Automated License Plate Recognition (ALPR) Policy for Westfield Park Recreation and Parkways District #12 to comply with California SB34

 

 

Automated License Plate Recognition (ALPR) Usage and Privacy Policy

Entity Name: Westfield Park Recreation and Parkways District #12 (Park Board).  The Park Board is composed of 5 Westfield residents who volunteer their time on an unpaid basis as their personal schedules permit.  The Park Board has no employees, no office, and a very limited budget which does not permit the ongoing retention of legal counsel.  Its scope of operations consists of maintaining the community equestrian arena, tennis court and hiking and riding trails.

Location: Unincorporated Palos Verdes Peninsula, Los Angeles County, CA

Effective Date: October 30, 2026

System Scope: Two (2) leased Flock Safety Sparrow ALPR Cameras, recording ingress and egress to our approximately 280 home cul-de-sac community, located at the entry/exit point of the cul-de-sac.  All data is recorded by and stored on equipment and systems belonging to Flock Safety.  The Park Board’s lease of the Flock Safety equipment entitles it to perform searches of data on Flock Safety’s system.  The Park Board does not collect, download, control or maintain copies or records of the ALPR data.  Consequently, the Park Board does not have certain knowledge of or control over the safe-keeping, integrity or distribution of the data recorded by the leased cameras.  The Park Board has granted access to the data on its Flock Safety account to only one other entity: the Los Angeles County Sheriff’s Department – Lomita Station, which is Westfield’s law enforcement entity.

1. Statutory Authority and Purpose

This Usage and Privacy Policy is adopted to comply with California Civil Code § 1798.90.51 et seq. (Senate Bill 34). The Park Board leases two fixed Flock Safety Sparrow Automated License Plate Recognition (ALPR) cameras located at the entrance of its approximately 280-home residential cul-de-sac.

Authorized Purposes

●        Community Safety & Crime Deterrence: Enhancing security across the approximately 280 residential properties by capturing vehicular license plates and vehicle characteristics (make, model, color) entering and exiting the single vehicular access point.

●        Incident Investigation: Providing evidence to assist local law enforcement—specifically the Los Angeles County Sheriff’s Department (LASD) - Lomita Station—in investigating reported crimes (e.g., burglary, vehicle theft, vandalism, trespassing) occurring within the community.

●        Real-Time Safety Alerts: Enabling automated notifications to local law enforcement (the LASD) e.g. for hot-listed vehicles associated with active felony warrants, stolen vehicles, or Amber/Silver Alerts.

The Park Board will never use the ALPR technology for general neighborhood surveillance, personal monitoring of residents, tracking resident lifestyle habits, or enforcing HOA code/CC&R violations.  The Park Board does not retain any copies or records of the ALPR data.

2. Authorized Personnel and Training Requirements

Authorized Users

The Park Board’s access to the Flock Safety ALPR system and its collected data is strictly limited to:

Designated Park Board Security Camera Administrator(s). Authorized Law Enforcement Personnel: The Los Angeles County Sheriff’s Department has also been granted system data access for legitimate law enforcement purposes.

Training Requirements

Prior to being granted access to the ALPR system data, the designated Park Board Security Camera Administrator(s) have:

●        Completed training on the Flock Safety software interface and system safeguards.

●        Reviewed and signed an acknowledgment of this ALPR Usage and Privacy Policy (and relevant California privacy laws (SB 34)).

●        Submitted to the Park Board annual certification of policy compliance.

3. Data Security, Monitoring, and Auditing

Security Safeguards

●        The Park Board does not download or maintain copies or records of the data. Consequently, the Park Board does not have certain knowledge of or control over the safe-keeping, integrity or distribution of the data recorded by the leased cameras. 

●        The Park Board has been informed by FlockSafety, the vendor, that it uses industry-leading safeguards to protect ALPR information from unauthorized access, use, destruction, modification, or disclosure, and that Flock’s information security policy and safeguards align with the security requirements established by NIST Cybersecurity and CISA Secure By Design. Examples of safeguards include:

o   Operational:

●      Audit logging.

●      Continuous security scanning and remediation of vulnerabilities on public facing infrastructure.

●               Role-based access controls to limit access based on functional need.

●      Processes to report vulnerabilities for responsible and public disclosure.

●      Third party attestations to requirements for SOC 2 Type II and ISO 27001.

●               Personnel screening for engineers with access to cloud infrastructure.

●      Strong multi-factor (TOTP) authentication for customer accounts.

●      NIST data security standards including encryption in transit and data at rest using FIPS approved algorithms.

 

●      Storage and processing of ALPR information in AWS US based cloud infrastructure.

●      Safeguards to mitigate device tampering and vulnerabilities in firmware.

●               Visitor controls, security personnel, and escort procedures for warehouses and sensitive areas.

●         

Audit Logs and Monitoring

●        The Park Board has been informed by Flock Safety that every user query or search in the ALPR database automatically generates an immutable audit trail logging:

o   Username and date/time of access.

o   Specific search parameters (e.g., plate number, date range).

o   Mandatory written purpose/reason for the search.

4. Restrictions on Data Sale, Sharing, and Transfer

●        While the ALPR information gathered by the ALPR system may be contractually owned by The Park Board, under the terms of its contract with Flock Safety, the ALPR information is stored on Flock Safety’s systems only, over which the Park Board has no control.

    

●        No Commercial Use or Sale:

●        The Park Board does not download or maintain copies or records of the data. Consequently, the Park Board does not have knowledge of or control over the safe-keeping, integrity or distribution of the data recorded by the leased cameras. 

●        Law Enforcement Sharing: Data is shared with the local California law enforcement agency (the LASD) solely for official criminal investigations or active public safety threats.

●        Prohibited Out-of-State / Federal Sharing: Pursuant to California law (including SB 34 and California Values Act / Government Code § 7284.2), ALPR data collected under this policy is not to be shared with out-of-state entities, federal immigration enforcement agencies (ICE/CBP), or used for enforcing out-of-state restrictions on reproductive or gender-affirming healthcare.

5. Data Retention and Purging Schedule

●        The Park Board does not download or maintain copies or records of the data. Consequently, the Park Board does not have knowledge of or control over the safe-keeping, integrity or distribution of the data recorded by the leased cameras. 

6. Data Accuracy and Error Correction

ALPR systems rely on Optical Character Recognition (OCR), which can occasionally result in misreads due to weather, dirt, or plate obstruction.

●        The Park Board has been informed by Flock Safety that Flock ALPR has a high rate of accuracy; because of Flock’s machine learning technology, these rates continue to improve over time. Additionally, the cameras self-monitor to ensure connectivity and functionality, and low-confidence plate reads are not sent to the user. Although infrequent, license plate translation may be incomplete or inaccurate. False positives are flagged to continuously improve the system. Users confirm the computer translation prior to taking any action based on ALPR information.

●        Verification Required: ALPR reads are informational leads only.

●        Data Correction: a resident or member of the public may identify inaccurate ALPR data and submit a written request to Flock Safety which stores and maintains the data.  The Park Board neither retains or maintains any data collected from the ALPR system.

7. Official Park Board Security Camera Administrator(s) and Custodian(s)

The designated individual(s) responsible for handling public inquiries under Civil Code § 1798.90.51 is(are):

Westfield Park Board Security Camera Administrator(s):

Mailing Address: 26610 Eastvale Road, Palos Verdes Peninsula, CA  90274

Email: ParkBoard90274@gmail.com

8. Public Notice and Transparency

Pursuant to California Civil Code § 1798.90.51(b)(1):

●        This Policy is available in writing to any resident or member of the public upon request.

●        This Policy shall be conspicuously posted on the community website/resident portal at: www.WPRPD.specialdistrict.org.

9. Data Retention: The Park Board has been informed by Flock Safety that the ALPR information is hard deleted on a rolling 30-day basis.