Turlock Police | License plate readers
A city of 73,000 with access to three separate plate reader databases, joined to a countywide network it did not build. Its published policy sets no retention period, and says so in a section short enough to read in full.
At a glance
- Retention in the published policy
- None stated. The policy refers to "an established records retention schedule" it does not contain, name, date or cite [1]
- Retention of vendor-held data
- Set by the vendor, not by the department. The policy says so explicitly [1]
- Databases the department can search
- Three: EPIC iO, Flock Safety and Vigilant [3]
- Countywide network
- Turlock joined a countywide EPIC iO network in 2023, giving it access to other members cameras across the county [3]
- Flock agreement
- $1,133,550 over five years, approved on the January 2025 agenda, with a first-year payment of $251,150 [3]
- How it was funded
- Half from the Cannabis fund reserve and half from the Measure A reserve, $566,775 each [3]
- Intersections
- The staff report says five in one place and six in another, and adds thirteen more, with four further interior locations identified [3]
- Sharing
- California public agencies only. Out-of-state and federal agencies are excluded by the policy [1]
- Audits
- the policy says audits "should be conducted on a regular basis" and names no interval, no auditor and no publication requirement [1]
- What the council decided
- we read the staff reports and the resolutions, not the minutes, so we can say what was proposed and recommended and not how anyone voted [3]
How it happened
- Deployment
The city installs plate readers and joins a countywide network
The department's later staff report records that with the initial installation in 2023 it "joined a countywide network of ALPR cameras manufactured by EpicIO, formally Intellisite", giving it access to data from other EPIC iO cameras throughout the county. [3]
- Expansion
The council considers a five-year Flock agreement
An agreement with Flock Safety for $1,133,550 over five years, adding thirteen intersections, funded in equal halves from the city's Cannabis fund reserve and its Measure A reserve. With it and a Vigilant subscription, the report says the department "will have access to the three most common ALPR databases in the surrounding area." [3]
- Context
The current policy manual is published
Chapter 437 of the department's policy manual, published under Senate Bill 978, states no retention period for plate data and defers the retention of vendor-supplied data to the vendor. The wording is identical to the standalone procedure the department published in 2023. [1] [2]
Three databases
Most departments on this site have one plate reader system. Turlock’s own staff report describes holding three, and treats that as the point of the purchase:
With approval of this item, and the recent allocation of funds to purchase a subscription to the Vigilant ALPR database, along with our current vendor EpicIO, Turlock Police Department will have access to the three most common ALPR databases in the surrounding area.
The reason it gives is independence: to “decrease our dependence on allied agencies to enter and search for vehicles on our behalf”, and to get an immediate answer instead of waiting for one.
That is a real operational argument. It is also a description of a city of about 73,000 people holding query access to three commercial surveillance networks at once.
The network it joined
The same report explains where the first system came from, and it was not a Turlock decision about Turlock:
With the initial installation of the ALPR system in Turlock in 2023, Turlock Police Department joined a countywide network of ALPR cameras manufactured by EpicIO, formally Intellisite. As a member of this network, Turlock Police Department has access to data from other EpicIO ALPR cameras throughout the County. This sharing of data allows participating law enforcement agencies to enter suspect vehicles so that any participating agency may be alerted to the presence of a wanted vehicle, regardless of which jurisdiction entered the vehicle.
A countywide network existed and the city joined it. The department’s account of its own safeguards belongs alongside that: officers must verify an alert with dispatch or through the state law enforcement network before acting on it, access is limited to law enforcement personnel for official investigative purposes, and every access is logged.
What the newest cameras do
The staff report is direct about why Flock was added on top of what the city already had:
Features such as the ability to capture images of vehicles which do not have a license plate attached or have a license plate cover and the ability to search for vehicles with unique features such as bumper stickers, decals, and roof racks, are offered features of the Flock Safety ALPR cameras.
Read that twice. The selling point is that the cameras identify vehicles that have no licence plate to read, and that they can be searched by what is stuck to the back of a car.
We are not adding anything to that sentence. The department wrote it, in a public agenda packet, as a reason to buy.
What the policy does not say
Turlock publishes its policy manual, which is why any of this can be checked. Chapter 437 covers plate readers. Its section on retention is short enough to quote whole:
The Special Operations Division Commander is responsible for ensuring systems and processes are in place for the proper collection and retention of ALPR data.
All data and images gathered by an ALPR for the official use of the Turlock Police Department should be stored in accordance with an established records retention schedule unless it has become, or it is reasonable to believe it will become, evidence in a criminal or civil action or is subject to discovery request or other lawful action to produce records.
Retention periods for ALPR data collected by commercial providers and/or other law enforcement agencies and made available to this department are set by those providers and agencies.
There is no number in it. The rule is a reference to a schedule the chapter does not contain, name, date or cite. And for data that arrives from a vendor or another agency, the chapter hands the question to them.
The department published this. It also published a standalone version in 2023 with the same wording, so this is not a drafting slip that a newer manual corrected. Elsewhere in California, Cotati’s council voted a one-month limit and San Mateo’s sheriff publishes a thirty-day purge. Turlock publishes a pointer.
On sharing the chapter is precise where retention is vague: data may go only to California state or local agencies, and the definition explicitly excludes out-of-state and federal law enforcement.
Who paid
The Flock agreement is $1,133,550 over five years. The funding is split exactly in half between two reserves: $566,775 from the fund holding cannabis revenue, and $566,775 from the fund holding Measure A money.
Neither is a police budget line that anyone had to cut something else to find. That is not a criticism of the choice, and reserves exist to be spent. It is a note about how such a decision reaches a council: as a transfer from money already sitting there rather than as a trade-off between this and something else the city wanted.
The report’s own alternatives section puts the recommendation plainly: the council could reject the agreement, “However, this is not recommended because by entering into an agreement with this vendor, Staff is able to utilize multiple ALPR vendors as well as expand the number of intersections utilizing license plate readers, broadening the scope of available data.”
What we do not know
- What records retention schedule the policy points at. Chapter 437 says plate data "should be stored in accordance with an established records retention schedule" and does not contain, name, date or cite one. Without it there is no answer to how long a Turlock plate read is kept.
- Who administers the countywide EPIC iO network, under whose policy, and with what retention. The department's own policy defers vendor-held data to the vendor, so for data arriving through the network the rules may be written somewhere Turlock's council never voted on.
- How many intersections have cameras. The same staff report says five in one paragraph and six in another.
- How chapter 437.7 fits with the Records Maintenance and Release Policy. Having excluded out-of-state and federal agencies from the definition of a public agency, 437.7 routes their requests to a different chapter of the manual, which we have not read.
- What the council actually decided on either 2025 item, and whether anyone spoke. We read the staff reports and resolutions, not the minutes.
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 Stanislaus County.
What we have documented in Stanislaus 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. Turlock Police Department Policy Manual, chapter 437, Automated License Plate Readers (ALPRs) · Primary document · · accessed · archived copy
- 2. Turlock Police Department, Automated License Plate Readers standard operating procedure · Primary document · · accessed · archived copy
- 3.
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