Title
Report regarding a resolution approving the draft response to the San Mateo County Grand Jury Report titled, “Is Our Flock of ALPR Cameras Properly Tended?” (Anthony Pinell, Captain, Police Department).
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RECOMMENDATION
Recommendation
Move to adopt a resolution approving the draft response to the grand jury report, “Is Our Flock of ALPR Cameras Properly Tended?”
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BACKGROUND/DISCUSSION
Background
On August 3, 2026, the 2025-2026 San Mateo County Civil Grand Jury released a report titled, “Is Our Flock of ALPR Cameras Properly Tended?” (the “Report”). The Report presented findings and recommendations to promote the transparent operation of ALPR systems consistent with public safety, privacy, and applicable law. The report made nine findings, four of which pertained to the South San Francisco Police Department. The report made four recommendations pertaining to our agency, which directly addressed the grand jury’s findings. The City of South San Francisco is required to respond to the report within 90 days of its filing, or by November 2, 2026.
Discussion
Included as Exhibit A to the resolution associated with this staff report is a draft letter in response to the grand jury report. The responses to the grand jury findings and recommendations discussed below are all included verbatim in the draft letter included as Attachment 2 to this staff report. Staff have provided the responses here, in the body of the staff report, for ease of reading.
Response to Grand Jury Findings:
F5. The audit reports produced by the ALPR operator were insufficient to substantiate compliance with applicable California law and the operator’s published ALPR policy.
The City of South San Francisco agrees with this finding. Prior audit data was not archived and a memorandum explaining the audit findings was submitted. For this reason, the raw audit data could not be provided to the grand jury. Moving forward, the audits will be archived, and associated memorandums will substantiate compliance with California law and the department’s ALPR policy.
F6. The ALPR operator’s Flock Safety contract does not include provisions specifically requiring compliance with applicable California law and the operator’s published ALPR policy.
The City of South San Francisco agrees with this finding. The City intends on including such language in any future contract with an ALPR vendor.
F7. The operator’s ALPR policy described a process requiring written requests and executed agreements for ALPR data-sharing relationships; however, the records produced did not substantiate that this process was followed or that the required agreements were obtained.
The City of South San Francisco agrees with this finding. The South San Francisco Police Department’s ALPR policy will be updated to better clarify the data-sharing approval process. All existing ALPR data-sharing agreements are archived at the SSFPD.
F8. The operator’s ALPR policy did not establish criteria governing the approval of in-state ALPR data-sharing requests or the termination of existing network-sharing relationships.
The City of South San Francisco agrees with this finding.
I. Response to Recommendations:
R5. The audit report produced by the ALPR operator should substantiate compliance with applicable California Law and the operator’s published ALPR policy.
The recommendation has been implemented. Audits are now archived and associated memorandums will substantiate compliance with California law and the department’s ALPR policy.
R6. Upon contract renewal, the ALPR operator should incorporate contractual language requiring vendor compliance with applicable California law and prohibiting vendors from disclosing ALPR data to unauthorized third parties. Operators should consider provisions similar to those contained in the Town of Colma contract with Flock.
This recommendation has not yet been implemented but will be implemented in the future, by August of 2027. The city intends to include the recommended language in the next contract with an ALPR vendor.
R7. The ALPR operator should update its ALPR policy to accurately reflect the process used to approve ALPR data-sharing relationships.
This recommendation has been implemented. The South San Francisco Police Department updated its ALPR policy (436) to accurately reflect the process used to approve ALPR data-sharing relationships.
R8. The ALPR operator should include in their ALPR policies written criteria governing the approval, denial, periodic review, and termination of in-state ALPR network-sharing relationships.
This recommendation has been implemented. The South San Francisco Police Department updated its ALPR policy (436) to include language pertaining to the approval, denial, periodic review, and termination of in-state ALPR network-sharing relationships.
FISCAL IMPACT
This report has no fiscal impact.
RELATIONSHIP TO CITY COUNCIL PRIORITIES ACTION PLAN
The response to the grand jury report supports the Modern and Sustainable Organization major focus area by ensuring our ALPR system is consistent with public safety, privacy, and applicable law.
ASSOCIATED DOCUMENTS
1. SM County Grand Jury Correspondence
a. 90 Day Response Letter Request
b. Grand Jury Report - “Is Our Flock of ALPR Cameras Properly Tended”
2. Draft SSF Response to the San Mateo County Grand Jury for submittal by 11/02/2026