Report 2019-118 Recommendation 18 Responses

Report 2019-118: Automated License Plate Readers: To Better Protect Individuals' Privacy, Law Enforcement Must Increase Its Safeguards for the Data It Collects (Release Date: February 2020)

Recommendation #18 To: Los Angeles Police Department

To ensure that ALPR images are being shared appropriately, as Los Angeles develops its ALPR policy, it should be certain to list the entities with which it will share ALPR images and the process for handling image-sharing requests.

Annual Follow-Up Agency Response From October 2021

See "Sharing of ALPR Data" in Special Order No. 31, dated December 10, 2020, titled Automated License Plate Recognition Usage and Privacy Policy."

Sharing of ALPR Data. The ALPR System is a valuable investigative tool and shall be used

appropriately in accordance with this policy and the provisions of the law. When sharing

information from the ALPR System, Department employees shall do so with integrity and

confidentiality. All ALPR data recorded and/or retained by the Department shall not be sold,

shared, transferred, or otherwise disclosed for commercial purposes or to persons or entities

that are not authorized to record, retain, access or use ALPR data. The ALPR data shall only be

shared with other local law enforcement agencies that have an interagency agreement with the

Department. All current and future contracts shall be reviewed and contain a clause prohibiting

the sharing of Department ALPR data outside of the agency with whom the Department has an

agreement.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

6-Month Agency Response

As you know, the Los Angeles Police Department and the City of Los Angeles have faced multiple challenges from the COVID-19 pandemic, as well as the protests and civic unrest following the death of George Floyd. These dual challenges have placed significant burdens on the Department's resources, and as a result of responding to these events, the Department has been delayed in adequately crafting an Automated License Plate Reader policy. The Department realizes the importance of finishing and implementing this policy, especially considering the statutory requirement and the State Auditor's report and recommendations. The Department's ALPR policy is being reviewed by external policy experts and the details are being finalized. We hope to present a completed policy to the Los Angeles Board of Police Commissioners in the near future and will keep you apprised of our progress.

California State Auditor's Assessment of 6-Month Status: Pending

We acknowledge the difficulty of the current situation with COVID-19. We look forward to the department's future status reports.

60-Day Agency Response

The Department has reviewed the State Auditor's Report and recommendations and we are in the process of drafting an ALPR usage and privacy policy. We aim to present a completed policy to the Los Angeles Board of Police Commissioners in June 2020. However, due to the significant response required to the COVID-19 pandemic, and the increase in our operational needs, please consider this our response to the Report's recommendations at this time. The Department understands the importance of drafting an ALPR policy in a timely manner and, even amid this ongoing pandemic, is striving to complete a policy that takes the many considerations into account.

California State Auditor's Assessment of 60-Day Status: Pending

We acknowledge the difficulty of the current situation with COVID-19. We look forward to the department's future status reports.

All Recommendations in 2019-118

Agency responses received are posted verbatim.