I am writing to express my opposition to the installation of Automatic License Plate Readers (ALPRs) in St. Helena. ALPRs present a serious threat to the privacy of ordinary citizens who end up in the dragnet of mass surveillance. The privacy concerns raised by ALPRs are compounded by the fact that these cameras will be leased from Flock Safety; the company maintains a nationwide database of plates captured by their cameras. I would strongly discourage the St. Helena City Council from approving any kind of automatic license plate recognition technology, especially the proposed contract, but if they still want ALPRs there are several steps that must be taken to minimize privacy invasions.
ALPRs log every car that passes; it is impossible to opt out of being monitored. Because the police department would contract with Flock Safety, every single plate reading would be sent to a national database controlled by the company. This information is available to any group that pays for Flock cameras, including police departments, federal agencies, HOAs, and residents’ groups. Flock’s self-imposed 30-day deletion policy is unenforceable because they are a private company unaffected by California ALPR laws. Beyond Flock, there is a history of targeted use of ALPRs against communities of color and other minority groups. In 2009 a Black woman, Denise Green, was pulled over and forced to exit her car at gunpoint in San Francisco because an ALPR misread her license plate. There is also precedent involving officers’ misuse of police databases. According to the Associated Press, officers across the country used various databases to find women to try to date, stalk former partners, and look up journalists critical of police.
If the Council insists on approving some form of license plate reading equipment, it should be as limited in scope as possible to lower privacy concerns. The photos captured by the cameras should only be stored for as long as it takes to check a database or local list of plates involved with a crime for a match. Any non-matches should be deleted immediately. Matches should be confirmed by a human before any action is taken. The Council should audit the local list and database access logs periodically. Every time the police access the information captured by the ALPRs there should be a short report to the Council.
These steps would serve to lessen the privacy impacts that ALPRs cause but wouldn’t eliminate them completely. Given recent events concerning abortion and transgender rights, this contract should not be approved because the data collected here could be used to prosecute people in other states who come here to safely access healthcare. Once the data is in Flock Safety’s database it is completely out of the local authorities’ hands. The only way to completely resolve the privacy concerns is to not install cameras at all.
The ACLU published an excellent white paper earlier this year detailing their concerns with Flock’s technology and ALPRs that goes into more detail on the issues I discussed above. It can be found by searching for “Flock Safety” on the ACLU website. The search bar is at the bottom of the homepage.
St. Helena City Council: please reject the proposed ALPR contract between the police department and Flock Safety. Privacy means being able to choose who has access to your personal information. Automated license plate readers take this choice away and Flock’s database makes your personal data yet another line item in their revenue report.
The Calistoga City Council approved six automatic license plate reader cameras on Tuesday, to be installed at entry points into the city. More cameras are likely coming elsewhere in Napa in the future.