Report 2019-118 Recommendation 23 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 #23 To: Los Angeles Police Department

To ensure that ALPR system access is limited to agency staff who have a need and a right to use ALPR data, by August 2020, Los Angeles should develop and implement procedures for granting and managing user accounts that include, but are not limited to, requiring that supervisors must approve accounts for users, providing training to users before granting accounts, suspending users after defined periods of inactivity, and requiring regular refresher training for active users and training for users before reactivating previously inactive accounts. Los Angeles should also ensure that it has procedures in place to deactivate an account immediately for an account holder who separates from the agency or who no longer needs a user account.

Annual Follow-Up Agency Response From October 2021

See page 2 in Special Order No. 31, dated December 10, 2020, titled Automated License Plate Recognition Usage and Privacy Policy."

ALPR Data Users —Defined. Any active Department employees (both sworn and civilian) or

independent contractors, who have received written authorization from their supervisor and

have been granted permission from ITB to query the ALPR System.

Note: Employees equipped with the ALPR Cameras in their Department vehicles may

receive an ALPR Hit, and when used for this purpose officers receive on-the job training.

They have no ability to add, remove, or change any information in the ALPR System.

ALPR Data Users Training. All ALPR Data Users shall complete one of the Department's

POST-certified training courses on accessing and using ALPR data prior to querying the ALPR

System. A second course is offered as supplemental training for ALPR Data Users on search

capabilities.

ALPR System Administrators. All ALPR System Administrators shall receive training to fulfill

their job responsibilities by a current ALPR System Administrator and/or vendor prior to

accessing the ALPR System as an ALPR System Administrator.

Note: Any ALPR Data User or ALPR System Administrator who has not used their ALPR

System account for one year and whose duties require their use of the ALPR System, shall

complete a reorientation training course prior to accessing the ALPR System.

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.