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Healdsburg Police | License plate readers

Healdsburg publishes its license plate reader policy on the city's own website. The policy states that "Reasonable suspicion or probable cause is not required before using an ALPR." The vendor, the number of cameras and where they sit are not in the records we fetched.

At a glance

Threshold for using a reader
None required: "Reasonable suspicion or probable cause is not required before using an ALPR" [1]
When a reader may be used
"in conjunction with any routine patrol operation or criminal investigation" [1]
Sharing stated in the policy
"only with other law enforcement or prosecutorial agencies for official law enforcement purposes or as otherwise permitted by law" (Policy 465.7) [1]
Federal immigration enforcement
Barred by Policy 465.7. The department "does not permit the sharing of ALPR data gathered by the City or its contractors/subcontractors for purpose of federal immigration enforcement, these federal immigration agencies include Immigrations and Customs Enforcement (ICE) and Customs and Border Patrol (CPB)" [1]
Audits
"ALPR system audits should be conducted on a regular basis" [1]
Who administers the system
The Administration Division Commander [1]
Date of the policy
Policy 465 carries a Lexipol stamp of December 20, 2022 [1]
Retention stated in the policy
Policy 465.5.1 says of parking enforcement data that "All ALPR data downloaded to the server should be stored for a minimum of one year (Government Code § 34090.6)", and that the vendor "will purge their data at the end of the 90 days of storage" [1]
Vendor, camera count and locations
not in the records we fetched [1]

How it happened

  1. Context

    Policy 465 in the published policy

    The department's license plate reader policy, stamped December 20, 2022, states that no reasonable suspicion or probable cause is required to use a reader. It limits sharing to law enforcement and prosecutorial agencies and bars sharing for federal immigration enforcement, naming ICE and Customs and Border Patrol. It calls for regular system audits and puts administration with the Administration Division Commander. [1]

What the policy says

The department’s license plate reader policy is Policy 465, published as its own document on the city’s website and carrying a Lexipol stamp of December 20, 2022. It sets the threshold for use in two sentences: “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.” Section 465.7 says the data “may be shared only with other law enforcement or prosecutorial agencies for official law enforcement purposes or as otherwise permitted by law.” The policy says “ALPR system audits should be conducted on a regular basis,” and puts administration of the system with “the Administration Division Commander.”[1]

Section 465.7 also carries an express bar on one kind of sharing. The department “does not permit the sharing of ALPR data gathered by the City or its contractors/subcontractors for purpose of federal immigration enforcement, these federal immigration agencies include Immigrations and Customs Enforcement (ICE) and Customs and Border Patrol (CPB).” The policy requires the Chief to consider the California Values Act, the state law limiting local assistance with immigration enforcement, before approving a release.[1] Which agencies have received Healdsburg plate data, and under what terms, is not in the records we fetched.

On retention, Policy 465.5.1 gives two figures for two different things. Of parking enforcement data it says “All ALPR data downloaded to the server should be stored for a minimum of one year (Government Code § 34090.6).” It also says the vendor “will purge their data at the end of the 90 days of storage.”[1] What the system is configured to do today is a separate question, and the policy is the only record we fetched that speaks to it.

What it does not establish

The policy is the whole of what we read. It does not name a vendor, a number of cameras or an installation site, and no other record we fetched supplies them.[1] The city keeps a program page for the readers, which this pass did not read in detail.[2] Whether the policy has been amended since December 2022 is open on the same footing.

Questions

Does an officer need a reason to run a plate through the Healdsburg system?
Not under the policy. Policy 465 states that "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." [1]
Who can receive Healdsburg's plate data?
Policy 465.7 says the data "may be shared only with other law enforcement or prosecutorial agencies for official law enforcement purposes or as otherwise permitted by law." The same section states that the department "does not permit the sharing of ALPR data gathered by the City or its contractors/subcontractors for purpose of federal immigration enforcement, these federal immigration agencies include Immigrations and Customs Enforcement (ICE) and Customs and Border Patrol (CPB)." It also requires the Chief to consider the California Values Act before approving a release. [1]
How long is the data kept?
Policy 465.5.1 gives two figures. Of parking enforcement data it says "All ALPR data downloaded to the server should be stored for a minimum of one year (Government Code § 34090.6)." It also says the vendor "will purge their data at the end of the 90 days of storage." What is configured on the system today is a question for a records request. [1]

On the map

The community has mapped 361 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 →

Street names from reverse geocoding — © OpenStreetMap contributors (ODbL).

What we do not know

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 Sonoma County.

What we have documented in Sonoma 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. 1.
    Healdsburg Police Department, Automated License Plate Reader Policy, Policy 465 (Lexipol, 2022-12-20) · Primary document · · accessed · archived copy
  2. 2.
    City of Healdsburg, Automated License Plate Reader Program · Primary document · accessed · archived copy

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