--- page 1 --- Caution: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. 8/31/20257:57:51AM Sent: From: To: "Mark" Cc: "Steve" Bcc: Importance Normal Subject: Fwd: Benicia ALPR Policy Briefing for Police Chief and City Council Dear Chief Menesini, 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 October21st.Pleaseletmeknow ifyouhave anyquestions. Thank you, ExecutiveSummary 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— page 2 — · 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 2. Federal Data Sharing Vulnerabilities · CBP accessed 80,0o0+ Flock cameras nationwide through pilot programs · llinois 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 Strengthen Federal Restrictions ·Add technical restrictions preventing federal account creation · Mandate 48-hour City Council notification of federal contact · Annual compliance certification Limit Technology Scope · Explicitly prohibit video recording beyond license plate capture · Ban Al behavioral analysis and people tracking features ·Restrict integrationwith databroker services · Require approval for any new system capabilities
— page 3 — 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 Contract Modifications Needed
- Data Control: Require local storage options and real-time notification of third-party requests
- Capability Restrictions: Mandate written approval before enabling new features
- 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 Budget Considerations nd s nd ns ne s sn es ·Contract modifications may involve legal review costs · Potential cost savings from limiting system expansion Legal and Risk Factors · Liability exposure from federal data sharing violations · Compliance requirements under California privacy laws · Public trust issues if transparency failures continue
— page 4 — · Constitutional concerns with expanded surveillance capabilities Recommendations
- Immediate: Demand Flock restore audit functionality
- Short-term: Update policy to restrict federal sharing and system expansion
- 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 · Community engagement on enhanced oversight mechanisms
— page 5 — Public Records Exemptions Enclosed please find a copy of the response documents for your public process employed to review and produce the response documents. Reason Description Pages 1 of 1