San Mateo County Sheriff | License plate readers
The Sheriff's own policy purges Flock camera data after thirty days, one of the shortest retention periods this site has recorded, and bars sharing with federal and out-of-state agencies. The same policy states that no suspicion is required to run the system, and the county's civil grand jury recorded the office as having no stated retention period at all.
At a glance
- Retention
- Flock camera data that is not intelligence or investigative information is purged after 30 days. Other plate data may be kept up to one year [1]
- Suspicion needed to run the system
- None. The policy states that reasonable suspicion or probable cause is not required [1]
- When the patrol cameras run
- Units on marked patrol vehicles are activated and used at all times, unless the driver is not trained and certified [1]
- Federal and out-of-state sharing
- Barred by the policy, citing Civil Code 1798.90.55(b) and 1798.90.5(f) [1]
- Immigration enforcement
- Barred by the policy, which names Immigration and Customs Enforcement and Customs and Border Protection [1]
- Reproductive health care
- Barred by the policy for prosecuting, investigating or initiating proceedings against a person exercising reproductive health care rights [1]
- Protest and assembly
- The policy bars use aimed at people or groups based solely on activity protected by the First Amendment [1]
- Cameras
- 109 in the office's own column, plus 14 in Half Moon Bay and 26 in Woodside that it operates under separate contracts, as counted by the civil grand jury on March 30, 2026 [3]
- Audits
- An ALPR Administrator conducts periodic audits of user queries. The policy says audits "should be conducted on a regular basis" [1]
- Before a fixed camera goes up
- The policy requires an opportunity for public comment at a regularly scheduled meeting of the governing body of the area [1]
- Whether the required audits happened
- the civil grand jury reported that the audit records produced to it were insufficient to substantiate compliance with California law and the office's own policy. We have not seen the audit records ourselves [3]
How it happened
- Context
An earlier Policy 420 is stamped
The version of Policy 420 still served from the Sheriff's website under the filename ALPR_Policy.pdf carries a Lexipol copyright stamp of September 13, 2018. It sets the one-year retention rule and carries no mention of Flock cameras, which the current version purges at thirty days. [2]
- Context
The vendor disables nationwide sharing by default
The civil grand jury records that Flock first disabled nationwide sharing by default in February 2025 and permanently removed it in March 2025, and that in June 2025 it disabled the ability to create new out-of-state sharing relationships. The report notes those changes did not automatically end sharing relationships that already existed. [3]
- Context
The current Policy 420 is stamped
The copy of Policy 420 that the Sheriff's plate reader transparency page links carries a Lexipol copyright stamp of February 4, 2026. It is the version that adds the thirty-day purge for Flock camera data and the bar on use aimed at First Amendment activity. [1]
- Deployment
The county's cameras are counted
The civil grand jury counts more than 582 plate reader cameras across San Mateo County as of this date. The Sheriff's Office is the largest operator at 109, and separately operates the 14 cameras in Half Moon Bay and the 26 in Woodside. Broadmoor is the only police department in the county with none. [3]
- Coverage
The civil grand jury reports, and names the Sheriff as a respondent
The 2025 to 2026 San Mateo County Civil Grand Jury releases "Is Our Flock of ALPR Cameras Properly Tended?", reviewing plate reader use by eighteen operators. It assigns six of its nine findings to the Sheriff, covering private university sharing, audit sufficiency, contract terms, a written-request process, sharing criteria, and a retention mismatch. The Sheriff is required to respond as an elected county officer. [3]
What the policy actually permits
The Sheriff’s Office runs the largest plate reader system in San Mateo County. Its rules are Policy 420, and the version the office links from its own transparency page carries a Lexipol stamp of February 4, 2026.
Two sentences in it describe the collection posture. Section 420.3(b) says that “[a]n 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.” Section 420.4(c)(3)(A) says that plate readers on marked patrol vehicles “shall be activated and used at all times unless the operator of the vehicle has not been trained and certified to use the system.”
Those are the department’s own words for what suspicionless collection means. Quoting them is not a criticism. It is the answer to the question most residents would ask first, which is whether anything has to be suspected before the cameras record a plate.
Thirty days, not a year
Section 420.2 sets two retention periods:
ALPR data that is not considered intelligence and investigative information may be retained for a maximum of one (1) year unless the information is from an ALPR device deployed within an area wherein the local government has requested a different retention period. Data from FLOCK cameras that is not considered intelligence or investigative information will be purged after 30 days.
Nearly every camera the office runs is a Flock camera, so the thirty-day purge is the number that governs most of the data. It is materially shorter than the one-year general rule, and shorter than most of the retention periods recorded elsewhere on this site.
The 2018 version of the same policy carries the one-year sentence in almost identical words and has no Flock sentence at all. That file is still live on the Sheriff’s website under a different filename, and it is the copy a web search tends to surface first.
What the policy forbids
Section 420.6 sets out prohibited uses. Four of them are worth reading in full.
The office does not permit sharing plate data “for purpose of federal immigration enforcement,” naming Immigration and Customs Enforcement and Customs and Border Protection, under the California Values Act. It will not share with federal or out-of-state agencies at all, citing Civil Code sections 1798.90.55(b) and 1798.90.5(f). It does not permit sharing data to prosecute or investigate “any person for the exercise of reproductive health care rights as defined by California law.”
And the fourth:
ALPR technology shall not be used for the purpose of monitoring, tracking, identifying, or investigating individuals or groups based solely on the exercise of rights protected by the First Amendment of the United States or California Constitution, including but not limited to lawful speech, association, assembly, or participation in protests, demonstrations, or other expressive activities.
The civil grand jury’s report notes the argument that plate tracking can affect freedom of association by revealing attendance at protests, political meetings or religious gatherings, and says that concern was not the focus of its investigation. The Sheriff’s policy addresses that use directly and bars it.
Two things are true about that provision at once. It is a clear commitment, more explicit than most policies this site has read. And it is a commitment the agency makes to itself. The grand jury’s finding that the office’s audit records were insufficient to substantiate compliance with its own published policy applies to this provision as much as to any other.
Where the record disagrees with itself
The civil grand jury’s summary table records, in its data retention column for the Sheriff’s Office, “No stated retention.”
The office’s current policy states a one-year maximum, states a thirty-day purge for Flock data, and then states a “maximum of 12 months” a second time inside its accounting requirements.
We cannot reconcile those two things from what we have read. The grand jury’s stated method was to compare the retention period in each agency’s policy against the period shown on the vendor’s transparency portal and, where available, the vendor contract. Every other agency’s entry in that column reads “Consistent” or “Inconsistent.” The Sheriff’s is the only one that reads as an absence, and the report does not say which of the three documents the entry describes.
We have not seen the contract or the portal. We are not saying the grand jury was wrong, because we have not seen what it saw. Both statements are on this page, sourced, and the question of which document produced the discrepancy is the first thing to ask the office.
What the department reports about accuracy
Policy 420 describes how the system misreads plates, in section 420.4(d)(2):
ALPR systems will alert based on the alpha numeric characters displayed for license plates issued and false positives are possible based on license plates with the same numbers from other states. ALPR systems may also misread letters and numbers of similar shapes. This is the primary reason that, absent exigent circumstances, all positive Hits must be confirmed prior to taking law enforcement action.
A department writing down how its own equipment fails, and requiring a human check because of it, is more candid than most policies on this site. The confirmation requirement is a real safeguard and it is worth knowing it exists.
The county picture this sits inside
The Sheriff’s system is one of eighteen in San Mateo County. The civil grand jury counted more than 582 plate reader cameras across the county as of March 30, 2026, and reported that Broadmoor is the only police department in the county operating none.
The report also recorded a positive finding that belongs beside the critical ones: it “did not identify any instances in which ALPR cameras were deployed without the required public notice and discussion.” Policy 420 carries that requirement, promising an opportunity for public comment at a regularly scheduled meeting of the governing body before any fixed camera goes up.
On sharing, the report found that as of December 2025 no operator in the county was sharing plate data with entities outside California. It did find sharing with private security agencies serving two universities, and concluded that the materials produced did not establish that those recipients meet the legal definition of a public agency. It did not find that the sharing was unlawful, and neither do we.
What we do not know
- Which document the civil grand jury was reading when it recorded "No stated retention" for the Sheriff's Office. The office's current policy states two retention periods, one year in general and thirty days for Flock data, and states the twelve-month ceiling a second time in its accounting requirements. The report compared each agency's policy against the vendor's transparency portal and the vendor contract, and does not say which of the three the entry refers to. We could not resolve it from the documents we read.
- What the Sheriff's Flock contract and vendor transparency portal say about retention. We have read neither.
- Whether the audits the policy requires were conducted. The grand jury reported that the records produced to it were insufficient to substantiate compliance; it did not report that no audits occurred, and its own report says a finding based on nonproduction is not a determination that no record exists.
- How the Sheriff will answer the six findings assigned to the office. A response is required under Penal Code section 933.05, due roughly sixty days after the August 3, 2026 report.
- Why the 2018 version of Policy 420 is still served from the same directory as the current one. The two differ on retention, and the older file is the one a search engine tends to return.
What you can do
Show up
Systems like this one are approved by boards, councils and committees that meet in public. We have not yet confirmed where each of them meets in San Mateo County.
What we have documented in San Mateo County →Protect yourself
Practical steps to shrink your personal data trail. Our guides publish at launch; until then, EFF's Surveillance Self-Defense is the best starting point.
Surveillance Self-Defense →Sources
- 1. San Mateo County Sheriff's Office, Policy 420, "Automated License Plate Readers (ALPRs)", Lexipol stamp February 4, 2026 · Primary document · · accessed · archived copy
- 2. San Mateo County Sheriff's Office, Policy 420, "Automated License Plate Readers (ALPRs)", Lexipol stamp September 13, 2018 · Primary document · · accessed · archived copy
- 3. San Mateo County Civil Grand Jury 2025-2026, "Is Our Flock of ALPR Cameras Properly Tended?" · Primary document · · accessed · archived copy
- 4. San Mateo County Sheriff's Office, ALPR transparency page · Primary document · accessed · archived copy
Get the digest
A regular digest of what changed in the world of surveillance: the counties we published, the devices that appeared on the map, and the public meetings where these decisions get made. We send it when there is enough to report.
One click to unsubscribe. What we do with your address is on the newsletter page.