Vallejo Police | License plate readers
Vallejo's plate reader policy bars sharing with immigration authorities and bars sharing to investigate anyone exercising reproductive health care rights. The same chapter sets out a procedure for agencies outside California to get access through the Flock portal.
At a glance
- Retention
- No longer than one year on the department server; the vendor purges at the end of 30 days [1]
- Federal immigration enforcement
- Sharing not permitted, naming ICE and Customs and Border Patrol [1]
- Reproductive health care
- Sharing not permitted to prosecute or investigate anyone exercising reproductive health care rights under California law [1]
- Out-of-state agencies
- The policy sets a procedure: agencies outside California requesting access through the Flock portal must agree to abide by applicable federal and California law and department policy [1]
- What state guidance says about that
- The Attorney General published guidance in 2023 reading state law to bar sharing plate reader data with out-of-state and federal agencies [2]
- Suspicion needed to run the system
- None. The policy says reasonable suspicion or probable cause is not required before using a reader [1]
- Query logging
- Every browsing inquiry must carry a case or incident number and a reason [1]
- Audit
- At least ten inquiries drawn at random from the preceding six months, once each calendar year [1]
- Whether any out-of-state agency has been granted access
- not in any record we fetched. The policy describes a procedure; we hold nothing showing it was used
- Camera count
- not stated in the policy. The EFF Atlas snapshot in this repo counts 131 Flock cameras as of April 2024 [3]
How it happened
- Context
An earlier ALPR policy, still reachable
The city's file host serves a standalone plate reader policy numbered 428 with an adoption date of June 23, 2016. The 2024 manual carries the plate reader chapter at a different number, 426, with materially more content. [4]
- Context
Atlas snapshot counts 131 Flock cameras
The EFF Atlas of Surveillance records the department operating 131 Flock Safety license plate readers as of April 2024. [3]
- Context
Policy 426 published in the May 2024 manual
The manual released on May 20, 2024 carries the plate reader chapter at Policy 426, including the immigration and reproductive privacy clauses and the procedure for agencies outside California. [1]
What the policy establishes
The plate reader chapter of Vallejo’s May 2024 manual, Policy 426, carries two protective clauses that are worth stating in full. The department “does not permit the sharing of ALPR data gathered by the City or its contractors/subcontractors for purpose of federal immigration enforcement, pursuant to the California Values Act”, naming Immigration and Customs Enforcement and Customs and Border Patrol.[1] And the chief “will also consider the California Reproductive Privacy Act … before approving the sharing of ALPR data for the purpose of investigating any person seeking to exercise their reproductive health care rights within California”, with sharing for that purpose not permitted.[1]
On retention, data on the department server is kept “for no longer than one year”, while “Flock Safety will purge their data at the end of the 30 days of storage”.[1]
Accountability is written down in a checkable form. “Every ALPR detection browsing inquiry must be documented by either the associated Vallejo Police case number or incident number, and/or a reason for the inquiry.”[1] An annual audit “shall randomly select at least 10 detection browsing inquiries conducted by Department employees during the preceding six-month period”.[1] Ten is the floor the policy sets, against a system the Atlas snapshot associates with 131 cameras as of April 2024.[3] That sentence also cross-references “policy section 462.6(e)” where the manual’s own numbering for the query-logging rule is 426.6(e).
The clause that sits against state guidance
The same sharing section contains a procedure for agencies outside California: they “must agree to abide by all applicable Federal and California State Laws as well as Department policy”, must complete a data sharing request “prior to the granting of access”, and their access “can be stopped at anytime by authorized VPD Command Staff”.[1]
California’s Attorney General issued guidance in 2023 reading state law to bar sharing plate reader data with out-of-state and federal agencies.[2]
Both texts are quoted here because both are the record. We hold no document showing that any out-of-state agency was granted access to Vallejo data, and this page makes no claim that one was. What we can say is that the policy as published in May 2024 describes how such a request would be handled, and that is a question a resident can put to the city.
Two policies, two vintages
The city’s file host also serves a standalone plate reader policy numbered 428 with an adoption date of June 23, 2016.[4] The 2024 manual numbers the chapter 426 and contains substantially more, including both clauses quoted above.[1] The later document is the later document; which one the department treats as operative is not something the files themselves settle.
Where to ask
Ask for the audit. The policy requires one every year and sets a sample floor of ten inquiries, so a records request for the most recent audit memorandum, and for the number of inquiries reviewed, is specific and answerable. Ask separately whether any agency outside California has been granted access through the Flock portal, and for the data sharing requests on file. Vallejo City Council meets in public and takes comment.
Questions
- Can immigration authorities get Vallejo plate data?
- The policy says the department does not permit sharing plate data for federal immigration enforcement, and names Immigration and Customs Enforcement and Customs and Border Patrol. It says so twice, once in the policy statement and once in the sharing section. We hold no record of what has actually been shared. [1]
- What does the policy say about agencies in other states?
- It sets out a procedure. Agencies outside California that request access through the Flock portal "must agree to abide by all applicable Federal and California State Laws as well as Department policy", complete a data sharing request before access is granted, and can have access stopped by command staff. California's Attorney General published guidance in 2023 reading state law to bar sharing plate reader data with out-of-state agencies. We hold no record showing any out-of-state agency was actually granted access. [1] [2]
- Is there anything unusual in this policy?
- Yes. It bars sharing plate data to prosecute or investigate anyone exercising reproductive health care rights as defined by California law, and requires the chief to consider the state's Reproductive Privacy Act before approving a release. That clause appears in few of the policies we have read. [1]
- How closely is use audited?
- Every browsing inquiry must be documented with a case or incident number and a reason. Once a year the professional standards lieutenant audits a sample, and the policy sets the sample floor at ten inquiries drawn at random from the preceding six months. [1]
On the map
The community has mapped 377 devices of this type in the county on OpenStreetMap. These are community reports: the vendor and operator of each point are unverified, and none is confirmed to belong to this system. See them on the map →
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Street names from reverse geocoding — © OpenStreetMap contributors (ODbL).
What we do not know
- Whether any agency outside California has been granted access through the procedure the policy describes.
- The results of the annual audits, and how large the samples actually were.
- How many cameras the department operates now and where they sit.
- Which of the two reachable plate reader policies the department treats as current.
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 Solano County.
What we have documented in Solano 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. Vallejo Police Department Policy Manual, Policy 426, Automated License Plate Readers (released 2024-05-20) · Primary document · · accessed · archived copy
- 2.
- 3.
- 4. Vallejo Police Department, Policy 428, Automated License Plate Readers, adoption date 2016-06-23 · Primary document · · accessed · archived copy · our copy (12 KB)
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