Safety and Security Camera and Automated License Plate Reader Policy Copyrighted
August 7, 2023
City of Dubuque Action Items # 03.
City Council Meeting
ITEM TITLE: Safety and Security Camera and Automated License Plate Reader
Policy
SUM MARY: City Manager recommending City Council approve the updated policy on
City of Dubuque Traffic Camera use with the addition of Automated
License Plate Readers (APLR).
SUGGESTED Suggested Disposition: Receive and File;Approve
DISPOSITION:
ATTACHMENTS:
Description Type
MVM Memo City Manager Memo
Staff Memo final Staff Memo
Proposed Safety and Security Camera and Automated Supporting Documentation
License Plate Reader Policy
Current Safety and Security Camera Policy Supporting Documentation
Proposed Flock Safety Camera Locations Supporting Documentation
Flock Safety Presentation Supporting Documentation
Flock Safety Ethics and Innovation Paper Supporting Documentation
Flock Safety ALPR FAQs Supporting Documentation
Flock's response to common concerns Supporting Documentation
Flock's Response to ACLU Recommendations Supporting Documentation
Flock Customers Transparency Pages Supporting Documentation
International Association of Chiefs of Police LPR Supporting Documentation
Policy
International Associations of Chiefs of Police LPR Supporting Documentation
Paper
Dubuque
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TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Safety and Security Camera and Automated License Plate Reader Policy
DATE: August 2, 2023
Chief of Police Jeremy Jensen is recommending City Council approve the updated
policy on City of Dubuque Traffic Camera use with the addition of Automated License
Plate Readers (APLR).
I concur with the recommendation and respectfully request Mayor and City Council
approval.
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Mic ael C. Van Milligen
MCVM:sv
Attachment
cc: Crenna Brumwell, City Attorney
Cori Burbach, Assistant City Manager
Jeremy Jensen, Chief of Police
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Dubuque Law Enforcement Center
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E-mail: police@cityofdubuque.org
www.cityofdubuque.org
TO: Mike Van Milligen, City Manager
FROM: Jeremy Jensen, Chief of Police
SUBJECT: Safety and Security Camera and Automated License Plate Reader Policy
DATE: August 3, 2023
INTRODUCTION:
This memo is to present an updated policy on City of Dubuque Traffic Camera use with
the addition of Automated License Plate Readers (APLR).
BACKGROUND:
As part of the FY24 budget process, the City Council approved $73,000 ($58,000
recurring) for Automated License Plate Reader cameras (ALPR). However, approval
was contingent on the City Council first receiving more information and a policy. The
dollar amount was based upon a quote from Flock Safety to install 22 cameras and
implement their system, which included a network of other law enforcement agencies
using the Flock Safety camera system.
On May 1, 2023, myself and members of the Dubuque Police Department and the City
of Dubuque Engineering Department conducted a City Council work session on how the
current camera system is used and the staff time and input it takes to use the camera
system. This work session was held by the City Council at the Traffic Control Center in
City Hall.
On May 15, 2023, a representative of Flock Safety conducted a City Council work
session outlining how the Flock Safety ALPR cameras work, model policies, network
security, and transparency of the system.
DISCUSSION:
The purpose of proposing ALPR cameras was to automate safety and security
cameras. The ALPR's read license plates, then using that information, accesses the
lowa System maintained by the lowa Department of Transportation. The lowa System
controls the National Crime Information Center. Simply, the ALPR is identifying
wanted, stolen, or missing persons and property associated with a specific license plate.
The ALPR does this continuously, as where currently a person would have to watch
cameras continuously or the officer on the street would just happen to be in a specific
place at a specific time and know to check a license plate. The problem with this is that
an officer most likely would not know that that vehicle passing them was stolen out of
another jurisdiction, that a person in that vehicle was wanted on an arrest warrant, or
was a missing person/child.
The benefit of using the Flock Safety system is based upon several factors. First, the
system is all over the United States to include lowa, Wisconsin and Illinois. Flock
Safety cameras are currently installed in the following lowa cities and Tri-State
locations.
• Altoona PD
• Ankeny PD
• Urbandale PD
• Clive PD
� Council Bluffs PD
� Camanche PD
� Clinton PD
• West Des Moines PD
• Glenwood PD
• Carter Lake PD
• Polk County Conservation
• Waukee PD (recently approved)
• University of lowa Police
• Grant County, WI
• East Dubuque, IL PD
• Additional points between Dubuque and Chicago and Dubuque and Milwaukee
The system has proven to be highly ethical and feedback from law enforcement in these
cities have stated the system has been a highly effective tool. The use of the Flock
Safety system has the same requirements and regulations as an officer who accesses
the same data from their MCT in their squad car. This is the purpose of creating a
robust policy. Second, the Flock System is a network which allows agencies to
communicate the location of a vehicle that is associated with a crime or missing
person/child via their cameras. For example, a vehicle associated with a violent crime
in Dubuque leaves Dubuque immediately after the crime. The vehicle, if entered the
Flock System will trigger on any other Flock Camera. Third, by using another vendor,
this allows for redundancy in the current camera system. And finally, ALPR's are a
force multiplier. Potentially, the automation can significantly reduce the amount of hours
an officer or multiple officers spend at reviewing cameras to locate a wanted, stolen, or
missing person associated with a vehicle. Simply, it makes the officers more efficient.
The current Traffic Camera Policy was approved in 2014 and had not been updated
since then. City Attorney Crenna Brumwell, Traffic Engineer Dave Ness, and I reviewed
the current policy and added a section on ALPR use. Additionally, the current overall
policy was updated. A key component to the overall policy is adding a yearly review.
The ALPR section was drafted using language from other law enforcement agencies
that are CALEA accredited, best practice language from the International Association of
Chiefs of Police, State of lowa Policy on use of the lowa System which includes NCIC,
and best practices on transparency.
RECOMMENDATION:
The original quote from Flock Safety was to install 22 cameras. The locations are
attached. The locations were picked based upon high traffic areas, roadways in and out
of the city. It should be noted that if approved, the number of cameras and locations
will have to be renegotiated as the cost of the system has gone up. The
recommendation will be to review the policy and approve the policy as well as approve
the use of the funding.
ACTION REQUESTED:
I am requesting approval of the policy and use of the approved funding.
CITY OF DUBUQUE
ADMINISTRATIVE POLICY
POLICY NUMBER: 5.05
SUBJECT: SAFETY AND SECURITY CAMERA ACCEPTABLE USE
POLICY
APPROVED BY: CITY MANAGER
EFFECTIVE DATE: August 7, 2023
PURPOSE
The City of Dubuque is committed to enhancing the quality of life of the members of the
community by integrating the best practices of safety and security with technology. A
critical component of a comprehensive security plan is the utilization of a security and
safety camera system. The surveillance of public areas is intended to deter crime and
assist in protecting the safety and property of the Dubuque community. This policy
addresses the City's safety and security needs while respecting and preserving individual
privacy.
To ensure the protection of individual privacy rights in accordance with the City's core
values and state and federal laws, this policy is adopted to formalize procedures for the
installation of surveillance equipment and the handling, viewing, retention, dissemination,
and destruction of surveillance records. The purpose of this policy is
to regulate the use of camera systems used to observe and record public areas for the
purposes of safety and security. The existence of this policy does not imply or guarantee
that cameras will be monitored in real time 24 hours a day, seven days a week.
SCOPE
This AP applies to all departments under the administrative control of the City Manager.
RESPONSIBILITY
Department Managers are responsible for making sure that the provisions of this AP are
adhered to.
POLICY
The City of Dubuque has the authority to select, coordinate, operate, manage, and
Policy Number: 5.05 Safety and Security Camera Acceptable Use Policy Page 2 of 9
monitor all City security surveillance systems pursuant to this policy. All departments
using camera surveillance are responsible for implementing and complying with this
policy in their respective operations.
RESPONSIBILITIES
The Dubuque Police Department, Information Services, Engineering, Leisure Services,
Parking Division and the City Manager's Office are responsible for realization and
assimilation of the policy.
Information Services, Engineering and the Dubuque Police Department are responsible
for advising departments on appropriate applications of surveillance technologies and for
providing technical assistance to departments preparing proposals for the purchase and
installation of security camera systems.
The Dubuque Police Department, Information Services, Engineering and the City
Attorney's Office shall monitor developments in the law and in security industry practices
and technology to ensure that camera surveillance is consistent with the best practices
and complies with all federal and state laws.
The Dubuque Police Department, Information Services, Engineering and other City
Manager designees will assess new camera locations. Maintenance and testing will be
the responsibility of the department utilizing the camera system.
The Chief of Police will review any complaints regarding the utilization of surveillance
camera systems and determine whether this policy is being followed. Appeals of a
decision made by the Chief of Police will be made to the City Manager, who will render a
decision. An appeal of the City Manager's decision may be taken to the City Council.
General Responsibilities
The Chief of Police, Information Services, Engineering and other City Manager designees
will review proposals for camera installations and review specific camera locations to
determine that the perimeter of view of fixed location cameras conforms to this policy and
make recommendations to the City Manager.
Responsibilities of Public Information Officer Relations and City Attorney's Office
The City's Public Information Officer will review all external requests to release records
obtained through security camera surveillance, with consultation and advice from the City
Attorney's Office related to these requests prior to the release of any records.
General Principles
Information obtained from the cameras shall be used for safety and security purposes
and for law and policy enforcement, including, where appropriate, judicial functions.
Information must be handled with an appropriate level of security to protect against
Policy Number: 5.05 Safety and Security Camera Acceptable Use Policy Page 3 of 9
unauthorized access, alteration, or disclosure. All appropriate measures must be taken
to protect an individual's right to privacy and hold City information securely through its
creation, storage, transmission, use, and deletion.
All camera installations are subject to federal and state laws. Departments requesting
security cameras will be required to follow the procedures outlined in this policy.
Camera Placement Criteria
This policy applies to all personnel, and departments of the City of Dubuque in the use of
security cameras and their video monitoring and recording systems. Security cameras
may be installed in situations and places where the security and safety of either property
or persons would be enhanced. Cameras will be limited to uses that do not violate the
reasonable expectation of privacy as defined by law. Where appropriate, the cameras
may be placed citywide, inside and outside buildings. Although the physical cameras may
be identical, the functions of these cameras fall into four (4) main categories:
A. Property Protection: Where the main intent is to capture video and store it so that if
property is reported stolen or damaged, the video may show the perpetrator. Examples:
an unstaffed building or a parking lot.
B. Personal Safety: Where the main intent is to capture video and store it so that if a
person is assaulted, the video may show the perpetrator. Examples: a public walkway, or
a parking lot.
C. Extended Responsibility: Where the main intent is to have the live video stream in
one area monitored by a staff member in close proximity. In this case video may or may
not be recorded. Example: areas with limited staff.
D. Assist City Departments: Where the intent is to have live feed or capture video and
store it for purposes of process improvement (Ex. Traffic flow), infrastructure assessment
(Ex. Flooding), situational assessment (Ex. Flooding, pending criminal acts), or
investigations (Ex. Traffic accident criminal acts, or civil process).
The City of Dubuque will consider any of the following locations for placement of a
camera, including but not limited to:
• All City owned property, including but not limited to buildings, parks, hike/bike trails,
and parking lots; and any streets or alleys that intersect with said properties.
• In conjunction with the placement of a 911 kiosk
• Streets not designated as Local, i.e. street designations which include Collector,
Minor Arterial, or Arterial streets; and any streets or alleys that intersect with these
streets
• Other publicly owned spaces or facilities upon request, i.e. Dubuque Community
School District, Dubuque County; other institutional entities or areas for the public
good.
• Temporary cameras for special events
• Any other areas deemed appropriate by law enforcement or traffic safety personnel
Policy Number: 5.05 Safety and Security Camera Acceptable Use Policy Page 4 of 9
The locations where cameras are installed may be restricted access sites such as
departmental offices; however, these locations are not places where a person has a
reasonable expectation of privacy. Cameras will be located so that personal privacy is
maximized.
Camera positions and views of residential housing shall be limited. The view of a
residential housing facility must not violate the standard of a reasonable expectation of
privacy.
Unless the camera is being used for criminal investigations, monitoring by security
cameras in the following locations is prohibited:
• Bathrooms
• Locker rooms
• Offices
• Conference/meeting rooms
The installation of"dummy" cameras that do not operate is prohibited. Unless being used
for criminal investigations, all video camera installations should be visible.
Access and Monitoring
All recording or monitoring of activities of individuals or groups by City security cameras
will be conducted in a manner consistent with City policies, state and federal laws, and
will not be based on the subjects' personal characteristics, including age, color, disability,
gender, national origin, race, religion, sexual orientation, or other protected
characteristics. Furthermore, all recording or monitoring will be conducted in a
professional, ethical, and legal manner. All personnel with access to City security
cameras should be trained in the effective, legal, and ethical use of monitoring equipment.
City security cameras are not generally monitored continuously under normal operating
conditions but may be monitored for legitimate safety and security purposes.
For Property Protection and Personal Safety cameras, access to live video or recorded
video from cameras shall be limited to authorized personnel of the department which
installed the cameras, the Police Department and other persons authorized by the Chief
of Police or designee. The copying, duplicating and/or retransmission of live or recorded
video shall be limited to persons authorized by the Chief of Police or designee. A record
log will be kept of all instances of access to, and use of, recorded material. Nothing in this
section is intended to limit the authority of the Dubuque Police Department in law
enforcement activities.
Policy Number: 5.05 Safety and Security Camera Acceptable Use Policy Page 5 of 9
Appropriate Use and Confidentiality
Personnel are prohibited from using or disseminating information acquired from City
security cameras except for official purposes. All information and/or observations made
in the use of security cameras are considered confidential and can only be used for official
City and law enforcement purposes.
Personnel are also expected to know and follow all City of Dubuque Administrative
Policies, including but not limited to those associated with technology: 2.07 Internet and
Electronic Mail; 2.13 Acquisition and Use of Cellular Telephone Equipment; 2.19 IT and
Internet Appropriate Use; 2.20 Social Networking, Acceptable Use and Administration of
Computer and Communication Systems.
Use of Cameras for Criminal Investigations
The use of mobile or hidden video equipment may be used in criminal investigations by
the Dubuque Police Department. Covert video equipment may also be used for non-
criminal investigations of specific instances which may be a significant risk to public
safety, security and property as authorized by the Chief of Police or designee.
Excluded Camera Uses
This policy does not address the use of the following:
• Webcams for general use by the City (e.g., remote meetings).
• Video equipment for the recording of public perFormances or events, interviews, or
other use for broadcast or educational purposes.
• Cameras mounted in vehicles, including police and fire vehicles.
• Body worn cameras worn by City personnel engaged in enforcement activities.
• Cameras primarily used for traffic engineering and traffic control. However, these
cameras may have an incidental or ancillary use as security cameras for criminal
investigations.
Procedures
Departments requesting security cameras will be required to follow the procedures
outlined in this policy.
Installation
Individual departments installing video surveillance equipment shall submit a written
request to their appropriate department manager describing the proposed location of
Policy Number: 5.05 Safety and Security Camera Acceptable Use Policy Page 6 of 9
surveillance devices, justifying the proposed installation, and identifying the funding
source or sources for purchase and ongoing maintenance.
The department manager or designee will review the request and recommend it to the
Chief of Police and Information Services, if appropriate.
The Chief of Police and/or Information Services will review all proposals from department
manager. Upon completion of review of the project, the Chief of Police and/or Information
Services will forward the proposal to the City Manager with a recommendation.
The City Manager will be responsible for reviewing and approving or denying all proposals
for security camera equipment recommended by the Chief of Police. Information Services
shall oversee the installation of all approved security camera systems with the assistance
of the Police Department, and other City departments as required. Purchasing will not
accept, approve, or process any order for security camera systems without the approval
of the City Manager.
Training
Camera control operators shall be trained in the technical, legal, and ethical parameters
of appropriate camera use. Camera control operators shall receive a copy of this policy
and provide written acknowledgement that they have read and understood its contents.
Operation
Video surveillance will be conducted in a manner consistent with all existing City policies.
Camera control operators shall monitor based on suspicious behavior, not individual
characteristics.
Camera control operators shall not view private rooms or areas through windows.
All operators and supervisors involved in video surveillance will perform their duties in
accordance with this policy.
Storage and Retention of Recordings
No attempt shall be made to alter any part of any surveillance recording. Surveillance
centers and monitors will be configured to prevent camera operators from tampering with
or duplicating recorded information.
Surveillance records shall not be stored by individual departments. All surveillance
records shall be stored in a secure City centralized location for a period of approximately
30 days and will then promptly be erased or written over, unless retained as part of a
criminal investigation or court proceedings (criminal or civil), or other bona fide use as
approved by the City Manager or designee. Individual departments shall not store video
surveillance recordings. A log shall be maintained of all instances of access to or use of
surveillance records. The log shall include the date and identification of the person or
persons to whom access was granted.
Policy Number: 5.05 Safety and Security Camera Acceptable Use Policy Page 7 of 9
Fees
Individual City departments will establish policies and/or procedures for dissemination,
and fee schedules for reproduction of City video.
Automated License Plate Readers (ALPRs)
Purpose and Scope
Automated License Plate Reader (ALPR) technology provides automated detection of
license plates. ALPRs are used by the Dubuque 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. ALPR's
may be used to gather information related to active warrants, homeland security, suspect
interdiction, stolen property, and other crimes.
Administration
The Chief of Police or designee shall be responsible for overseeing the installation and
maintenance of APLR equipment, as well as ALPR data retention and access. This will
include any contractors authorized to install and maintain the system. ALPR systems
repair, hardware, or software, shall be made by agency authorized sources.
Operation
Department personnel shall not use or allow others to use the equipment or database for
any unauthorized purpose.
• An ALPR shall only be used for official and legitimate law enforcement business.
• 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 an ALPR.
• Prohibited uses include immigration enforcement, traffic enforcement, harassment
or intimidation, usage based solely on a protected class, or personal use.
• No member of the Dubuque Police Department shall operate the ALPR equipment
or access the ALPR date without first completing Department training.
• No member of the Dubuque Police Department may access data from the IOWA
system maintained by the lowa Department of Transportation, the National Crime
Information Center (NCIC), and from other motor vehicle departments of other
states through the National Law Enforcement Telecommunications System
(NLETS) or International Information through interfaces with the Canadian Police
Information Centre and INTERPOL, without first receiving certification through the
IOWA system.
• If practicable, the officer shall verify an ALPR response through the IOWA system
before taking enforcement action that is based solely on an ALPR alert.
Policy Number: 5.05 Safety and Security Camera Acceptable Use Policy Page 8 of 9
Additionally, the officer shall visually verify that the license plate and vehicle
identifiers match the alert.
• Placement of the camera systems will be determined as with other camera
placement
ALPR Data Collection and Retention
All data and images gathered by an ALPR are for the official use of the Dubuque Police
Department and because the data may contain confidential information that is provided
through the IOWA system which includes NLETS, NCIC, Canadian Police Information
Centre and INTERPOL, the information is not open for the public view. ALPR information
gathered and retained by the Dubuque Police Department may be used and shared with
prosecutors or others only as permitted by law.
Data collected by the ALPR system shall be retained for a period to not exceed 30 days,
unless the data has been identified as part of a criminal investigation.
Accountability and Safeguards
The Dubuque Police Department will observe the following safeguards regarding access
to and use of stored data:
• All requests for access to stored data shall be processed in accordance with
applicable law.
• All ALPR data downloaded to the operator workstation and server shall be
accessible only through a login/password protected system capable of
documenting all access of information by name, date and time.
• Persons approved to access ALPR data under these guidelines are permitted to
access the data for legitimate law enforcement purposes only, such as when data
relates to a criminal investigation or department related action.
• All ALPR data queries must be accompanied by the law enforcement case number
corresponding with the investigation. Without a case number entered, the system
will not allow a query of the data. This does not include NCIC alerts received
unless law enforcement action is taken.
• ALPR data may be released to other authorized and verified law enforcement
officials and agencies for legitimate law enforcement purposes.
• ALPR system audits should be conducted on a regular basis by the ALPR
Administrator with the system vendor.
• Queries that are not covered under the IOWA system requirements shall not be
made into the system without Supervisor approval.
Policy Number: 5.05 Safety and Security Camera Acceptable Use Policy Page 9 of 9
Log of use required.
• The Dubuque Police Department shall maintain a public log of its use, including
but not limited to:
o specific times of day that any readers actively collected data;
o the aggregate number of vehicles or license plates on which data are
collected for each period of active use and a list of all state and federal
databases with which the data were compared, unless the existence of the
database itself is not public;
o for each period of active use, the number of vehicles or license plates in
each of the following categories where the data identify a vehicle or license
plate that has been stolen, a warrant for the arrest of the owner of the
vehicle or an owner with a suspended or revoked driver's license or similar
category, or are active investigative data; and
o for any readers at a stationary or fixed location, the location at which the
readers actively collected data and is installed and used.
• The Dubuque Police Department shall maintain a list of the current and previous
locations, including dates at those locations, of any fixed stationary automated
license plate readers or other surveillance devices with automated license plate
reader capability used by the Department. The Department's list shall be
accessible to the public on its website, unless the agency determines that the data
is confidential information as provided in lowa Code 22.7.
• The log of use shall be updated on the Department website monthly.
Policy Review
This policy shall be reviewed by the Police Department, Engineering, Information
Services, the City Attorney's Office and the City Manager on an annual basis.
Michael C. Van Milligen, City Manager
CITY OF DUBUQUE
ADMINISTRATIVE POLICY
POLICY NUMBER : 5 . 05 ,:
SUBJECT : SAFETY AND SECURITY CAMERA ACCEPTABLE USE
POLICY
APPROVED BY : CITY MANAGER
EFFECTIVE DATE : February 3 , 2014
PURPOSE
;!
The City of Dubuque is committed to enhancing the quality of life of the members of the
community by integrating the best practices of safety and security with technology . A
critical component of a comprehensive security plan is the utilization of a security and
safety camera system . The surveillance of public areas is intended to deter crime and
assist in protecting the safety and property of the Dubuque community . This policy i,
addresses the City' s safety and security needs while respecting and preserving
individual privacy .
To ensure the rotection o ' ' ' I
f individual rivac ri hts in accordance with the Cit s core
p p Y g Y
values and state and federal laws , this policy is adopted to formalize procedures for the I�
installation of surveillance equipment and the handling , viewing , retention ,
dissemination , and destruction of surveillance records . The purpose of this policy is �I
to regulate the use of camera systems used to observe and record public areas for the
purposes of safety and security . The existence of this policy does not imply or
guarantee that cameras will be monitored in real time 24 hours a day , seven days a
week .
SCOPE
This AP applies to all departments under the administrative control of the City Manager .
RESPONSIBILITY
,,
Department Managers are responsible for making sure that the provisions of this AP are
adhered to .
POLICY
The City of Dubuque has the authority to select , coordinate , operate , manage , and
Policy Number: 5 . 05 Safety and Security Camera Acceptable Use Policy Page 2 of 7
monitor all City security surveillance systems pursuant to this policy . All departments
using camera surveillance are responsible for implementing and complying with this
policy in their respective operations .
RESPONSIBILITIES
The Dubuque Police Department , Information Services , Engineering , Leisure Services ,
Parking Division and the City Manager' s Office are responsible for realization and
assimilation of the policy .
Information Services and the Dubuque Police Department are responsible for advising
departments on appropriate applications of surveillance technologies and for providing
technical assistance to departments preparing proposals for the purchase and
installation of security camera systems .
The Dubuque Police Department , Information Services and the City Attorney' s Office
shall monitor developments in the law and in security industry practices and technology
to ensure that camera surveillance is consistent with the best practices and complies
with all federal and state laws .
The Dubuque Police Department , Information Services , and other City Manager
designees will assess new camera locations . Maintenance and testing will be the
responsibility of the department utilizing the camera system .
The Chief of Police will review any complaints regarding the utilization of surveillance
camera systems and determine whether this policy is being followed . Appeals of a
decision made by the Chief of Police will be made to the City Manager , who will render
a decision . An appeal of the City Manager' s decision may be taken to the City Council .
General Responsibilities
The Chief of Police , Information Services and other City Manager designees will review
proposals for camera installations and review specific camera locations to determine
that the perimeter of view of fixed location cameras conforms to this policy and make
recommendations to the City Manager.
Responsibilities of Public Information Officer Relations and City Attorney' s Office
The City' s Public Information Officer will review all external requests to release records
obtained through security camera surveillance , with consultation and advice from the
City Attorney' s Office related to these requests prior to the release of any records .
General Principles
Information obtained from the cameras shall be used for safety and security purposes
and for law and policy enforcement , including , where appropriate , judicial functions .
Information must be handled with an appropriate level of security to protect against
Policy Number: 5 . 05 Safety and Security Camera Acceptable Use Polic Pa e 3 of 7
Y J
unauthorized access , alteration , or disclosure . All appropriate measures must be taken
to protect an individuaPs right to privacy and hold City information securely through its
creation , storage , transmission , use , and deletion . i
All camera installations are subject to federal and state laws . Departments requesting
security cameras will be required to follow the procedures outlined in this policy . �
Camera Placement Criteria
,
This policy applies to all personnel , and departments of the City of Dubuque in the use �
i
of security cameras and their video monitoring and recording systems . Security
cameras may be installed in situations and places where the security and safety of
either property or persons would be enhanced . Cameras will be limited to uses that do
not violate the reasonable expectation of privacy as defined by law . Where appropriate , '�
the cameras may be placed citywide , inside and outside buildings . Although the
physical cameras may be identical , the functions of these cameras fall into three main �:
categories :
A . Property Protection : Where the main intent is to capture video and store it so that if �;
property is reported stolen or damaged , the video may show the perpetrator. Examples :
an unstaffed building or a parking lot .
B . Personal Safety : Where the main intent is to capture video and store it so that if a
person is assaulted , the video may show the perpetrator. Examples : a public walkway ,
or a parking lot . ,
C . Extended Responsibility : Where the main intent is to have the live video stream in
one area monitored by a staff member in close proximity . In this case video may or may
not be recorded . Example : areas with limited staff. `
„'
The City of Dubuque will consider any of the following locations for placement of a �.
camera , including but not limited to : �
� All City owned property , including but not limited to buildings , parks , hike/bike �,
trails , and parking lots ; and any streets or alleys that intersect with said
properties .
• In conjunction with the placement of a 911 kiosk �
• Streets not designated as Local , i . e . street designations which include Collector ,
Minor Arterial , or Arterial streets ; and any streets or alleys that intersect with
these streets
• Areas of Non -Single Family Zoning
• Other publicly owned spaces or facilities upon request , i . e . Dubuque Community
School District , Dubuque County ; other institutional entities or areas for the public
good .
• Temporary cameras for special events
• Any other areas deemed appropriate by law enforcement or traffic safety
personnel
Policy Number: 5 .05 Safety and Security Camera Acceptable Use Policy Page 4 of 7
The locations where cameras are installed may be restricted access sites such as
departmental offices ; however , these locations are not places where a person has a
reasonable expectation of privacy . Cameras will be located so that personal privacy is
maximized .
Camera positions and views of residential housing shall be limited . The view of a
residential housing facility must not violate the standard of a reasonable expectation of
privacy .
Unless the camera is being used for criminal investigations , monitoring by security
cameras in the following locations is prohibited :
• Bathrooms
• Locker rooms
• Offices
• Conference/meeting rooms
The installation of "dummy" cameras that do not operate is prohibited . Unless being
used for criminal investigations , all video camera installations should be visible .
Access and Monitoring
All recording or monitoring of activities of individuals or groups by City security cameras
will be conducted in a manner consistent with City policies , state and federal laws , and
will not be based on the subjects ' personal characteristics , including age , color ,
disability , gender, national origin , race , religion , sexual orientation , or other protected
characteristics . Furthermore , all recording or monitoring will be conducted in a
professional , ethical , and legal manner. All personnel with access to City security
cameras should be trained in the efFective , legal , and ethical use of monitoring
equipment . City security cameras are not monitored continuously under normal
operating conditions but may be monitored for legitimate safety and security purposes
that include , but are not limited to , the following : high risk areas , restricted access
areas/locations , in response to an alarm , special events , and specific investigations
authorized by the Chief of Police or designee .
For Property Protection and Personal Safety cameras , access to live video or recorded
video from cameras shall be limited to authorized personnel of the department which
installed the cameras , the Police Department and other persons authorized by the Chief
of Police or designee . The copying , duplicating and /or retransmission of live or recorded
video shall be limited to persons authorized by the Chief of Police or designee . A
record log will be kept of all instances of access to , and use of, recorded material .
Nothing in this section is intended to limit the authority of the Dubuque Police
Department in law enforcement activities .
i"
Policy Number: 5 . 05 Safety and Security Camera Acceptable Use Policy Page 5 of 7
Appropriate Use and Confidentiality ,
Personnel are prohibited from using or disseminating information acquired from City
security cameras except for official purposes . All information and /or observations made
in the use of security cameras are considered confidential and can only be used for
official City and law enforcement purposes . 4
Personnel are also expected to know and follow all City of Dubuque Administrative
Policies , including but not limited to those associated with technology : 2 . 07 Internet and ;'
Electronic Mail ; 2 . 13 Acquisition and Use of Cellular Telephone Equipment ; 2 . 19 IT and I
Internet Appropriate Use ; 2 . 20 Social Networking , Acceptable Use and Administration of �
Computer and Communication Systems . I
Use of Cameras for Criminal Investigations 'r
The use of mobile or hidden video equipment may be used in criminal investigations by
the Dubuque Police Department . Covert video equipment may also be used for non -
criminal investigations of specific instances which may be a significant risk to public �
safety , security and property as authorized by the Chief of Police or designee .
Excluded Camera Uses
This policy does not address the use of the following :
• Webcams for eneral use b the Cit e . . remote mee in
9 Y Y � 9 , t gs) •
• Video e ui ment for the �
q p recording of public performances or events , interviews ,
or other use for broadcast or educational purposes .
• Cameras mounted in vehicles , including police and fire vehicles . ;
• ' Cameras primarily used for traffic engineering and traffic control . However, these
cameras may have an incidental or ancillary use as security cameras for criminal
investigations .
Procedures
Departments requesting security cameras will be required to follow the procedures
outlined in this policy .
Installation
Individual departments installing video surveillance equipment shall submit a written
request to their appropriate department manager describing the proposed location of
surveillance devices , justifying the proposed installation , and identifying the funding
source or sources for purchase and ongoing maintenance . I
Policy Number: 5 .05 Safety and Security Camera Acceptable Use Policy Page 6 of 7
The department manager or designee will review the request and recommend it to the
Chief of Police and Information Services , if appropriate .
The Chief of Police and /or Information Services will review all proposals from
department manager . Upon completion of review of the project , the Chief of Police
and/or Information Services will forward the proposal to the City Manager with a
recommendation .
The City Manager will be responsible for reviewing and approving or denying all
proposals for security camera equipment recommended by the Chief of Police .
Information Services shall oversee the installation of all approved security camera
systems with the assistance of the Police Department , and other City departments as
required . Purchasing will not accept , approve , or process any order for security camera
systems without the approval of the City Manager.
Training
Camera control operatorsshall be trained in the technical , legal , and ethical parameters
of appropriate camera use . Camera control operators shall receive a copy of this policy
and provide written acknowledgement that they have read and understood its contents .
Operation
Video surveillance will be conducted in a manner consistent with all existing City
policies . Camera control operators shall monitor based on suspicious behavior, not
individual characteristics .
Camera control operators shall not view private rooms or areas through windows .
All operators and supervisors involved in video surveillance will perForm their duties in
accordance with this policy .
Storage and Retention of Recordings
No attempt shall be made to alter any part of any surveillance recording . Surveillance
centers and monitors will be configured to prevent camera operators from tampering
with or duplicating recorded information .
Surveillance records shall not be stored by individual departments . All surveillance
records shall be stored in a secure City centralized location for a period of
approximately 30 days and will then promptly be erased or written over, unless retained
as part of a criminal investigation or court proceedings (criminal or civil ) , or other bona
fide use as approved by the City Manager or designee . Individual departments shall not
store video surveillance recordings . A log shall be maintained of all instances of access
to or use of surveillance records . The log shall include the date and identification of the
person or persons to whom access was granted .
Policy Number: 5 . 05 Safety and Security Camera Acceptable Use Policy Page 7 of 7
Fees
Individual City departments will establish policies and/or procedures for dissemination ,
and fee schedules for reproduction of City video . I
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What we observe:
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• Limited Police Resources • Technology multiples the force
• Crime is on the rise • Capture and distribute
objective evidence to the right
• Trust is needed more than user
ever
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and grow
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When you get Flock � ;� y , =
you get: �
objective, real-time and investigative leads � . • ' � ' '
• Vehicle Fingerprint T"" = license plate plus �� - -
• Indiscriminate evidence from fixed � • ' ' " �O� ' " '
locations �� , ,
• No people, no facial recognition, no traffic
enforcement
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What is this tech? What ISN'T this tech?
License plate recognition Not facial recognition
Gathers objective evidence and Not tied to PII
facts about vehicles, not people
Not used for traffic
Alerts police of wanted vehicles enforcement
Used to solve crime Data not stored beyond 30
days � automatica//y de%tes
Adheres to all state laws every30days
■
OW OeS t IS Proactive: Real Time Alerts when
technolo Stolen or Wanted Vehicles enter
gy your City
prevent and
el i m i nate cri me? Investigative: As clearance rates
increase, crime rates decrease
Flock cameras act as a deterrent
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Protecting Privacy
Footage owned by Agency/City and will All data is stored securely in the AWS
never by sold or shared by Flock Government Cloud, and end to end AES-
256 encryption of all data
30 day data retention, then deleted
Search reason is required for audit trail
Short retention period ensures that all data
not associated with a crime is NOT facial recognition software
automatically deleted & unrecoverable
NOT predictive policing
Takes human bias out of crime-solving by
detecting objective data, and detecting NO PII is contained in Flock
events that are objectively illegal (ex.
Stolen vehicles) NOT used for traffic enforcement
Not connected to registration data or 3rd
party databases (Carfax, DMV)
ITransparency Portal (optional)
Resources: ALPR Policy RENO POLfCE DEPARTMENT
Policy 3.00.005 Use of Automated License Plate Readers
Eff�c�ive DazE: 04,�3G/2o2u Replaces:N1A
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O tion 1
■ Option 2 I• POLICY
Ihe Reno Police Department has been authorized Dy the Reno City
Council to utilize Autamated I�icense Plate Readers {ALPR) to
■ 0 pt i o n 3 assist in providing safety co the res;dents of the City of Reno.
Ihis golicy zstab2ishes the use of F,LPR technaiogy.
II. PURPOSE
Ihe primary purpose of the Reno Police Depaxtment Aucomated
Licznse Plate Readers [ALPR} system ia to provide a cool for use
by Patrol and Crirninal Investiqations personnel. This too�
assist9 in tke detzction azd apprehen9ion of vehicles and/or
persons travzling throuqh the �urisdiction of the Reno Poiice
Department in a vehicle that has license plates shat have been
enter�d either into the National Crime Index Caiaputer or on the
Rena Police Deparr.ment ALPR Hotlist. The ALPR 9ystem can a190 be
utili�ed by RPD Detectiv-e9 to assist in the development of leads
that can eventualYy identify suspects ;�ho i:ave co:nmitted Cil'.IlE9
Hi�rin the Cizy.
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Measure ROI and promote the ethical use
of public safety technology
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Customizable for each agency ° ��`�'����� � �� � °�A`�"�����
Display technology policies o ""� '�„u , ; � �""` '°"°"'
Publish usage metrics ,
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It actuall solves and revents
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Widely Adopted in lowa/ State
Borders
• West Des Moines Douglas • Silvis, IL
• Altoona County, NE • Fulton, IL
• Council Bluffs Peoria, IL
• Urbandale East
• Camanche Dubuque, IL
• Clinton Rockford, IL
• Muscatine ( Chicago
Coming Soon) Metro Area
Urbandale PD Immediate
Success
II Urbandale PD Q Urbandale, IA
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Installed 13 cameras . � . � � ; _ ,
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Eight arrests within first month � • � �
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Assisted police in finding a wanted suspect
with outstanding warrants in their city.
Case Study: Smash & Grab Robbery
� San Bruno PD Q San Bruno, CA
. - - .
. . . - .
January 2022 - Five suspects attempt a
Smash & Grab at a Jewelry store but are . �� , w
chased off by the owner � i
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But here's what didn't make the news... '�" w, ��r F
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Suspect vehicle identified using Flock � -
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SBPD thought the suspects would try again, _ r � `
potentially more violently .y �
Vehicle placed on a custom hotlist
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SBPD receives a real time alert that the - — �
suspects are returning
Officers locate the vehicle within seconds
preventing another attempt
CASE STUDY AmberA/ert When every second matters,
Flock Safety's Machine Vision
II CPD Q Chamblee, Geor , , ,
is Critical
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� ,�,i;�� �� 12:33 PM � Amber Alert Issued
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Stranger on Stranger Abduction 6:00 PM O Baby Reunited with Mother
August 28, 2020
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Solar & Electric & Solar & Solar & Traffic
Existing Pole Existing Flock Pole Pole
Structure / Pole
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Questions
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Ethics + Innovation
Privacv I Transparency � Accountabilitv
Footage owned by Public approval process and Investigative reason
Agency/City and will never by community education for required for search
sold or shared by Flock each customer
Flock system proactively
30 day data retention, then Flock's transparency portal provides audit report that
deleted. Short retention period tells your community how includes details of each
ensures that all data not law enforcement use the search in the customer's
associated with a crime is system, including how many network
automatically deleted & searches are conducted and
unrecoverable who data is shared with ALPR policy outlines how
NO personally identifiable the system is used
information is identifiable in
Flock
Not connected to registration
data or 3rd party databases
(Carfax, DMV)
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� � About Automat c ce se ate Readers
� �s �ALPR)
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`� ` The Problem: Violent Crime Is Not Going Away
� . . . . .
Nationwide, cities are experiencing a disturbing rise in homicides and violence. The
FBI's 2020 Crime Report shows a 30% increase in homicides from 2019 to 2020, the
largest single-year increase recorded.
Over two-thirds of the country's most populous cities saw even more homicides in 2021.
One Solution: Technoloqy that Detects Objective Evidence to Clear More Cases
Automated License Plate Readers (ALPR) capture computer-readable images of license
plates and vehicles, allowing officers to compare plate numbers against those of stolen
cars or wanted individuals on a crime database like the NCIC.
ALPR devices assist law enforcement in solving crime in two ways:
• Proactive - ALPR devices provide real-time alerts when a vehicle that is stolen or
associated with a known suspect is detected.
• Investigative - ALPR cameras help determine whether and which vehicle(s) were at
the scene of a crime.
Is ALPR effective ?
According to the National Conference of State Legislatures, when employed ethically
and objectively, ALPRs are an effective tool for law enforcement, cutting down on the
time required for investigations and acting as a force multiplier. In 2011, a study by the ,�,
Police Executive Research Forum concluded that ALPRs used by the Mesa, Ariz., Police
Department resulted in "nearly 3 times as many 'hits' for stolen vehicles, and twice as
many vehicle recoveries."
Communities with ALPR systems report crime reductions of up to 70 percent. In some �
areas, that included a 60 percent reduction in non-residential burglaries, 80 percent ..�,,., �
reduction in residential burglary, and a 40 percent reduction in robberies.
• . . ••
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�� ALPR Provides Objective Evidence While Protecting Privacy
�
,����' ALPR does not include facial recognition capabilities and does not capture personally
� identifiable information (PII). While eyewitnesses and individual officers are subject to
,� inherent human bias, ALPR cameras capture wholly-objective images of vehicles and
license plates, providing a clear and actionable investigative lead.
�`
i
ALPR Use Cases Include:
• AMBER Alerts: License plate readers in metro Atlanta were able to find a vehicle
containing a kidnapped one-year-old, who had been taken from his mother at
random off the street. The child was recovered unharmed. Some ALPR systems
integrate directly with the National Center for Missing and Exploited Children's
AMBER Alert system, sending real-time alerts to officers in seconds. [New
information released about 1-year-old's kidnapping]
• Silver Alerts: Knoxville Police were able to locate a missing elderly man who suffers
from dementia after he drove away in a family vehicle. ALPR technology has helped
solve hundreds of Silver Alerts across the country. [Missing man with dementia
found using Flock camera]
• Firearm violence: The Las Vegas Trail, a high-crime area in Fort Worth, TX, saw
violent crime decrease by 22% in 2021 compared with the first nine months of 2019.
Fort Worth Police attributed this drop partially to the license plate reader system
implemented in the neighborhood during the same period of time. [Crime is down
22% in Fort Worth's Las Vegas Trail. How neighbors and police made it safer]
• Organized theft: Grafton, a growing village with a bustling retail district, is dealing
with increased organized retail theft — Two-thirds of all the crimes reported to
Grafton police in 2020 were retail thefts. Grafton Police have implemented a license
plate reader system to identify vehicles that have been involved in thefts or have
,��
been stolen themselves. In one week alone, they recovered three stolen vehicles
,��
with drivers planning to engage in retail theft. [Losses mount as retailers fight theft
rings, accuse online storefronts of doing little to stop resale of stolen goods]
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� Short data retention & No sharing with 3rd parties
a. Data is by default stored for 30 days and then permanently
deleted, unless connected to an active investigation.
b. You own your data, and we never sell your data.
Public input and approval
a. City Council approval
FI o c k's res p o n s e b. Community town-halls
Transparent communication
a. Transparencyportal
to co m m o n b. Annual updates to City Council
co n ce rn s Slippery slope arguments
a. Democratic authorization, good ALPR policies, and community
engagement protects us and our customers from becoming what
we want to avoid.
Audits and accountability
a. Our system automatically requires a law enforcement reason to
search. These can be reported through the transparency portal.
6. Over-policing
a. Violent crime disproportionately affects the BIPOC community (8X
more likely to be a victim than white counterparts), and violent
crime has increased by more than 30% in the last 2 years.
b. Indiscriminate evidence. Unbiased, actionable leads
- - - - . • � ��r.. ... 1. ., .. � -^� ��r
Developing yourALPR policy
In the ACLU's reports on ALPR, they make recommendations for law enforcement who consider
using ALPR. Flock addressed each of these in our system design and implementation.
(1) Short data retention (4) Consult legal counsel
(a) Flock by default deletes the data every 30 (a) Flock welcomes conversations with legal counsel.
days, allowing a detective to use the footage
for investigative purposes (5) Open to public input and receive approval from
(b) Flock is among the shortest of all the state democratically elected governing bodies
statutes on data retention (a) Flock encourages all agencies to seek democratic
approval.
(2) No hot lists unless independently verified. (6) Operate in public and disclose use of ALPR
(a) The FBI curates NCIC hot list plates; the (a) Flock developed a transparency portal.
NIJ curates NAMUS; DOJ funds and
curates NCMEC. (7) Public audits and reports
(b) Most ALPR policies require hot list (a) Flock requires an investigative reason to search,
verification before action. and we provide an audit report to system
administrators.
(3) No data sharing with 3rd parties.
(a) Flock does not share with 3rd parties
Transparency
Highlight: Lexington,
KYLexington, Kentucky PD has robust Transparency Portal:
Easily understandable and divided into sections by
� LEXINGTON subject matter.
� �,��� � 1 � � Has a subsection dedicated to License Plate Readers
- - , � ;==,� • Video Archive of public approval process.
; . _ ,� ",�a, � I
�°' � � • License Plate Reader Policy
� ' • License Plate Reader Statistics ( Frequently
.:
` updated)
� • Audit Report
` �'�` � • Section on recovery of Stolen Vehicle Success
• FAQ Section
, i
Promote the ethical use of public safety
technology
Transparency Portal � "°„`"",°`°"". o �."..,���������.��
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Reference •;;; Special Instructions
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Distribution Reevaluation Date No. Pages
3
I. PURPOSE Hot list: License plate numbers of stolen cars,
The purpose of this policy is to provide officers vehicles owned by persons of interest, and vehicles
with guidelines on the proper use of license plate associated with AMBER Alerts that are regularly
recognition (LPR) systems, also commonly known as added to "hot lists" circulated among law enforcement
license plate reader systems. agencies. Hot list information can come from a variety
of sources,including stolen vehicle information from
II. POLICY the National Insurance Crime Bureau and the National
The availability and use of LPR systems have Crime Information Center(NCIC), as well as national
provided many opportunities for the enhancement of AMBER Alerts and Department of Homeland Security
productivity, effectiveness, and officer safety. It is the watch lists. Departments of motor vehicles can provide
policy of this agency that all members abide by the lists of expired registration tags, and law enforcement
guidelines set forth herein when using LPR systems. agencies can interface their own, locally compiled hot
lists to the LPR system. These lists serve an officer
III. DEFINITIONS safety function as well as an investigatory purpose.In
FOUO: For Official Use Only addition to agency supported hot lists, users may also
LPR: License Plate Recognition/License Plate manually add license plate numbers to hot lists in order
Reader to be alerted if and when a vehicle license plate of
OCR: Optical Character Recognition interest is "read"by the LPR system.
Read: Digital images of license plates and Fixed LPR system: LPR cameras that are
vehicles and associated metadata(e.g., date,time, and permanently affixed to a structure, such as a pole, a
geographic coordinates associated with the vehicle traffic barrier, or a bridge.
image capture) that are captured by the LPR system. Mobile LPR system: LPR cameras that are affixed,
Alert: A visual and/or auditory notice that is either permanently (hardwired) or temporarily (e.g.,
triggered when the LPR system receives a potential magnet-mounted), to a law enforcement vehicle for
"hit" on a license plate. mobile deployment.
Hit: A read matched to a plate that has previously Portable LPR system: LPR cameras that are
been registered on an agency's "hot list" of vehicle transportable and can be moved and deployed in a
plates related to stolen vehicles, wanted vehicles, variety of venues as needed, such as a traffic barrel or
or other factors supporting investigation, or which speed radar sign.
has been manually registered by a user for further
investigation.
1
IV. PROCEDURES C. License Plate Reader System Usage
A. General 1. LPR operation and access to LPR collected
1. The use of LPR systems is restricted to public data shall be for official agency purposes only.
safety—related missions of this agency. 2. Only officers who have been properly trained
2. LPR systems and associated equipment and in the use and operational protocols of the LPR
databases are authorized for official public systems shall be permitted to use it.
safety purposes. Misuse of this equipment and 3. At the start of each shift users must ensure
associated databases, or data, may be subject that the LPR system has been updated with the
to sanctions and/or disciplinary actions. most current hot lists available.
3. LPR systems and LPR data and associated 4. LPR Alerts/Hits: Prior to initiation of the stop:
media are the property of this agency and a. Visually verify that the vehicle plate num-
intended for use in conducting official business ber matches the plate number run by the
with limited exceptions noted elsewhere in this LPR system, including both alphanumeric
policy. characters of the license plate and the state
B. Administration of issuance.
1. The agency shall designate an employee(s) b. Verify the current status of the plate
with administrative oversight for LPR sys- through dispatch or MDT query when
tem deployment and operations who is (are) circumstances allow.
responsible for the following: 5. In each case in which an alert or a hit is trig-
a. Establishing protocols for access, collec- gered, the user should record the disposition of
tion, storage, and retention of LPR data the alert and the hit into the LPR system
and associated media files 6. Hot lists may be updated manually if the user
b. Establishing protocols to preserve and enters a specific plate into the LPR system and
document LPR reads and"alerts" or"hits" wants to be alerted when that plate is located.
that are acted on in the field or associated Whenever a plate is manually entered into the
with investigations or prosecutions LPR system, the officer should document the
c. Establishing protocols to establish and reason.
ensure the security and integrity of data 7. Special Details: LPR use during nontraditional
captured, stored, and/or retained by the deployments (e.g., special operations or during
LPR system a criminal investigation) must be approved by
d. Ensuring the proper selection of the per- the administrator.
sonnel approved to operate the LPR sys- 8. Searches of historical data within the LPR sys-
tem and maintaining an adequate number tem should be done in accordance with estab-
of trainees; lished departmental policies and procedures.
e. Maintaining records identifying approved D. LPR Data Sharing and Dissemination
LPR deployments and documenting their LPR data should be considered FOUO and can be
results, including appropriate documenta- shared for legitimate law enforcement purposes:
tion of significant incidents and arrests that 1. When LPR data are disseminated outside the
are related to LPR usage agency, it should be documented in a second-
f. Authorizing any requests for LPR systems ary dissemination log.
use or data access according to the policies 2. Information sharing among agencies should be
and guidelines of this agency dictated in accordance with MOUs (memoran-
2. Designated, trained personnel shall check da of understanding) or established departmen-
equipment on a regular basis to ensure func- tal policies.
tionality and camera alignment.Any equip- E. Retention
ment that falls outside expected functionaliry Please refer to the License Plate Reader Concepts
shall be removed from service until deficien- and Issues Paper for a discussion on retention.
cies have been corrected.
3. LPR systems repairs, hardware or software,
shall be made by agency authorized sources.
2
Acknowledgment
This document was developed by International As-
sociation of Chiefs of Police (IACP), Law Enforcement
Information Management(LEIM) Section,in cooperation
with the IACP National Law Enforcement Policy Center.
Additional support was provided by the LPR Model Policy
Working Group, to whom we are deeply appreciative for
sharing their agency policies and expertise.
Every effort has been made by the IACP National Law
Enforcement Policy Center staff and advisory board to
ensure that this document incorporates the most current
information and contemporary professional judgment on
this issue.However,law enforcement administrators should
be cautioned that no"model"policy can meet all the needs
of any given law enforcement agency.Each law enforcement
agency operates in a unique environment of federal court
rulings, state laws, local ordinances, regulations, judicial
and administrative decisions and collective bargaining
agreements that must be considered. In addition, the
formulation of specific agency policies must take into
account local political and community perspectives and
customs, prerogatives and demands; often divergent law
enforcement strategies and philosophies; and the impact of
varied agency resource capabilities among other factors.
This project was supported by a grant awarded by
the Bureau of Justice Assistance. The Bureau of Justice
Assistance is a component of the Office of Justice Programs,
which also includes the Bureau of Justice Statistics, the
National Institute of Justice, the Office of Juvenile Justice
and Delinquency Prevention,the Office for Victims of Crime,
and the Office of Sex Offender Sentencing, Monitoring,
Apprehending,Registering,and Tracking.Points of view or
opinions in this document are those of the author and do not
necessarily represent the official position ar policies of the
U.S.Department of Justice or the IACP.
IACP National Law Enfarcement Policy Center Staff:
Philip Lynn, Manager; Sara Dziejma, Project Specialist;
and Vincent Talucci, Executive Director, International
Association of Chiefs of Police.
O Copyright 2010.Departments are encouraged to use this policy
to establish one customized to their agency and jurisdiction.
However, copyright is held by the International Association of
Chiefs of Police, Alexandria, Virginia U.S.A. All rights reserved
under both international and Pan-American copyright conventions.
Further dissemination of this material is prohibited without prior
written consent of the copyright holder.
3
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I. INTRODUCTION �� • Read: Digital images of license plates and vehicles
and associated metadata(e.g., date, time, and geo-
A. Purpose of Document graphic coordinates associated with the vehicle im-
This paper is designed to accompany the Model Policy age capture)that are captured by the LPR system.
on License Plate Reader("LPR") Systems published by ' Alert: A visual and/or auditory notice that is trig-
the IACP Law Enforcement Information Management gered when the LPR system receives a"hit" on a
(LEIM) Section and the IACP National Law Enforcement license plate.
Policy Center. This paper provides essential background • Hit: A read matched to a plate that has previously
material and supporting documentation to provide greater been registered on an agency's "hot list" of vehicle
understanding of the developmental philosophy and plates related to stolen vehicles, wanted vehicles,
implementation requirements for the model policy.' It or other factors supporting investigation, or which
is anticipated that this material will be of value to law has been manually registered by a user for further
enforcement executives in their effarts to tailor an effective investigation.
LPR policy to meet their agencies strategic objectives and ' Hot list: License plate numbers of stolen cars,
operational requirements. vehicles owned by persons of interest, and ve-
hicles associated with AMBER Alerts that are
B. Acronyms and Definitions regularly added to "hot lists" circulated among law
The model policy provides a number of definitions that enforcement agencies. Hot list information can
are of particular importance including the terms "alert," come from a variery of sources,including stolen
"hit," "hot list," and"read" as well as differentiating vehicle information from the National Insurance
between the three categories of LPR systems; fixed, Crime Bureau and the National Crime Information
mobile, and portable. Given that the use of the system Center(NCIC), as well as national AMBER Alerts
may not be restricted to sworn personnel, the term"user" and Department of Homeland Security watch lists.
is employed throughout this document and the model Departments of motor vehicles can provide lists
LPR policy to refer to any individual who can access of expired registration tags, and law enforcement
infarmation and use the system. agencies can also interface their own,locally com-
• FOUO: For Official Use Only piled hot lists to the LPR system.These lists serve
• LPR: License Plate Recognition/License Plate an officer safety function as well as an investiga-
Reader tory purpose. In addition to agency supported hot
• OCR: Optical Character Recognition lists, users may also manually add license plate
numbers to hot lists in order to be alerted if and
when a vehicle license plate of interest is "read"by
' Much of the material far this LPR Concepts and Issues paper is the LPR System.
drawn from the Privacy Impact Assessment for the Iltilization of License
Plate Readers.
A publication of the IACP National Law Enforcement Policy Center
44 Canal Center Plaza, Suite 200,Alexandria,VA 22314
This document is the result of work perfarmed by the IACP National Law Enforcement Policy Center.The views and opinions expressed in this document are
sanctioned by the center's advisory board and do not necessarily represent the official position or policies of the Intemational Association of Chiefs of Police.
• Fixed LPR system: LPR cameras that are perma- when a license plate on the hot list is observed in real time;
nently affixed to a structure, such as a pole, a traffic this can be the case for both fixed and mobile LPR units.
barrier, or a bridge. Historical LPR data can also be searched to determine the
• Mobile LPR system: LPR cameras that are affixed, date and time a license plate number contained on a hot list
either permanently (hardwired) ar temporarily passed a certain camera.
(e.g., magnet-mounted), to a law enforcement vehi- The mode] LPR policy outlines general policies
cle for mobile deployment. specific to LPR systems deployment and operations, and
• Portable LPR system: LPR cameras that are notes that policies departments may already have in place
transportable and can be moved and deployed in a regarding information sharing and information technology
variety of venues as needed, such as a traffic barrel security protocols may be sufficient to address similar
or speed radar sign. concerns regarding LPR systems, though they may need to
C. Background be updated.
A fundamental element of policing is locating vehicles IL HOW LICENSE PLATE READERS
that are wanted because the vehicle is stolen, wanted in
connection with a crime, or driven by a subject who is T'UNCTI�N
wanted or suspected of committing a crime ar otherwise LPR systems consist of high-speed cameras combined
of interest to law enforcement. Patrol officers are with sophisticated computer algorithms capable of
frequently provided with written descriptions of vehicles converting the images of license plates into electronically
and/or license plates at the beginning of their shifts and readable data. Systems in existence as of the date of this
asked to be on the lookout for these vehicles, or they report are routinely capable of capturing multiple license
build these lists contemporaneously during their shifts in plate images per second on vehicles traveling at high
response to offenses that are reported and calls for service. speeds.�
Managing these paper lists—remembering or writing down
descriptions of vehicles and/or license plates and trying to A. LPR Operations
maintain a constant observation for vehicles of interest— An essential element of any LPR system is the camera
is difficult and time consuming. Investigators must rely hardware that captures the image of the license plates.The
upon witness statements to determine what areas a subject quality of the captured image lays the foundation far the
frequents and may be located. overall performance of the system. LPR systems typically
Automated license plate recognition(LPR) systems, utilize specialized cameras designed to capture images of
or license plate readers as they are commonly referred to, license plates, either from static positions or mobile patrol
play an increasingly important role in public safety by vehicles.
enhancing productivity, effectiveness, and officer safety. Factors that pose difficulty for license plate imaging
LPR systems are able to recognize,read, and compare cameras include the speed of the vehicles being recorded,
motor vehicle license plates against various "hot lists" the distance and the angle of the vehicles from the camera,
much more efficiently than officers manually scanning varying ambient lighting conditions, headlight glare, and
and making comparisons while on routine patrol. LPR harsh environmental conditions. In order to address these
systems can observe and record over 1,000 license plates difficulties, many LPR systems employ infrared cameras
an hour in various lighting and weather conditions. LPR operating in addition to visible light cameras.
cameras can be fixed, mobile, or portable.A fixed LPR unit The optica] character recognition (OCR) of images
is permanently mounted, usually to a bridge or a pole, and captured by LPR cameras is performed through the use of
frequently in a jurisdiction's most heavily traveled points of sophisticated algorithms. Six primary algorithms that LPR
ingress and egress. Mobile LPR units are mounted to law system software requires to identify a license plate include
enforcement agency vehicles and can capture data from • plate localization, which finds and isolates the plate
any area within an agency's jurisdiction. Portable LPR contained in the picture;
cameras can be moved from vehicle to vehicle or deployed • plate orientation and sizing, which compensates for
in covert configurations. the skew of the plate and adjusts the dimensions to
The license plate numbers of stolen cars, vehicles the appropriate size and shape;
owned by persons of interest, and vehicles associated with • normalization, which adjusts the brightness and
AMBER Alerts are routinely added to"hot lists" circulated contrast of the image;
among law enfarcement agencies. These lists serve an
OffiCeY Safety funCtlOn aS well aS an 1nveStlgatOry puYpOSe. � Most LPR systems capture mulriple images of the same vehicle and
LPR Systems funChOn ln SUCh a way as to nOhfy an OffiCei' then use the best image;other systems are capable of capturing more
than one vehicle per second.
2
• character segmentation, which finds the individual • Camera identification (mobile cameras may capture
characters on the plates; officer identification and vehicle/unit number);
• optical character recognition, which converts the • GPS coordinates or other location information; and
image into actual characters; and • Date and time of observation.
• syntactical/geometrical analysis, which checks The contextual photo provides a more inclusive
characters and positions against state-specific rules view of the vehicle and its surroundings. Depending
to identify the state of issuance for the license on the focal length of the camera and the distance of
plate. capture, the photo may provide a view of part or all of the
Many LPR systems utilizing mobile LPRs are vehicle, its surroundings, and possibly the occupants of a
equipped with global positioning system(GPS)receivers. vehicle.This information may be helpful in, among other
This allows mobile and portable units to record the date, things, (a)identifying the vehicle by providing color or
time, and location of license plate image capture. Data unique attributes such as damage or bumper stickers, (b)
such as date and time stamps and GPS coordinates can be confirming the location of the LPR camera that took the
reviewed in relation to investigations and can help lead photograph, ar(c) confirming the identity of a vehicle's
to critical breaks, such as placing a suspect at a scene, occupant.
witness identification, pattern recognition, or the tracking Although a contextual photo contained in an LPR
of previously identified suspects. system may contain a great deal of raw information,
LPR cameras take digital and infrared pictures of only certain pieces of infarmation contained in any LPR
vehicles and license plates as they pass through the field of photograph will be subjected to OCR and rendered into
view of an LPR camera. These images, and the metadata an electronically readable format.Thus,images of vehicle
associated with them(described in more detail below), occupants, vehicle make and model, and any distinguishing
can be used in a variety of public safety contexts and the features of a vehicle contained in a contextual photo are
amount of information utilized from an LPR system can not electronically readable or compiled by existing LPR
vary depending upon an agency's objectives. Fixed LPR systems.
units in operation at national border crossings, for example, B. LPR Hot Lists
which often operate in a setting consisting of slow-moving
lanes of traffic, may collect different information than a Many of the primary uses of LPR data involve the
mobile LPR camera operated by a local law enforcement comparison of license plate numbers collected by an LPR
agency. system to numbers contained on a previously compiled
Images of vehicles and license plates are the primary list. These hot lists may be compiled by the local law
form of information collected by an LPR system. OCR enforcement agency utilizing the LPR system or by other
is performed on these images and the alphanumeric state or federal government agencies.The purpose of
characters on each license plate are rendered into an these lists is to inform law enforcement officials which
electronically readable farmat. LPR cameras can attach vehicles are of interest to law enforcement and why,
date, time, and geographic location information to an alerting officials when such a vehicle displaying a license
image. plate number that is included on a hot list is near an LPR
The image collected by an LPR camera is maintained camera. This can be done in real time or through the use of
in the information system to provide a means of ensuring historical LPR data.
that the license plate number was properly converted into 'The use of hot lists is essentia] to LPR systems
an electronically readable format. This digital image, intended to serve public safety purposes, and the actions
sometimes referred to as a contextual photo, can include taken by law enforcement officers informed of a"hit"will
additional information that is not necessarily electronically vary depending upon the list that contains the vehicle's
recorded. LPR systems may contain information including license plate number. Limiting the number of hot lists
the following: uploaded to an LPR system is recommended to guard
OCR of license plate numbers; against the system"crying wolf."If law enforcement
• Digital images of license plates as well as the vehi- officers are bombarded by an alert at every third license
cle's make and model; plate that passes the LPR camera due to the inclusion of
Digital images of the vehicle's driver and passen- too many hot lists, a danger might exist that officers may
� turn off the system or otherwise ignore alerts during their
gers;
• Images of distinguishing features (e.g.,bumper shifts. Including only those hot lists that further the law
stickers, damage); enforcement agency's goals is one way to guard against
State of registration; this danger. Local agencies are ultimately responsible for
� selecting which hot lists to upload onto their LPR systems.
3
Compiling and Managing of LPR Hot Lists. Security watch lists. Departments of motor vehicles
Managing hot lists is a key element to the success of an can provide lists of expired registration tags and police
LPR system.The content of hot]ists should be monitored departments can also interface their own hot lists to the
to protect people whose vehicles license plates numbers LPR system. Hot lists can be uploaded onto an LPR system
are contained on such lists from continued and unnecessary either as separate lists or merged into a single list.
annoyance.While some hot lists focus on identifying a Law enforcement officials have access to the license
particular vehicle regardless of who is operating it(e.g., plate numbers contained on multiple LPR hot lists. Some
stolen cars,AMBER alerts), other lists include license plate hot lists will contain numerous license plate numbers,
numbers known to be associated with specific individuals and officials may not be able, or desire, to review their
(e.g., sex offenders, wanted persons).These hot lists, entire contents. For purposes of sharing hot lists across
whether they relate to stolen cars or potential occupants jurisdictions, it may be beneficial for law enforcement
of vehicles, enhance law enforcement agencies' ability to agencies that create hot lists to maintain supporting
detect crime and provide critical officer safety information. documentation regarding why a particular license plate
LPR hot lists are compiled to serve agency-specific number is on the specific hot list and make that information
needs. Hot lists may include,for example,license plate available, upon request, to the agency utilizing that hot list
numbers of vehicles known to be operated by (a)violent as part of its LPR system.
probationers and parolees; (b) violent gang members; (c) The heads of law enforcement agencies are ultimately
individuals with outstanding warrants; and(d)individuals responsible for determining which hot lists are uploaded
identified as witnesses.In same instances,individuals onto the agency's LPR system and what actions officers
provide the license plate numbers of vehicles they may take in response to an LPR hit.Agencies should establish
operate; in others, departments of motor vehicles may criteria for determining which hot lists will be uploaded
provide license plate numbers of vehicles registered to onto the LPR system. Since hot lists are created to enhance
individuals. In still other circumstances,license plate law enforcement officers' abilities to conduct investigations
numbers may be linked to certain individuals by direct and provide for officer safety, the contents of hot lists
observation and documentation from law enforcement should not be disseminated to the public.
officers.
When developing their own hot lists,law enforcement �, DATA QUALITY
agencies should develop a process that sets forth criteria
for including certain license plate numbers on a hot list. LPR cameras capture images of vehicles and license
For instance, in order to activate an America's Missing: plates, and OCR software, utilizing sophisticated
Broadcast Emergency Response(AMBER)Alert certain algorithms, translates the alphanumeric characters on each
criteria must be met. Specifically, a juvenile (a) must have license plate into an electronically readable farmat.The
been confirmed as abducted, (b)is under the age of 16 image collected by an LPR camera is maintained in the
or has a proven mental or physical disability, and(c)is information system to provide a means of ensuring that
in danger of serious bodily injury. There also needs to be the license plate number was properly converted into an
enough descriptive information to believe that a broadcast electronically readable format.An LPR system's ability to
alert will help.Additionally, agencies may consider accurately identify the characters on a license plate lies at
providing a process whereby a license plate number's the heart of the data quality issue.
inclusion on a hot list can be verified. A. OCR Accuracy
Providing for verification is one way of monitoring the
accuracy of data contained on a hot list.It also helps ensure Many variables affect OCR accuracy. Each state has
that law enforcement officials act only upon complete, multiple license plate designs, and plates vary significantly
correct, and timely information.Agencies should also from state to state. For maximum effectiveness,LPR
develop procedures for removing license plate numbers systems must be properly configured to recognize the
that do not belong on a particular hot list. design and layout of plates most likely to be encountered in
Updating and Sharing Hot Lists. Hot lists are the area of operation. The shape of the characters, amount
typically uploaded onto an LPR system daily and can be of contrast between a particular state's background and
updated by the authoring agency or an officer in the field. the color of the license plate characters, and whether the
Hot list information can come from a variety of sources, characters are raised or flat can all impact the accuracy of
including,but not limited to, stolen vehicle information the OCR read.
from the National Insurance Crime Bureau and the Poor image resolution, and thus poor character
National Crime Information Center(NCIC), as well as recognition, can be the result of several factors. License
national AMBER Alerts and Department of Homeland plates can be too far away for the capabilities of the LPR
4
camera to capture and motion blur can also occur.Poor IV. POLICY AND PROCEDURAL
lighting and low contrast due to overexposure, reflection, DEVELOPMENT
adverse weather conditions, or shadows can also result
in a poor image quality. Occasionally, an object might A. System Information
obscure all or a portion of the license plate and interfere
with accurate OCR. Oftentimes the object is a tow bar, dirt Given the different types of LPR systems and that
on the license plate, or a loaded bike rack; other times the each may function in a slightly different manner, it may
object may be an LPR circumvention device. be beneficial for an agency to describe the system(s)
Increasing the height of the LPR camera may correct and intended operational use, along with any additiona]
some of these problems;however, changing the position supplemental information, such as best practices, not
of the LPR camera with respect to the license plate it is otherwise covered by policy. For example, the length of
supposed to read may require the system to adjust for the time it takes to upload and download information to the
new orientation and increased skew of the license plate. LPR unit varies depending on the data transfer method.
From time to time, states may make significant Agency best practices may dictate that, if it is a mobile
changes in their]icense plate formats and designs that can LPR system the uploadldownload is only initiated during
substantially impact OCR accuracy. For instance, a state refueling to reduce downtime at the station.
might add a character or issue a new license plate design. B. Procedural Concerns and Requirements
LPR systems must adapt to these changes quickly in order While LPRs enhance public safety by increasing law
to remain effective. enforcement efficiency,public concerns regarding use,
Sometimes the letter D is mistaken for a Q or an data retention, and privacy implications of the technology
O. Other times, the characters on the license plate are must be addressed by implementing departments. There
sometimes cut off from the frame of the image; when this are a number of ineasures an agency can take to address
occurs, the OCR software may incorrectly read an E as these concerns as well as other questions that may arise
an F or a Z as a 7. Some colors, especially reddish tones, When implementing any new technology. These include
may be difficult for LPR system OCR software to read. developing an operational plan that clearly articulates the
Learning the type of mistakes LPR system's OCR software purpose(s) for using license plate readers, defines how
makes can help investigators run queries on potentially the data will be used, and means for limiting the data
misread license plate numbers. For these reasons the mode] Within those original parameters, while allowing for those
policy specifies that officers should"[v]isually verify circumstances where secondary uses of the LPR system or
that the license plate on the vehicle of interest matches data are needed.
identically with the image captured, `read,'by the LPR Before any policy or operational plan is developed it
system, including both the alphanumeric characters of the is essential that an individual with administrative oversight
license plate and the state of issue:' be designated.This individual should be someone with
B. Comparison of OCR Information with Hot List sufficient authority in the agency to champion the LPR
Data program, carry out the responsibilities listed in the model
Another data quality challenge involves the comparison policy, and autharize any additional uses of the LPR that
the agency may deem appropriate.
of the OCR data with the license plate numbers on a hot The administrator should also do the following:
list. States develop license plate number formats robust
enough to provide unique serials for all the motor vehicles • Stay abreast of legal trends and case law in the area
the jurisdiction expects to register. Less-populous states of license plate readers and other electronic forms
may use six-character formats whereas more populous of public surveillance
states may choose to utilize a seven-character format. • Monitor the use of the LPR system and ensure peri-
Complicating this factor is the fact that multiple states odic audits
may utilize the same alphanumerical formats; for example, ' Ensure that the LPR system is used only for ap-
neighboring states may use three letters followed by four propriate agency business in keeping with agency
numbers.Thus, two cars from different jurisdictions could policy and technical requirements
have the same number, but different license plate designs. ' Manage the compilation of hot lists
As a consequence, each time a law enforcement officer is ' Make updates to the LPR policy as needed
alerted to the proximity of a vehicle displaying a license LPR systems are only as good as the data they rely
plate number contained on a hot list, the user should verify upon, and ensuring that the hot lists are kept current is
that the plate that caused the alert matches the hot list data. critical to limiting the possibility that users will act or
rely on erroneous information.The system administrator
5
should establish criteria to determine which hot lists will The officer should act cautiously,however, to determine
be uploaded into the LPR system and establish any policy whether the driver is in fact the registered owner and the
and procedures needed to govern manual entries of license person of interest.
plates into the LPR system. Manual entries,for example, C. Security Safeguards
should be reviewed periodically to determine whether they
should be kept, and only certain individuals will be given LPR data are sensitive enough to be categorized
the necessary IT permissions to perform this function. for official use only.As such,LPR systems should be
Many systems on the market already include technological protected by reasonable security safeguards to prevent loss
controls governing manual updates entered in the hot lists or unauthorized access, destruction,use, modification, or
and erase manual updates after a certain time period or disclosure of LPR data. Ensuring that LPR data remain
whenever a new hot list is added. secure is one way for law enforcement agencies to build
In addition to managing the timeliness and accuracy public confidence.
of the information being included in the hot lists, data Law enforcement agencies may consider taking
qualiry audits may be necessary and should concentrate on several steps to help secure LPR data. LPR systems and
measuring the accuracy of the read when compared with the computers that access them should utilize antivirus
contextual images. Data quality audits provide the agency software and firewalls.Additionally,it is recommended
with a baseline of its LPR system's accuracy over time that authorized users should be given individual log-
and could alert the agency to equipment or alignments in IDs and required to utilize alphanumeric passwords
problems if there is a drop-off in the accuracy rate. consisting of a combination of upper and lower case letters,
Developing policy, and training consistent with that numbers, and symbols; users should also be required to
policy, can help to address concerns that automated LPR frequently change their passwords and keep them safe.
systems take the human element out of policing.At the Law enforcement agencies should also utilize encryption
time of this policy's development, similar concerns had technologies to protect LPR data in storage and in transit
led to bans on red light cameras in at least seven states and over networks.
pending legislation limiting their use in two more states.3 D. Data Sharing
LPR systems now face the same challenge, as two states
have established restrictions on the use of license plate Most agencies already have policies concerning
readers.' the dissemination and sharing of official data.Agencies
Verifying the accuracy of the license plate read and the should review existing information sharing policies to
currency of the hot list information is essential. The model determine whether they adequately and appropriately cover
policy addresses this issue by specifying that"When an the sharing of LPR data and make any modifications if
LPR alerts an officer of a `hit,'prior to initiation of a stop necessary.
Since it is recommended LPR data be classified as
of the vehicle or other intervention based on the alert/hit, FOUO (for official use only), agencies should maintain
the officer should first, (a)Visually verify that the license
plate of the vehicle of interest matches identically with the secondary dissemination logs when LPR data are shared
image captured(read)by the LPR system, including both outside the originating agency. Secondary dissemination
the alphanumeric characters of the license plate and the logs should contain the following information:
state of issue, and(b) verify the current status of the license • Description of the LPR data disseminated
plate through dispatch or MDT query to ensure the validity • Date and time the information was released
of the information and whether the plate is still stolen, • Identity of the individuals to whom the information
wanted, or otherwise of interest:' was released, including agency and contact infor-
Additionally,it is important to remember that LPR mation
systems are used to identify vehicles, not persons.In cases • Purpose for which the LPR data will subsequently
where agency hot lists include license plate numbers of be used
vehicle(s) registered to persons of interest, the LPR system Such logs function as programmatic audit trails
will alert the officer to the presence of the vehicle. and help agencies monitor the use of the LPR data.
Additionally, should the origina] data be revised, it may be
3 Larry Copeland,"Communities Put a Halt to Red-light Cameras," necessary to provide the updated information to those with
USA Today,January 18,2010,http://www.usatoday.com/news/na- whom the o]'iginal data weI'e Shal'ed.
tion/2010-01-17-red-light_N.htm(accessed May 4,2010).
° L.Samuel Pfeifle,"License Plate Recognition to Be Regulated in
Maine,"Security Director News,March 2,2010,http://www.security-
directornews.com/?p=article&id=sd201003nYy2tH(accessed June 22,
2010).
6
E. Data Retention Situational realities. Political, social, technical, and
Although retention periods were once necessitated by financial realities are different in every jurisdiction, and
physical storage constraints, technological advances in the each must be weighed against the other and combined with
electronic storage of records have made the destruction the business needs and priorities of the agency.Where
of criminal justice and law enforcement information the social and political climate is more favorable to]aw
largely unnecessary.Thus, whether to retain a piece of enforcement's use of LPR systems, a longer retention
information indefinitely is now a matter of policy.When period may be possible. Longer retention periods generally
developing policy, consideration should be given to the fact require more technical and financial resources for support,
that privacy concerns are often framed in the context of however, and agency objectives and priorities in the use
retention and agencies using LPR systems may be called of LPR data should substantively contribute to decisions
upon to explain the rational for their retention policies, regarding retention duration.
particularly one that maintains data for a considerable Loss of value over time. Historical data may lose value
period of time. over time due to the sale and transfer of automobiles or
There is no formula for determining how long LPR the ability to obtain information from other governmental
data should be retained, nor have standards or guidelines departments.
been established that agencies can refer to as they develop Statutes o limitations. Consideration should also be
LPR data retention policies. Given the lack of professional given to the mission of the agency and to the operational
standards in this area, this paper offers the following objectives. If the LPR data are associated with a crime that
recommendations on criteria that should be considered in is subject to a statute of limitations, then an agency may set
establishing retention policies: a retention period relative to that statute.
State and local data retention schedules Potential evidentiary value. Potential evidentiary value
� System rype(s)being deployed(fixed, mobile, may not only affect the length of retention but how the data
� portable) are retained. For example, during an investigation it may
be determined that the LPR data could be valuable at a
• Situational realities later point. In such a case, a query for all LPR data within
• Loss of value over time a certain time frame relative to the incident could be run,
• Statutes of limitations and the results saved to a CD or thumb drive and placed in
• Potential evidentiary value the case jacket so they are available at a later date even if
State and local data retention schedules. State and the original data have already been discarded.In this case,
local data retention schedules supersede retention periods While saved LPR data are no longer subject to the original
established by individual entities.As noted previously, retention period, they may still be subject to policies
two states have already established restricrions specifically regarding evidentiary practices.
focusing on license plate readers.5 Even where there are no
state or local guidelines directly focused on license plate F. Privacy Concerns
readers, existing guidelines related to comparable forms of Chief among all of the issues and concerns raised
electronic data and imaging systems may be applicable to relative to law enforcement's use of LPR systems is
LPR systems. privacy. Concerns about privacy issues are similar to those
System type. The type of LPR system an agency uses raised about other forms of video surveillance(such as
may also play a factor in determining retention policies. CCTVs, and red light cameras) and center primarily on
Fixed LPR systems, for example, typically capture more the issues of loss of anonymity, data retention and sharing,
license plate reads in a day than mobile or portable LPR and analysis out of context.The IACP's Privacy Impact
systems.As a consequence, some agencies that use more Assessment Report for the Utilization of License Plate
than one system type establish different retention schedules Readers notes that
for each type of deployment, with longer retention periods
for mobile and/or portable LPR systems and shorter The enhanced sharing, even among law
periods for fixed LPR systems. enforcement personnel, of substantial amounts
of information about people not immediately
suspected of criininal activity may lead the
public to believe that its privacy interests are
s New Hampshire passed a bill in 2007 that bans the use of any surveil- being ignoYed. MoYeoveY, impYopeY disClosuYes of
lance technolog;es on a public way,including everything from red light potentially sensitive information not only damage
cameras to LPR technology.Maine's leg;slation limits the use of license the relationship betWeen citizens and their
plate readers,sets a data retention length of no mare than 21 days,and
limits the enrities permitted to use the technology to law enforcement,
the Department of Transpartation,and toll booth entities.
7
governmental institutions...[but]may also make be acted upon in a timely manner.As LPR technology
people more vulnerable to physical, emotional, continues to improve, increased accuracy of these systems
financial, and reputational harms.� will better help law enforcement to identify potential
suspects as well as assist in the elimination of individuals
Law enforcement has always been permitted to recard as suspects.
license plate numbers on vehicles in public places. The For a more detailed look at the privacy concerns
public's perception of that process changes, however, surrounding law enforcement's use of license plate readers
when systems are employed to record substanrial amounts and how they can be addressed it is suggested that agencies
of information about people who are not immediately also read the IACP's Privacy Impact Assessment for the
suspected of criminal activity. Depending on the type of Utilization of License Plate Readers.
system deployed, the amount of data gathered, and the
manner in which the data are used,LPR systems have the
potential to reveal an individual's driving habits. Concerns Acknowledgement
about privacy have been raised because of that ability, '1'his Concepts &Issues Paper was developed by
combined with enhanced sharing and aggregation of data. Internationa]Association of Chiefs of Police(IACP)Law
Specifically, LPR systems have the ability to capture a Enforcement Information Management(LEIM) Section
vehicle's presence at locations or events that are lawful in cooperation with the IACP National Law Enforcement
and public, such as political protests, doctor's offices, ar policy Center.Additional support was provided by the LPR
religious places of worship. Model Policy Working Group, to whom we are deeply
Several prominent privacy groups and LPR critics appreciative for sharing their agency policies and expertise.
view information concerning individuals'locations as
inherently prone to abuse. The concern is not limited to
law enforcement,but is extended to other members of the
general public. Misuses of LPR data can potentially take
several forms. One common misuse of any data system
involves the improper disclosure of information about
an individual that could affect an individual's perceived
character and reputation. Civil litigation may flow from
personal damages of this type. Furthermore, the knowledge
of a person's location or frequent travel pattern could, for
example, heighten that person's vulnerability to property
theft or physical harm if it falls into the wrong hands.
Still, there are strong arguments that persons have a
diminished expectation of privacy in public spaces. It is
further argued that license plate numbers identify only
a specific vehicle, not a specific individuaL Moreover,
state laws require vehicles to be registered and generally
mandate that a vehicle pass safety and emissions
inspections before it can be legally driven on public roads.
The public display of a license plate exists in part so that
law enforcement can easily verify that the vehicle complies
with the law.
The use of cameras to capture vehicle images and
then use that information to identify the vehicle's owner
or operator is not a new concept. Until recently however,
this technology was often time-consuming and costly to
operate. It also faced a number of limiting environmental
factors such as poar lighting and weather conditions, not to
mention problems in producing information that could
� Privacy Impact Assessment for the Utilization of License Plate
Readers(Alexandria,Va.:International Association of Chiefs of Police,
September 2009), 12,http://www.theiacp.org/LinkClick.aspx?filetick-
et=N%2bE2wvY%2f1QU%3d&tabid=87(accessed August 23,2010).
8
Every effort has been made by the IACP National Law
Enforcement Policy Center staff and advisory board to
ensure that this document incorporates the most current
information and contemporary professional judgment
on this issue. However, law enforcement administrators
should be cautioned that no "model" policy can meet all
the needs of any given law enforcement agency. Each law
enforcement agency operates in a unique environment
of federal court rulings, state laws, local ordinances,
regulations, judicial and administrative decisions and
collective bargaining agreements that must be considered.
In addition,the formulation of specific agency policies must
take into account local political and communiry perspectives
and customs,prerogatives and demands;often divergent law
enforcement strategies and philosophies; and the impact of
varied agency resource capabilities among other factors.
This project was supported by a grant awarded by
the Bureau of Justice Assistance. The Bureau of Justice
Assistance is a component of the Office of Justice Programs,
which also includes the Bureau of Justice Statistics, the
National Institute of Justice, the Office of Juvenile Justice
and Delinquency Prevention,the Office far Victims of Crime,
and the Office of Sex Offender Sentencing, Monitoring,
Apprehending,Registering,and Tracking.Points of view ar
opinions in this document are those of the author and do not
necessarily represent the official position or policies of the
U.S.Department of Justice or the IACP.
IACP National Law Enforcement Policy Center Staff:
Philip Lynn, Manager; Sara Dziejma, Project Specialist
and Vincent Talucci, Executive Director, International
Association of Chiefs of Police.
O Copyright 2010. International Association of Chiefs
of Police,Alexandria,Virginia U.S.A.All rights reserved
under both international and Pan-American copyright
conventions. No reproduction of any part of this material
may be made without prior written consent of the copyright
holder.
9