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Why a city policy must cover every plate read
An ALPR system uses cameras and software to turn plate images into searchable records. A system may also retain the images, not just the plate characters. Records can include vehicles that do not match a police hot list and whose occupants are not suspected of wrongdoing.
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Data may be searchable across agencies: a city might access records collected by another jurisdiction even if it does not operate the cameras itself. The policy therefore needs to govern both the city’s own collection and its users’ access to outside data, as well as access by other agencies to city-held records.
Require these safeguards before deployment
1. Define permitted purposes and prohibit misuse
List the purposes for which ALPR searches are allowed in concrete terms—for example, investigating specified offenses, locating missing people, or responding to a defined public-safety threat, subject to applicable law. Do not leave the scope to a vague phrase such as “law enforcement purposes.”
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Prohibit searches for personal curiosity, harassment, political or protest monitoring, or any purpose outside the policy and applicable law. Require users to record a meaningful purpose for each search, and specify consequences for misuse. California SB 34 requires an operator’s policy to state authorized purposes and limits use of ALPR information to those purposes; that is a California requirement, not a nationwide rule.
2. Restrict access to named roles and trained users
Identify the job classifications that may use the system, and separate administrative privileges—such as managing accounts—from investigative search privileges. Use individual accounts, least-privilege permissions, and a documented process to remove access when someone changes roles or leaves. Shared credentials should not be allowed.
Require initial and periodic training on permitted purposes, search documentation, data handling, and consequences for misuse. California SB 34 requires policies to identify authorized employee and contractor designations and their training requirements. The California State Auditor has also recommended a “need to know and right to know” approach, with user classifications set out in policy.
3. Set a short retention period and automatic deletion
Choose a short default retention term for ordinary plate reads and images, including reads that do not produce an alert. Configure automatic deletion at expiration and keep records showing that deletion occurred. The policy should state the retention period and destruction process rather than leaving them to vendor settings or informal practice.
Allow extensions only for a specific, documented reason—such as a defined investigation, evidence hold, or other legal requirement—with supervisor approval and a new expiry date. Avoid open-ended exceptions. California SB 34 requires a retention period and destruction process but does not set a general duration for city-held ALPR records. A separate California rule described by the State Auditor limits California Highway Patrol images to no more than 60 days unless used in a felony investigation or as evidence; that is not a citywide default. A 2025 committee analysis discussed a proposed 30-day limit in SB 274, but a bill analysis does not establish that the proposal became law.
4. Control sharing with other agencies
Require a written agreement for each recipient or tightly defined recipient category. It should specify the permitted purpose, data available and access duration, eligible users, restrictions on onward disclosure, security duties, audit rights, and deletion obligations. Require a request to state its purpose and legal basis, and make approvals case-specific or limited to categories the city has expressly approved.
Give the city power to suspend access and obtain recipient audit records. Prohibit recipients from using data for a different purpose or passing it onward outside the agreement. California SB 34 requires a policy to address sharing purposes, processes, and restrictions on sale, sharing, or transfer. California’s Attorney General also highlighted SB 54 limits concerning immigration-enforcement uses in a 2023 announcement; those California-specific constraints should not be treated as universal law.
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5. Log every meaningful action and audit those logs
Keep tamper-resistant records of each view, search, export, configuration change, sharing event, and deletion. At minimum, logs should identify the time, query or plate data, user and affiliated organization where applicable, stated purpose, and action taken. Review the records on a set schedule, flag unusual searches and bulk exports, investigate exceptions, and report findings to an independent city oversight body.
California SB 34 expressly requires access records with date and time, plate or other query data, username and affiliated organization as applicable, and purpose. The State Auditor identified inadequate auditing as a privacy risk. A policy that requires logs but never reviews them is not effective oversight.
6. Secure records and address inaccurate reads
Require encryption in transit and at rest, strong authentication, role-based access, security monitoring, incident notification, and tested response procedures. Backups and exported copies need deletion controls too; otherwise, expiration in the main system may leave extra copies behind.
Set a procedure to verify a plate read before an officer acts on it, provide a way to correct inaccurate data, record corrections, and notify users or recipients who received the incorrect record. California law requires reasonable operational, administrative, technical, and physical safeguards and a policy describing accuracy measures and error correction.
7. Put enforceable limits in vendor contracts
The contract should make the city—not the vendor—responsible for setting data purposes, retention, deletion, permissions, external connections, and system changes. Permit vendor access only for support the city expressly authorizes and logs. Prohibit secondary use, sale, model training, or onward sharing.
Require audit access, prompt notice of security incidents, export of city data in a usable format, and secure deletion when the contract ends. Require city approval before new features or sharing integrations are enabled. These are recommended contract protections; California SB 34 sets policy and security duties but is not a complete vendor-contract template.
8. Publish the rules and make the program answerable to residents
Publish the policy, a plain-language explanation of the system, approved use categories, retention rules, sharing arrangements subject to lawful redactions, and periodic aggregate activity and audit reports. Provide a public comment or hearing process before deployment and require a renewal vote after a defined pilot or sunset period.
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California SB 34 requires a written public policy and, for operators with a website, conspicuous online posting. The State Auditor says programs implemented after January 1, 2016, also must offer public comment before implementation. Requirements elsewhere depend on local and state law.
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California SB 34 (2015) is a useful statutory example. It addresses reasonable security safeguards; authorized purposes and users; training and security monitoring; sharing purposes, processes, and restrictions; a responsible custodian; accuracy and correction; and retention and destruction. It also requires specified access records and restricts use to authorized purposes.
On October 30, 2023, the California Attorney General announced updated bulletins and model policies, reminding law-enforcement agencies about SB 34 and the separate constraints of SB 54 concerning immigration-enforcement uses. A city considering an actual program should have local counsel check current statutes, ordinances, court orders, public-records duties, and the city’s authority. The California framework does not answer every jurisdiction’s legal questions.
Turn policy language into tests before launch
The California State Auditor’s 2019-118 review found privacy risks at the four agencies it examined, including sharing decisions made without informed consideration, retention choices not grounded in actual data use, poor access practices, and inadequate auditing. Its summary said none of the four policies included all required information and reported that Los Angeles had not developed an ALPR policy during the period covered. These are historical findings about the agencies reviewed, not a statement about current compliance by every agency.
Before launch, the city should test whether its controls work in practice:
- Check that each account belongs to one person and permissions match the person’s role.
- Test that searches require a purpose and that records capture the required details.
- Verify that expired records and backup copies are deleted as required.
- Review sharing agreements and confirm recipients can be audited and access suspended.
- Run an audit exercise to see whether unusual searches, exports, or access are detected and investigated.
- Test the process for validating and correcting an inaccurate read and notifying affected recipients.
Questions for a council or procurement review
When comparing proposals or reviewing a renewal, ask for clear answers on each of these policy choices:
Quick Recap
- Which purposes are allowed, and which uses are expressly prohibited?
- What is the default retention duration, and what specific conditions permit an extension?
- Which roles may administer the system or conduct searches, and what training is required?
- Which outside agencies can access data, for what purposes, and under what written terms?
- How often are logs audited, who conducts the audit, and what findings become public?
- How are reads checked, errors corrected, and corrections propagated to recipients?
- What can the vendor access or do, and what happens to data when the contract ends?
- When will the city hold a public review and decide whether to renew or end the program?
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