Report 2019-118 Recommendation 24 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 #24 To: Los Angeles Police Department

To enable auditing of user access to and user queries of ALPR images, by April 2020, Los Angeles should assess the information its ALPR system captures when users access it to ensure that the system's logs are complete and accurate and that the logs form a reasonable basis for conducting necessary, periodic audits.

Annual Follow-Up Agency Response From October 2021

See "Records of Access and Periodic System Audits" in Special Order No. 31, dated December 10, 2020, titled Automated License Plate Recognition Usage and Privacy Policy."

Records of Access and Periodic System Audits. The ITB shall ensure that a database of records of

ALPR end-user activity, including all queries to the ALPR System is maintained. The records of

access shall be maintained for at least five (5) years. At a minimum, the records of access shall

include all of the following:

- The date and time the information is accessed;

- The license plate number or other data elements used to query the ALPR System;

- The username of the person who accessed the information; and,

- The identified authorized purpose for accessing the information.

The access and use of ALPR data through Department systems shall be subject to review and

audit by Audit Division. Audit Division shall conduct periodic audits in accordance with Audit

Division's Annual Audit Plan. Audit reports shall be maintained by the Department and

accessible for public view indefinitely. Moreover,

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.