2026 Amount to be refunded for
unused service, if contract is
terminated: $35,581.05 $32,267.70 $29,063.20 $25,750.85 $22,438.50 2024 Contract (UASI 2021-
(extended to 04/19/2026)
Termination Costs
14 cameras) - Original Renewal Date - 03/19/2026
Termination of convenience fee
(camera removal fee)
$500
Total $7,000 (500 x 14)
Contract Term Fee/annually \ $42,000
Amount to be refunded for
unused service (pro-rated per
day)
$115.07
Potential contract termination
date: 05/1/2026 06/1/2026 07/1/2026 08/1/2026 09/1/2026 Amount to be refunded for
unused service, if contract is
extended and terminated at a
later date:
$37,052.54 $33,485.37 $30,033.27 $26,466.10 $22,898.93
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Policy
462
Pasadena Police Department
Policy Manual
Automated License Plate Readers (ALPRs)
462.1 PURPOSE AND SCOPE
The purpose of this policy is to provide guidance for the capture, storage and use of digital data obtained through the use of Automated License Plate Reader (ALPR) technology. 462.2 POLICY
The policy of the Pasadena Police Department is to utilize ALPR technology to capture and store digital license plate data and images while recognizing the established privacy rights of the public.
All data and images gathered by the ALPR are for the official use of this department. Because such data may contain confidential information, it is not open to public review. 462.3 ADMINISTRATION
The ALPR technology, also known as License Plate Recognition (LPR), allows for the automated detection of license plates. It is used by the Pasadena Police Department to convert data associated with vehicle license plates for official law enforcement purposes, including identifying stolen or wanted vehicles, stolen license plates and missing persons. It may also be used to gather information related to active warrants, homeland security, electronic surveillance, suspect interdiction and stolen property recovery.
All installation and maintenance ofALPR equipment, as well as ALPR data retention and access, shall be managed by the Executive Administrator of the Strategic Services Division. The Executive Administrator of the Strategic Services will assign members under his/her command to administer the day-to-day operation of the ALPR equipment and data. 462.3.1 ALPR ADMINISTRATOR
The Executive Administrator of the Strategic Services Division shall be responsible for developing guidelines and procedures to comply with the requirements of Civil Code § 1798.90.5etseq. This includes, but is not limited to (Civil Code § 1798.90.51; Civil Code § 1798.90.53):
(a) A description of the job title or other designation of the members and independent contractors who are authorized to use or access the ALPR system or to collect ALPR information.
(b) Training requirements for authorized users.
(c) A description of how the ALPR system will be monitored to ensure the security of the information and compliance with applicable privacy laws. (d) Procedures for system operators to maintain records of access in compliance with Civil Code §1798.90.52.
(e) The title and name of the current designee in overseeing the ALPR operation. (f) Working with the City's Department of Information Technology (Dolt) and the Custodian of Records on the retention and destruction ofALPR data.
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456
Pasadena Police Department
Policy Manual
Automated License Plate Readers (ALPRs)
(g) Ensuring this policy and related procedures are conspicuously posted on the department's website.
462.4 OPERATIONS
Use of an ALPR is restricted to the purposes outlined below. Department members shall not use, or allow others to use the equipment or database records for any unauthorized purpose (Civil Code § 1798.90.51; Civil Code § 1798.90.53).
(a) An ALPR shall only be used for official law enforcement business. (b) An ALPR may be used in conjunction with any routine patrol operation or criminal investigation. Reasonable suspicion or probable cause is not required before using anALPR.
(c) While an ALPR may be used to canvass license plates around any crime scene, particular consideration should be given to using ALPR-equipped cars to canvass areas around homicides, shootings and other major incidents. Partial license plates reported during major crimes should be entered into the ALPR system in an attempt to identify suspect vehicles.
(d) No member of this department shall operate ALPR equipment or access ALPR data without first completing department-approved training.
(e) No ALPR operator may access department, state or federal data unless otherwise authorized to do so.
(f) If practicable, the officer should verify an ALPR response through the California Law Enforcement Telecommunications System (CLETS) before taking enforcement action that is based solely on an ALPR alert.
462.4.1 VOLUNTEER OPERATORS OF ALPR
(a) Selected CAPP Volunteers will be authorized to drive and use an ALPR equipped volunteer vehicle for information gathering purposes only.
1. ALPR certified volunteers will be selected by the Volunteer Coordinator and approved by the Chief of Police or his/her designee.
2. ALPR certified volunteers will be trained regarding the use and procedures associated with driving the vehicle equipped with an ALPR.
3. Volunteers are not to access any information other than the normal scanning operation of the ALPR.
462.5 DATA COLLECTION AND RETENTION
The Executive Administrator of the Strategic Services is responsible for ensuring systems and processes are in place for the proper collection and retention ofALPR data. Data will be transferred from vehicles to the designated storage in accordance with department procedures.
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457
Pasadena Police Department
Policy Manual
Automated License Plate Readers (ALPRs)
All ALPR data downloaded to the server should be stored for a minimum of two years in accordance with the City's established records retention schedule. Thereafter, ALPR data will be purged. Any ALPR data related to evidence in a criminal or civil action or data that is subject to a discovery request or other lawful action should be downloaded from the server onto portable media and booked into evidence.
462.6 ACCOUNTABILITY
All data will be closely safeguarded and protected by both procedural and technological means.
The Pasadena Police Department will observe the following safeguards regarding access to and use of stored data (Civil Code § 1798.90.51; Civil Code § 1798.90.53):
(a) All ALPR data downloaded to the mobile workstation and in storage shall be accessible only through a login/password-protected system capable of documenting all access of information by name, date and time (Civil Code § 1798.90.52). (b) Members approved to access ALPR data under these guidelines are permitted to access the data for legitimate law enforcement purposes only, such as when the data relate to a specific criminal investigation or department-related civil or administrative action.
(c) ALPR system audits should be conducted on a regular basis.
For security or data breaches, see the Records Release and Maintenance Policy. 462.7 RELEASING ALPR DATA
The ALPR data may be shared only with other law enforcement or prosecutorial agencies for official law enforcement purposes or as otherwise permitted by law by emailing the internal pd_cau group. Requests must be made utilizing a government recognized email account. Agencies requesting ALPR data shall include the following in thier request:
(a) The agency makes an email request for the ALPR data that includes:
1. The name of the agency.
2. The name of the person requesting.
3. The intended purpose of obtaining the information and case number. (b) The request should be reviewed by the Technical Services Administrator or the authorized designee and approved before the request is fulfilled. (c) The approved request is retained on file.
Requests forALPR data by non-law enforcement or non-prosecutorial agencies will be processed as provided in the Records Maintenance and Release Policy (Civil Code § 1798.90.55). 462.8 TRAINING
The Training Coordinator should ensure that members receive department-approved training for those authorized to use or access the ALPR system (Civil Code § 1798.90.51; Civil Code § 1798.90.53).
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Pasadena Police Department
Policy Manual
Automated License Plate Readers (ALPRs)
462.9 REFERENCE
See PPD Procedure Manual 462p.
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459
Sabha, Tamer
From:
Sent:
To:
Subject:
Margaret Starbuck <
Tuesday, March 17, 2026 10:18 PM
Sabha, Tamer
3/18/26 Public Safety Committee Public Comment
You don't often get email from. Learn why this is important [ l ] CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content is safe. Report phish using the Phish Alert Button. For more information about the Phish Alert Button view article "KB0011474" on the DolT portal.
Dear Public Safety Committee Members,
I am emailing you regarding the Pasadena PD Flock License Plate Reader Camera Audit presentation taking place tomorrow, March 18th, at the Public Safety Committee meeting. I urge you to oppose further Flock camera expansion in Pasadena and to cancel the city's existing contract with Flock.
When the license plate reader contract was initially made several years ago I opposed it because these kinds of technologies feed into the increased militarization and mass-expansion of policing-which always has adverse affects on Black and Brown communities-and because of the possibility of Flock data sharing with federal agencies. Those fears have now become reality.
Flock's cameras are Al-powered mass surveillance tools and the data they collect goes into a nationally searchable database that can and has been accessed by federal agencies like Customs and Border Protection. In this moment where the federal government is descending into authoritarianism; collecting and weaponizing US resident data; and actively surveilling, imprisoning, and killing US citizens, I do not want Pasadena resident data to be part of any kind of nationwide surveillance database.
Please cancel the Flock contract.
Sincerely,
Margaret Starbuck
District 5 Resident