REPORT TO COUNCIL
SUBJECT
Title
Informational Report Regarding the Santa Clara Police Department’s Automated License Plate Reader (ALPR) Policy, Compliance Review, and Program Operations
Report
EXECUTIVE SUMMARY
This informational report provides an overview of the Santa Clara Police Department’s (Department) Automated License Plate Reader (ALPR) program, including its operational use, legal and policy framework, and oversight practices. ALPR technology supports criminal investigations by helping officers identify vehicles associated with crimes, locate stolen vehicles, and develop investigative leads. The report also summarizes the Department’s review of system configuration and audit logs and confirms that the current program operates in compliance with California law and Department policy.
BACKGROUND
The Santa Clara Police Department has used Automated License Reader (ALPR) technology for approximately 18 years as an investigative tool to assist officers in locating stolen vehicles, identifying vehicles associated with criminal investigations, locating missing persons, and supporting public safety operations.
In 2008, ALPR technology from PIPS Technology was mounted on four patrol vehicles. These mobile systems allowed officers to automatically scan license plates during routine patrol operations and compare captured plates against databases of stolen vehicles, warrant suspects, vehicles of interest, and missing persons. These real-time alerts changed policing; however, only a small fraction of the Department’s fleet was equipped with this technology, limiting the number of plates scanned.
Effective January 1, 2016, California Senate Bill 34 (SB 34), codified in California Civil Code §§1798.90.5-1798.90.55, established requirements governing the use of ALPR systems by law enforcement agencies. The law requires agencies to adopt and publicly post an ALPR usage and privacy policy, implement safeguards governing data access and sharing, and provide a private right of action for violations of the statute.
On May 17, 2016, the City Council approved the Department’s ALPR policy to comply with the California Civil Code changes related to the collection and use of ALPR information (Attachment 1). The policy established operational guidelines governing authorized use, data security, training requirements, and retention of ALPR information in accordance with State law. Following the City Council’s adoption, the policy along with the Department’s other policies, was posted on www.scpd.org <http://www.scpd.org>.
Legislative changes, such as the passage of Proposition 47, led to the reclassification of certain nonviolent crimes from felonies to misdemeanors. As a result, flash mob shoplifting and smash and grab thefts from vehicles increased dramatically between 2016 - 2019 throughout the state. In Santa Clara, thefts from vehicles increased by more than 55 percent during that period. These crimes often involved suspects using vehicles to quickly enter and exit City limits, making it difficult for investigators to identify suspect vehicles and detect crime patterns using traditional investigative methods.
In response to these trends, ALPR technology was identified as one of several analytical tools law enforcement personnel could utilize to identify suspect vehicles, track patterns of criminal activity, and improve investigative efficiency. In September 2019, the City Council approved $750,000 in grant funding from the California Board of State and Community Corrections (BSCC) to support regional crime prevention initiatives and investigative technology programs (Attachment 2).
As the Department evaluated future ALPR capabilities, the original mobile systems continued to deteriorate, could only address a fraction of the needs and were phased out of service. To expand investigative capabilities and provide broader coverage, the Department explored ALPR technology via fixed cameras at strategic arterial locations throughout the City.
Since 2021, Department ALPR has been supported under a contract with Flock. That year, the Department initiated a two-year pilot ALPR camera program, installing 12 fixed cameras at key ingress and egress locations throughout the City to assist investigators in identifying vehicles associated with criminal activity and support crime prevention efforts.
The Department found ALPR to be an effective way to prevent and solve crime.
By 2024, the City had deployed 17 fixed ALPR cameras citywide with the intention of expanding the network to 32 cameras. Twenty (20) additional cameras have been deployed in the Levi’s Stadium and Silicon Valley Power (SVP) footprint areas, bringing the City’s ALPR network to 52 cameras. Three additional cameras near Levi’s Stadium are currently in the deployment process, which would bring the total to 55 active cameras.
Funding for the ALPR system (Attachment 3) has been supported through a combination of Police Department operating funds, Levi’s Stadium to comply with Measure J, and Silicon Valley Power. In addition, several private entities within the City, including homeowners associations and commercial businesses, have installed privately owned ALPR cameras and voluntarily provide the Department with limited access to assist with crime prevention and investigative purposes. These partnerships support public safety efforts by expanding the availability of license plate recognition data that may assist officers and investigators in identifying vehicles associated with criminal activity.
Key Components of an Effective ALPR:
The ALPR program operates through several core components that define the system’s capabilities, the information collected, and the safeguards in place to protect privacy.
Capabilities - ALPR systems help law enforcement identify vehicles associated with criminal investigations, locate specific vehicles related to crimes, identify crime patterns, and improve investigative efficiency compared with manual license plate checks.
Data Collected - ALPR systems capture the license plate number, vehicle rear image, vehicle make and model, color and the date, time, and location of the scan. Images are captured from vehicles traveling on public roadways and do not include facial recognition, driver identity, or criminal history information.
Information Not Collected - The ALPR system does not collect or identify the identity of the driver or passengers, facial recognition or other biometric data, driver’s license records or personal identity information, criminal history information, or immigration or citizenship status.
Search Criteria - “Be On the Lookout” (BOLO) or hot list alerts identify license plates associated with criminal investigations. The system automatically compares captured license plates against these lists.
Data Storage - ALPR images and related data are stored for a defined period, creating a temporary searchable archive that can assist investigators in identifying vehicles associated with criminal activity.
Privacy and Security - ALPR use is governed by California law and Department policies regulating system access, search logging, auditing, and data retention.
DISCUSSION
Legal and Policy Framework
The use of Automated License Plate Reader technology by law enforcement agencies in California is governed by state law designed to ensure transparency, accountability, and privacy protections. Courts have consistently recognized that license plates displayed on vehicles traveling on public roadways are observable in public view and therefore do not carry the same expectation of privacy as personal records.
California Senate Bill 34 (SB 34), passed in 2016, codified in California Civil Code §1798.90.5 et seq., and established privacy and security requirements governing the collection, use, maintenance, sharing, and dissemination of ALPR information. The law requires public agencies operating ALPR systems to do the following:
• Maintain reasonable security procedures and practices, including operational, administrative, technical, and physical safeguards, to protect ALPR information from unauthorized access, destruction, use, modification, or disclosure
• Implement a usage and privacy policy, which shall be available to the public in writing and shall be posted conspicuously on that Internet Web site, and shall, at a minimum, include all of the following:
o The authorized purposes for using the ALPR system and collecting the ALPR information.
o A description of the job title or other designation of the employees and independent contractors who are authorized to use or access the ALPR system, or to collect ALPR information. The policy shall identify the training requirements necessary for those authorized employees and independent contractors.
o A description of how the ALPR system will be monitored to ensure the security of the information and compliance with applicable privacy laws.
o The purposes of, process for, and restrictions on, the sale, sharing, or transfer of ALPR information to other persons.
o The title of the official custodian, or owner, of the ALPR system responsible for implementing this section.
o A description of the reasonable measures that will be used to ensure the accuracy of ALPR information and correct data errors.
o The length of time ALPR information will be retained, and the process the ALPR operator will utilize to determine if and when to destroy retained ALPR information.
• The ALPR Operator must keep a detailed record of every access to the ALPR data including user identification, date and time of access, the query, and the purpose of the access.
• A public agency that operates or intends to operate an ALPR system shall provide an opportunity for public comment at a regularly scheduled public meeting of the governing body before implementing the program.
• A public agency shall not sell, share, or transfer ALPR information, except to another public agency, and only as otherwise permitted by law.
Neither SB 34, nor any other current law, provides any specific guidance or requirements relating to record retention. The California Highway Patrol has a statute specifically relating to their ALPR data retention (60 days), but that does not apply to municipal police departments. If the collection of ALPR data is analogized to “routine video monitoring” then Government Code §34090.6 requires retention of one year (which was incorporated into the City’s original 2016 ALPR Policy and has remained since that time). Otherwise, the standard minimum data retention period of two years would apply (Gov. Code §34090).
Note that SB 274 was proposed in 2025, passed by both houses of the State legislature, but vetoed by the Governor. It would have applied a 60-day record retention period for ALPR data for cities.
The frequently referenced 30-day retention period applies to the ALPR data stored in the FLOCK system and not downloaded to be in the City’s possession. As described below, it is the City’s understanding that FLOCK is complying with the 30-day period that was built into the City’s agreement with FLOCK.
SB 580 was approved in late 2025 and requires the California Attorney General to publish model policies for state and local agencies relating to interaction with immigration authorities consistent with federal and state law. The law further requires the AG to publish guidance, audit criteria, and training recommendations for databases operated by a state or local agency, including databases maintained for the agency by private vendors, aimed at ensuring that the databases are governed in a manner that makes the availability of information therein to anyone or any entity for the purposes of immigration enforcement limited to the fullest extent practicable. The deadline for the AG’s publication of model policy and guidance is July 1, 2026. This appears to encompass databases of information collected by ALPR systems. Therefore, if necessary, the City’s ALPR policy and practices will be updated to align with the Attorney General’s recommendation.
California Senate Bill 54 (SB 54), also known as the California Values Act, limits the sharing of certain information with federal immigration authorities and restricts the use of local law enforcement resources for immigration enforcement activities.
Santa Clara Police Department Policy 428 (Attachment 6) - Automated License Plate Readers establishes departmental procedures governing the capture, storage, access, retention, and release of ALPR data in compliance with state law.
Department Policy and Program Controls
Policy 428 establishes operational safeguards designed to ensure responsible and lawful use of ALPR technology. Key provisions include:
Authorized Use
ALPR technology may be used only for official law enforcement purposes, including identifying stolen or wanted vehicles, locating missing persons, and supporting criminal investigations.
Access Controls and Training
Access to ALPR systems and data is restricted to authorized personnel who have received training on system use, applicable laws, and Department policy. System access and searches are recorded in audit logs documenting the user, date, and time of access.
Data Retention
ALPR data downloaded to the server is retained in accordance with the Department’s records retention schedule unless preserved as evidence in a criminal or civil action.
Audit and Accountability
The Department conducts monthly audits to monitor system activity and ensure compliance with Department policy.
Data Sharing Restrictions
ALPR information may be shared only with other law enforcement or prosecutorial agencies for official law enforcement purposes. Requests must be submitted in writing, approved by the Administrative Services Division Commander or designee, and retained on file.
Privacy and Legal Compliance
The collection, use, and release of ALPR information must comply with California Civil Code §1798.90.5 et seq., enacted through Senate Bill 34 (SB 34), which establishes privacy, security, and usage requirements for ALPR systems. Department policy also requires compliance with the California Values Act (SB 54), which restricts the use of local law enforcement resources for immigration enforcement purposes.
Transparency
Consistent with these requirements and the City’s commitment to transparency, community engagement regarding the ALPR program has occurred at several publicly noticed meetings, including:
• May 17, 2016 - City Council approval of original ALPR Policy
• September 17, 2019 - City Council approval of BSCC funding related to automobile burglary prevention. (Attachment 2)
• October 5, 2020 - Presentation to Chief’s Advisory Committee regarding implementation of the pilot program.
• September 27, 2021 - Public ALPR Town Hall meeting hosted by the Police Department.
• October 26, 2021 - City Council informational report regarding the ALPR policy.
• February 7, 2023 - City Council approval of funding supporting ALPR program expansion. (Attachment 5)
• December 3, 2024 - City Council authorization for continued deployment and maintenance of ALPR cameras. (Attachment 3)
The Department also maintains a public transparency portal on its website that provides access to ALPR policies, program information, and a list of agencies authorized to access ALPR data.
Program Oversight and Accountability
The Department maintains internal oversight procedures to support responsible and lawful use of ALPR technology.
The Administrative Services Division Commander provides program oversight and conducts monthly reviews of system activity. An Intelligence Sergeant serves as the Department’s ALPR program coordinator and manages day-to-day system administration, including coordinating user training, monitoring system configuration, and working with the vendor to review platform settings and updates.
All searches and system activity are recorded in audit logs that allow supervisory review of system use.
Requests for ALPR information sharing must be submitted to the Department, identify the requesting agency and purpose of the request, and receive approval from the Administrative Services Division Commander or designee. Requests are retained on file for accountability.
Public Records Act requests are processed in accordance with Department policy and California Civil Code §1798.90.55.
System Configuration Review and Audit Findings
The Department routinely conducts internal reviews of ALPR system activity, sharing configurations, and vendor platform settings as part of ongoing program oversight.
In September 2025, the Department identified a remaining non-California sharing configuration involving the Houston Police Department during a vendor platform review. The configuration was immediately removed, and subsequent review confirmed that no Santa Clara camera data had been accessed by the Houston Police Department.
Recent public comments in February 2026 raised questions regarding historical audit log entries that appeared to show out-of-state search activity. The Department conducted a broader review of the ALPR system, including vendor platform functionality, configuration settings, and historical audit logs.
Of 114,497 total searches between 2024 and 2025, only two searches specifically queried the SCPD camera network, both conducted by the Las Vegas Metropolitan Police Department.
The Department confirmed that no out-of-state sharing has occurred since September 2025, when internal review identified and corrected the remaining configuration issues.
Vendor platform updates and Department configuration reviews have since resulted in additional safeguards, including:
• Participation in nationwide lookup networks disabled for California agencies
• Removal of out-of-state sharing relationships
• Removal of federal agencies from system lookup networks
The Santa Clara Police Department retains full control over its ALPR data and determines whether, when, and with whom information may be shared, consistent with California law and Department policy.
The Department confirmed that the current system configuration restricts ALPR information sharing to California law enforcement agencies only.
Data Retention
The collection, use, and retention of ALPR information is governed by California Civil Code §§1798.90.5-1798.90.55 enacted through Senate Bill 34.
Santa Clara Police Department Policy 428 establishes a retention schedule for ALPR information. The current written policy reflects a one-year retention period as outlined in the Department’s records retention schedule (Attachments 8 & 9 - Item 42), consistent with video monitoring retention authority provided under California Government Code §34090.6.
The vendor platform’s standard retention period is 30 days from the date of capture unless the information is downloaded and preserved for investigative or evidentiary purposes. In those cases, the data is retained in accordance with the Department’s records retention policy, or longer if needed for an investigation. Routine ALPR data that is not associated with an investigation or evidentiary need is automatically deleted after the retention period.
In this context, it is important to recognize the difference between audit logs and ALPR data. Audit logs are specifically required under SB 34, they do not include the ALPR data, and they are not subject to the 30-day retention requirement. Audit logs are kept longer specifically for oversight purposes. The ALPR data (the photo of the license plate and any other distinguishing characteristics noted) is deleted either by the vendor in accordance with the 30-day requirement, or by the City in accordance with the record retention schedule.
ALPR Operational Use and Value
ALPR technology supports criminal investigations and public safety operations by helping officers quickly identify vehicles associated with crimes, locate stolen vehicles, and develop investigative leads. The system has been used to assist investigations involving residential burglaries, commercial burglaries, automobile burglaries, robbery, homicide, assaults, mail theft, sexual assault, domestic violence, and missing persons cases.
As police operations become increasingly complex, technologies such as ALPR help the Department maximize existing personnel resources while expanding investigative capabilities. Between 2005 and 2025, Santa Clara’s population increased by 22 percent, while the number of sworn officers grew by only 3 percent. During the same period, the City’s commuter and event-driven population has expanded significantly. With staffing levels remaining relatively stable, leveraging technology is essential to maintaining service levels, officer effectiveness, and community safety.
In 2025, the Police Department’s ALPR system generated 29,968 “hot list” alerts across the City’s 52 cameras. A “hot list” is a customizable, real-time watchlist of license plates associated with stolen vehicles, warrants, or criminal investigation. Of those alerts:
• 338 involved stolen vehicles
• 31 involved vehicles connected to felony crimes
• 26,298 involved stolen license plates
• 3,301 were custom investigative alerts
Custom alerts include vehicles associated with active Santa Clara Police Department investigations, wanted subjects, or suspect vehicles identified through bulletins issued by neighboring jurisdictions.
During the same period, Department personnel conducted 46,220 investigative searches of the ALPR system to identify vehicles associated with crimes occurring in the City. These alerts and searches resulted in 17 arrests directly attributable to ALPR hot-hit alerts.
As with any automated alert system, officers must confirm the accuracy of a hot hit through additional law enforcement databases and visual verification before taking enforcement action.
Investigative Impact Examples
The Department has used ALPR technology to assist investigations, identify suspect vehicles, and safely apprehend individuals involved in criminal activity. The following examples illustrate how the system has supported real-world public safety operations:
Bank Distraction Thefts / “Bank Jugging” (Districts 1, 2 & 4)
Detectives investigated a series of bank distraction thefts linked to a South American Theft Group operating throughout the Bay Area. Within Santa Clara, the suspects were responsible for more than ten incidents involving the theft of over $250,000 in cash and jewelry. ALPR data assisted investigators in identifying suspect vehicles, linking incidents across multiple jurisdictions, and supporting surveillance operations. The investigation ultimately resulted in the identification of eight suspects and arrest warrants for more than 160 felony charges, including burglary, grand theft, and elder abuse. Detectives later executed multiple search warrants and arrested several suspects.
Home Invasion Robbery - Regional Coordination (District 2)
Santa Clara officers received an ALPR alert identifying a vehicle associated with an armed home invasion robbery reported by the Modesto Police Department. Officers located the vehicle and ultimately arrested the driver. Detectives from Modesto responded to Santa Clara continuing their investigation.
Commercial Burglaries (Districts 2 & 4)
An organized group committed numerous commercial burglaries, vehicle thefts, assaults, and attempted carjackings in Santa Clara and surrounding jurisdictions. The suspects stole vehicles and used them to forcibly enter businesses by driving into storefronts or removing doorframes before burglarizing the locations. ALPR data played a significant role in the investigation by helping officers identify suspect vehicles, link multiple crime scenes, and monitor vehicle activity associated with the suspects. Through coordinated investigative efforts, including search warrants and arrest warrants, detectives identified and arrested eight suspects and seized evidence related to the crimes.
Mail Theft & Fraud Investigation (District 2 & 4)
Detectives investigated multiple mail theft incidents in Santa Clara. ALPR data helped investigators identify the suspect vehicle, which was initially displaying a stolen license plate. Further ALPR searches allowed detectives to identify the vehicle’s true registration information. Additional investigation and search warrants led to the identification and arrest of the suspect. A search of the suspect’s residence resulted in the seizure of stolen mail, stolen license plates, burglary tools, narcotics, and a firearm.
Armed Robbery Investigation (District 3)
Three suspects armed with a firearm committed a robbery and assault with a deadly weapon at a business near Monroe Street and Lawrence Expressway. Video surveillance provided a partial description of the suspect vehicle, which was later positively identified through an ALPR search. Detectives determined the same suspects were involved in a similar robbery in a neighboring jurisdiction. Officers later received an ALPR alert for the vehicle and located it parked in a hotel parking lot. Through coordinated efforts with the neighboring law enforcement agency, five suspects were ultimately identified and arrested.
Assault with a Deadly Weapon - Road Rage Incident (District 4)
During a road rage incident near Homestead Road and Lawrence Expressway, a driver intentionally struck a bicyclist, causing minor injuries. Officers used vehicle descriptions and nearby ALPR camera data to identify the suspect vehicle and entered it into a hot list. Later that evening, officers received an automated alert and located and arrested the suspect, who admitted involvement.
Sexual Assault of a Child Under 14 Years Old (District 5)
Officers investigated a case involving the sexual assault of a juvenile victim. Detectives conducted an extensive investigation that included coordination with outside law enforcement agencies and the execution of multiple search warrants. ALPR data provided critical investigative information by identifying the suspect vehicle traveling to Santa Clara near the time of the offenses. Detectives ultimately identified and arrested the suspect for multiple violations of Penal Code §288 and identified additional victims during the investigation.
Carjacking Investigation (District 6)
An ALPR alert identified a vehicle stolen during an armed carjacking three days earlier. The suspects were also believed to be connected to a homicide in Alabama. Officers located the vehicle and detained the suspects. Subsequent search warrants served in Sunnyvale and Santa Clara led to the safe arrest of a third suspect associated with the carjacking.
Conclusion
The Department remains committed to the responsible and transparent use of technology that supports public safety while respecting privacy protections established under California law.
Following its review of system configuration, platform functionality, and applicable policies, the Department confirmed that the current ALPR program operates in alignment with California Civil Code §§1798.90.5-1798.90.55 (SB 34), the California Values Act (SB 54), and Santa Clara Police Department Policy 428.
The Department will continue to monitor vendor platform updates, maintain appropriate access controls, and conduct supervisory oversight to support ongoing compliance, transparency, and responsible use of ALPR technology.
ENVIRONMENTAL REVIEW
The action being considered does not constitute a “project” within the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines section 15378(b)(5) in that it is a governmental organizational or administrative activity that will not result in direct or indirect changes in the environment.
FISCAL IMPACT
There is no fiscal impact of this report.
COORDINATION
This report was coordinated with the City Attorney’s and City Manager’s Offices.
PUBLIC CONTACT
Public contact was made by posting the Council agenda on the City’s official-notice bulletin board outside City Hall Council Chambers. A complete agenda packet is available on the City’s website and in the City Clerk’s Office at least 72 hours prior to a Regular Meeting and 24 hours prior to a Special Meeting. A hard copy of any agenda report may be requested by contacting the City Clerk’s Office at (408) 615-2220, email clerk@santaclaraca.gov or at the public information desk at any City of Santa Clara public library.
RECOMMENDATION
Recommendation
Note and file Information Report.
Staff
Reviewed by: Cory Morgan, Chief of Police
Approved by: Jovan Grogan, City Manager
ATTACHMENTS
1. SCPD ALPR Policy May 17 2016
2. RTC 19-941
3. RTC 24-661
4. SCPD ALPR Policy 428
5. RTC 23-1418
6. RTC 25-535
7 Revised Police Department Records Retention Schedule