--- page 1 --- 9/1/20259:28:06AM Sent: From: MarkMenesini<Menesini To: "Edward" Cc: Bcc: Importance Normal Subject: FW: Benicia ALPR Policy Briefing for Police Chief and City Council From: Sent: Sunday,August 31, 2025 7:58 AM To: Mark Menesini <MMenesini@ci.benicia.ca.us> Cc: Steve Young <SYoung@ci.benicia.ca.us> Subject:Fwd:BeniciaALPRPolicyBriefingforPoliceChiefandCityCouncil Caution: This email originated from outside of the organization. Do not click Dear Chief links or open attachments unless you recognize the sender and know the Menesini, content is safe. Here is an initial draft of a proposal of changes I believe that are needed to the Flock System contracts and to our current gaps. I plan to present a more fleshed out version to Council on October 21st. Please let me know if you have any questions. Thank you, Executive Summary Benicia's 52 Flock Safety cameras require immediate policy updates to address recent federal data sharing violations and system expansion beyond traditional license plate reading. Current Immediate Issues Requiring Action 1. Transparency System Failure ·Flock's audit portal is often down, eliminating public oversight, no public release of quarterly audit reports. · No visibility into actual search usage or compliance verification ·Violates department's stated transparency commitments · Logging seems to be inconsistent and shows a lack of compliance training— page 2 — 2. Federal DataSharingVulnerabilities ·CBP accessed 80,oo0+ Flock cameras nationwide through pilot programs · Illinois found 47 agencies illegally sharing despite policy prohibitions · Benicia’s current restrictions may be ineffective without technical enforcement 3. Scope Expansion Beyond ALPR · No contractual restrictions on automatic system upgrades Required Policy Enhancements StrengthenFederal Restrictions ·Add technical restrictions preventing federal account creation ·Mandate48-hourCityCouncil notificationoffederalcontact ·Annual compliance certification Limit Technology Scope ·Explicitly prohibit video recording beyond license plate capture · Ban Al behavioral analysis and people tracking features ·Restrict integration with data broker services · Require approval for any new system capabilities Enhance Oversight · Restore functioning audit system immediately · Implement monthly public reporting · Release publicly the quarterly audits and consider independent auditing · Create community oversight board or make this a function of the Open Government Comission ContractModificationsNeeded 1 . Data Control: Require local storage options and real-time notification of third-party requests 2 . Capability Restrictions: Mandate written approval before enabling new features 3 . Termination Rights: Allow contract cancellation for unauthorized system expansion 4 . Financial Penalties: Include penalties for policy violations Implementation Timeline · 30 Days: Restore audit system, assess current capabilities · 60 Days: Draft enhanced policy, implement monthly reporting · 90 Days: Present to City Council, negotiate contract modifications
— page 3 — BudgetConsiderations · Current system funded by Measure C for public safety purposes · Contract modifications may involve legal review costs · Potential cost savings from limiting system expansion Legal and Risk Factors ·Liabilityexposurefromfederaldatasharingviolations · Compliance requirements under California privacy laws ·Public trust issues if transparency failures continue ·Constitutional concernswith expanded surveillance capabilities Recommendations 1 . Immediate: Demand Flock restore audit functionality 2 . Short-term: Update policy to restrict federal sharing and system expansion 3. Long-term: Establish robust community oversight and regular policy review NextSteps · Police Chief review current system capabilities and data sharing practices · Legal counsel review proposed policy changes · Schedule City Council agenda item for policy update presentation ·Community engagement on enhanced oversight mechanisms
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