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HomeMy WebLinkAboutStaff Report 2607-6594CITY OF PALO ALTO CITY COUNCIL Special Meeting Monday, August 24, 2026 Council Chambers & Hybrid 5:30 PM     Agenda Item     C.Surveillance Technology Report for Fiscal Year 2026; CEQA Status- Not a project City Council Staff Report From: City Manager Report Type: INFORMATION REPORTS Lead Department: City Manager Meeting Date: August 24, 2026 Report #:2607-6594 TITLE Surveillance Technology Report for Fiscal Year 2026; CEQA Status- Not a project RECOMMENDATION This is an informational report about the City's use of surveillance technology in Palo Alto during Fiscal Year 2026. No City Council action is required. BACKGROUND In September 2019, the City Council adopted the Surveillance and Privacy Protection Ordinance, establishing criteria and procedures for the protection of personal privacy when considering the acquisition and use of surveillance technologies by the City.1 Codified in the Municipal Code at Chapter 2.30, Part 6A, the ordinance also outlines ongoing monitoring and annual reporting of such technologies. Annual reporting must include the following information pursuant to PAMC section 2.30.680(a): 1. A brief description of how each City Council-approved surveillance technology was used, including whether it captures images, sound, or information regarding members of the public who are not suspected of engaging in unlawful conduct; 2. Whether and how often data acquired through the use of surveillance technology was shared with outside entities, the names of any recipient entity, the types of data disclosed, and the reason for disclosure; 3. A summary of any community complaints or concerns about surveillance technology; 4. Non-privileged and non-confidential information regarding the results of any internal audits, information about violations of the surveillance use policy, and any actions taken in response; 5. Whether the surveillance technology has been effective at achieving its identified purpose; 1 City Council Meeting 09/18/2018, Agenda Item#8, 6. The number and nature of Public Records Act requests relating to the surveillance technology; 7. Annual costs for the surveillance technology and for compliance with this surveillance; and 8. Other relevant information as determined by the City Manager. ANALYSIS Pursuant to the Surveillance and Privacy Protection Ordinance, the following departmental activities are summarized in this report. Information Technology (IT) Department Council Chambers Security Cameras. In April 2025, City Council approved the purchase of security cameras to enhance the safety and security of the Council Chambers.3 Equipment necessary for facilitating public meetings, including computers, monitors, and microphones, is kept in the Council Chambers and the general area. The public can access Council Chambers for public meetings or authorized special events. Outside of public meetings, room use is limited to staff in order to minimize tampering and the risk of damage to City property and equipment. In the past, there have been incidents of vandalism, theft, and interference with A/V equipment that is essential in supporting public meetings in Council Chambers. This surveillance system captures audio and video, which is required to be retained for 1 year by the City. Since camera installation there have been no additional incidents, indicating successful deterrence Surveillance will also assist should an incident occur. Additionally, no data was shared externally during the reporting period. The total contract cost is $4,886, which includes acquisition of surveillance cameras, monitoring systems, storage, maintenance, and personnel for oversight. During this reporting period, there have been no formal complaints, no reported use violations, and no Public Records Act requests. This project also includes a one-time cost of $5,400 for installation and an annual $605 licensing fee. The IT department funds this contract. Police Department Body Worn, Vehicle, and Interview Cameras. On June 18, 2024, City Council approved the contract with LensLock, a technology system that is used to document police contacts with the public.4 This Digital Evidence Management System (DEMS) is fully integrated with in-car, interview, and body-worn cameras used to capture video and audio. This technology is used for 3 City Council Meeting 04/21/2025, Agenda Item#10 4 City Council Meeting 06/18/2024, Agenda Item #AA1, law enforcement activities including, but not limited to, traffic stops, parking enforcement, suspect interviews, witness interviews, and other public contact in response to a call for service. It is also used when investigating criminal activity through police user-activated audio and video recordings. The system’s metadata is automatically uploaded into the evidence management system application, where the video assets are verified as original or exact duplicates (non- edited data) and managed as evidence. This technology has successfully achieved its purpose, enabling greater transparency and accountability. The Police Department also worked with the vendor to improve their Digital Evidence Management System DEMS. These updates delayed the body-worn and in-car systems implementation. Vehicle installation began in August 2025, and the fleet was fully upgraded to Lenslock in December 2025. GPS Vehicle Tracking. On April 15. In 2025, the City Council approved the contract with Starchase LLC for GPS vehicle-tracking implementation to track vehicles that may have been used in the commission of a crime.7 This technology is able to be launched from a patrol vehicle onto a fleeing vehicle to capture the vehicle’s GPS location. Tracking implementation has been successful, and many suspect vehicles have stopped once they notice a tracking device has been deployed. The total cost of a three-year term is not to exceed $224,657. eCitation Devices. On March 14, 2022, City Council approved the acquisition of handheld citation devices with Optical Character Recognition (OCR) technology for traffic violations by police officers.8 When used by officers, the device’s camera captures license plate images, which are processed through OCR to retrieve vehicle make and model information. This eliminates the need for manual entry into the records management system (RMS). In FY 2026, the total contract and maintenance costs to the General Fund was $23,714. 7 City Council Meeting 04/15/2024, Agenda Item#11, 8 City Council Meeting 03/14/2022, https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=81706&dbid=0&repo=PaloAlto The Police Department issued over 1,500 electronic citations in FY 2026. By implementing electronic citations, the data is automatically uploaded to the Police Records Management System (RMS), reducing staff time required to manually enter citations. This improves efficiency, thereby successfully achieving its intended purpose. Also, citations are electronically uploaded to the Santa Clara Traffic Court System. To date, there have been no formal complaints, no reported violations of use, and no Public Records Act requests related to this system. Fixed Automatic License Plate Recognition (ALPR). On April 3, 2023, City Council approved the contract with Flock Safety to implement fixed Automated License Plate Recognition as well as approve a surveillance use policy for the new camera equipment.11 In December 2024, City Council approved the deployment of 10 additional Automated License Plate Recognition cameras.12 ALPR technology uses a combination of cameras and computer software to scan license plates of passing vehicles and other details such as make, model, type, and color. The technology provides real-time alerts when stolen or wanted cars enter an area and provides enhanced investigative capabilities when a crime has already occurred. The contract cost in FY 2026 was $83,500. This was paid for using a combination of the General Fund and a State grant. Attachment A, where data is shared for law enforcement investigative purposes related to a specific criminal investigation. The Department has taken steps to minimize any potential misuse by limiting data sharing strictly with local law enforcement agencies per the MOU, and requiring them to abide by California law, which prohibits sharing data with Federal or out-of-state agencies. 13 This allowed out-of-state or federal law enforcement to query data from over 6,000 cameras across 400 agencies, including 10 in Palo Alto. All searches required articulation of legitimate law enforcement purpose. Palo Alto became aware of the issue in December 2025 and later learned the feature had already been disabled for Palo Alto by late October 2025 and for all other California agencies by March 2025. 11 City Council Meeting 04/03/2023, Agenda Item #11, 12 City Council Meeting 12/02/2024, Agenda Item #11, 13 City Council Meeting 06/01/2026 federal agencies. Community members also expressed concerns about whether the Department should continue its relationship with the vendor. This surveillance technology has provided significant public safety benefits. It has contributed to the recovery of stolen and wanted vehicles, and arrests of wanted people. Investigative searches have also contributed to the safe recovery of missing persons and assisted law enforcement in ongoing criminal investigations. Below are a few examples to illustrate the successful application of this technology: An elderly man, who suffers from dementia, was discovered to have taken his caregiver’s vehicle without permission and was missing. Flock data was used to determine his path of travel and, ultimately, locate him safely within the hour; A despondent teenager suffering from a mental health crisis had made threats of suicide before leaving home in a vehicle. Flock data was used to determine their path of travel, and a Flock real-time alert allowed officers to locate them safely and ensure they received appropriate care; Two suspects committed an armed robbery in Palo Alto after having just committed an armed robbery in another city. A Flock real-time alert allowed officers to locate the vehicle’s direction of travel within minutes, and additional Flock alerts in another city aided officers as they pursued the vehicle, apprehended the suspects, and recovered multiple firearms; and Two suspects committed a robbery at a shopping center and injured a police officer during their escape. Palo Alto Flock data was used to identify the suspects and Flock data in other cities enabled PAPD detectives to locate the suspect vehicle and, ultimately, arrest both suspects within 24 hours. Attachment B. The City has enlisted the independent Police Auditor to address this topic in a special report, which staff anticipated will be presented to Council later this year. Transportation Automatic License Plate Recognition (LPR) for Parking Enforcement. In February 2021, City Council approved the use of license plate recognition technology and corresponding LPR surveillance policy to be used for parking enforcement and permit management.17 LPR technology captures license plate images to identify vehicles and track parking time. 17 City Council Meeting 02/22/21, During the reporting period, there have been no formal complaints filed, use violations, or Public Records Act requests. ALPR has been successful in supporting City Residential Preferential Parking (RPP) programs by providing both enforcement and permit management efficiencies. Images of license plates are utilized as supporting documentation to verify parking time limits were exceeded. All other images are routinely purged in compliance with City surveillance policy adopted for this program. No data was shared externally during this reporting period. Ongoing costs are included in combined Duncan, LAZ and Turbodata contract costs. The total contract is $750,000, funded by the General Fund and Parking Program Funds. Traffic Signal Detection Hardware. On February 6, 2023, City Council approved the contract with Iteris for traffic signal operations.19 These devices are designed solely to detect when a vehicle is approaching an intersection to provide the vehicle with a green light phase. Data collection is used to support traffic control measures, roadway improvements, signal timings, pedestrian and bicycle roadway improvements. Together, these systems enhance traffic signal operations. The feature of this technology to capture images, sound, or any other identifying information is turned off. Live or sample video feeds may be used during configuration and testing to ensure detection capabilities are set up and operate correctly. After completion of configuration, the live video feed would be turned off. The technology has been effective in detecting vehicle presence and allowing for optimal traffic signal operations. In the past, staff have used live video feeds to observe real-time traffic conditions and to adjust traffic signal operations. In upcoming years, Staff may use technology for vehicle count and time of day data to assist with operations and programming of signal timing Traffic Data Collection Cameras. In April 2021, Council approved the use of technology for traffic data collection.20 The video technology is used solely to capture bicycle, pedestrian, parking occupancy, and vehicle turning-movement counts. This data helps inform appropriate traffic control measures, roadway enhancements, signal timing adjustments, and pedestrian and bicycle safety improvements. This technology does not collect visual, audio, location, or any personal identifiable information of individuals or vehicles. Office of Transportation works 19City Council Meeting 02/06/2023, Agenda Item #9, 20 City Council Meeting 04/05/2021, Agenda Item #4 with the vendor Data Service CA LL on projects where cameras are used. Below are some examples of projects used in FY26. This data collection method is highly effective and provides precise counts of vehicles, pedestrians, and bicycles, as well as accurate vehicle speed data. Video technology was used in February 2026 at Old Trace Rd and Arastradero Rd to determine whether traffic volumes met criteria for installing a Rectangular Rapid Flashing Beacon (RRFB). Video technology was used in March 2026 at 21 intersections in the Midtown neighborhood as part of the South Palo Alto Bike/Ped Connectivity Project. During the reporting period, there have been no formal complaints filed, use violations, or Public Records Act requests. Additionally, no data was shared externally. Cameras are installed only during the data-collection period and are accompanied by visible hand-tags labelled “Traffic Data Camera,” including the service provider’s name and contact phone number. This technology has been successful by providing the Office of Transportation with data that is expensive to collect manually, while reducing the potential for error. The total cost for a 4-year term is not to exceed $200,000, funded by the Capital Improvement Program and the General Fund. Tenants on City Property Ada’s Café Security Cameras. On June 16, 2025, Council approved the Surveillance Use Policy for security cameras at Ada’s Café at Mitchell Park Community Center and Library.23 Incidents of vandalism to Ada’s property had increased, and the owners had an interest in installing cameras to deter such incidents. According to the owners, some of the vandalized items include the café’s outdoor furniture and equipment. The goal of this technology is to enhance safety and security both inside and outside Ada’s café. This surveillance captures real-time video and audio of the interior and exterior areas. Cameras are positioned to monitor key entry points to monitor key entry points and café seating areas. Staff at Ada’s café have reported feeling safer with the camera installations. Surveillance footage will be accessible only to designated café management and City police personnel for law enforcement purposes. According to Ada Cafe‘s staff, there have been no formal complaints filed, violations, or Public Records Act requests during the reporting period. Additionally, no data was shared externally. This technology is paid for by Ada’s café and there is no cost to the City for this project. 23 City Council Meeting 06/16/2025, Item #9 Palo Alto Museum. In December 2025, City Council approved the installation of security cameras to enhance the safety and security of the Palo Alto Museum (PAM) at the Roth Building located at 300 Homer Avenue.25 Security cameras have been installed on the exterior and interior of the building to prevent incidents of vandalism or theft. The surveillance system captures video, audio (if permitted by law), and associated metadata, including date, time, and camera location. The footage obtained from the cameras can provide evidence to the Palo Alto Police Department (PAPD) if an incident should occur inside or outside the building. Any technology that collects information exclusively on or regarding City employees or contractors; Any technology used as part of the Foothill Fire Early Warning System to detect fire within the following area: o West Side: Skyline Blvd (Hwy 35) from Route 84 (Woodside Rd/La Honda Rd.) to Hwy 9 o North Side: Route 84 from Skyline to Alameda de la Pulgas o East Side: Alameda de las Pulgas to Santa Cruz Avenue to Junipero Serra Rd. to Foothill Expwy o Southside Side: Draw a line from the intersection of Hwy 9 and Hwy 35 to the intersection of Foothill Expwy at Magdalena. Foothill Fire Safety Cameras. As part of the improvement to the Foothills Management Plan, the Office of Emergency Services deployed several AlertWildfire cameras in the Foothills for early detection of wildfires as part of an interagency and countywide effort. 25 City Council Meeting 12/15/2025, Agenda Item#7 STAKEHOLDER ENGAGEMENT ENVIRONMENTAL REVIEW ATTACHMENTS APPROVED BY: ATTACHMENT A Data is shared with the below entities, pursuant to MOU, on an on-going basis. Data is shared for legitimate law enforcement investigative purposes if responsive to a specific query made by an entity relating to a specific criminal investigation. Alameda County CA SO Albany CA PD Belmont CA PD Benicia CA PD Berkeley CA PD Burlingame CA PD California Highway Patrol Campbell CA PD Capitola CA PD Carmel CA PD Central Marin CA PD Citrus Heights CA PD Clayton CA PD Colma CA PD Concord CA PD Danville CA PD Dixon CA PD Dublin CA PD (ACSO) East Palo Alto CA PD Elk Grove CA PD Fairfield CA PD Folsom CA PD Foster City CA PD Fremont CA PD Gilroy CA PD Hayward CA PD Hillsborough CA PD Lincoln CA PD Livermore CA PD Los Altos CA PD Marin County CA SO Menlo Park CA PD Mill Valley CA PD Milpitas CA PD Monterey County CA SO Monterey County District Attorney's Office Napa County CA SO Newark CA PD Oakland CA PD Oakley CA PD Pleasant Hill CA PD Pleasanton CA PD Redwood City CA PD Rohnert Park Department of Public Safety (CA) Roseville CA PD Sacramento CA DA Salinas CA PD San Bruno CA PD San Francisco CA PD San Joaquin County CA SO San Jose CA PD San Leandro CA PD San Mateo CA PD San Mateo County CA SO San Pablo CA PD San Rafael CA PD Santa Clara CA PD Santa Rosa CA PD Seaside CA PD Solano County CA SO Stanford University CA PD Suisun City CA PD Sunnyvale CA PD Town of Los Gatos CA Tracy CA PD Turlock CA PD Union City CA PD Vacaville CA PD Vallejo CA PD Walnut Creek CA PD Watsonville CA PD West Sacramento CA PD West Valley Mission College Dist Campus (CA) ATTACHMENT B Date of Request Information Requested Information Provided 7/22/2025 1. Organization Audit in Flock. 2. Network Audit in Flock. 3. A list of network share settings that include: https://transparency.flocksafety.com/palo-alto-ca-pd https://www.paloalto.gov/Departments/Police/Public-Information-Portal/Automated-License-Plate-Recognition-ALPR https://www.paloalto.gov/News-Articles/Police-Department/Police-Receive-State-Grant-for-5M-to-Combat-Organized-Retail- Theft#:~:text=You%20Are%20Here%20:%20Home%20/%20Police, vehicles%20while%20committing%20their%20crimes. https://www.cityofpaloalto.org/files/assets/public/v/1/administrative-services/budget-adjustments-and-monitoring/fy-2024-budget- adjustments/december/december-4th-ccm-item-4-staff-report.pdf 9/20/2025 1. Organization Audit in Flock. 2. Network Audit in Flock. https://transparency.flocksafety.com/palo-alto-ca-pd 11/5/2025 Name: C. Per Org Name: Miami-Dade FL SO Total Networks Searched: 5889 Time Frame: 12/24/2024, 03:28:29 PM UTC 01/23/2025, 03:28:29 PM UTC Search Time: 01/23/2025, 03:28:36 PM UTC Name: T. Hut Org Name: Palos Heights IL PD Total Networks Searched: 5927 Time Frame: 01/21/2025, 01:28:31 PM UTC 01/28/2025, 01:28:31 PM UTC Search Time: 01/28/2025, 01:28:38 PM UTC Name: L. Gut Org Name: Marshall County AL SO https://transparency.flocksafety.com/palo-alto-ca-pd Date of Request Information Requested Information Provided Total Networks Searched: 6076 Time Frame: 01/30/2025, 02:26:12 PM UTC 01/31/2025, 02:26:12 PM UTC Search Time: 01/31/2025, 02:26:17 PM UTC 11/11/2025 All images and/or video recordings taken between 11/08/2025 and 11/10/2025 by the Flock cameras at the following two intersections: (1) Alma Street and Palo Alto Avenue (2) Middlefield Road and Everett Avenue. https://transparency.flocksafety.com/palo-alto-ca-pd Date of Request Information Requested Information Provided 11/11/2025 all of the images and data logs created by all of the Flock Safety cameras installed in the city between 7:30 AM and 8:00 AM on November 6, 2025 https://transparency.flocksafety.com/palo-alto-ca-pd 2/27/2026 1. Comprehensive Audit Logs (CSV/Excel Format) 2. Aggregate Administrative Reports 3. Directives on Redaction & Data Integrity The City has reviewed its files and has located records responsive to the request. Beginning this week, recognizing public interest on this topic, the Police Department will begin proactively posting on a monthly cadence partially redacted Flock search logs on the City’s ALPR website. These logs include information concerning ALPR queries performed by PAPD users, as well as queries performed by other agencies, that has not previously been released pursuant to a legal exemption. Additionally, the City continues to use best practices to secure Palo Alto ALPR data, including a 30-day limit on data retention, requiring MOUs with other agencies for data sharing, and internal policy controls. The audits have been published in a way that does not compromise law enforcement efforts of the Palo Alto Police Department and other law enforcement agencies. Certain data has been excluded from these audits to protect these interests pursuant to California Government Code sections 7922.000 and 7923.600. The City will not release any additional information beyond what has been published in these audit logs. Please access the Records Center at the following LINK to access records responsive to your request. You can also find this information by visiting the City's ALPR Website 3/4/2026 Attachments included in the Council Bundle - February 23, 2026FW Avoiding Caltrain suicides in Palo Alto.msgFW Utilities analysis of 3606 el Camino Real development. msgFw DHS contracts in Palo Alto.msgFW CPAU Fee. msgFlock Surveillance.msgFW WIRED inquiry Palantir. msgRE Urgent Ongoing Health Harm and Unequal Housing Response.msgRE Palo Alto Link - please replace it.msg The City has reviewed its files and has located records responsive to your request. Please log in to the Records Center at the following LINK to retrieve the appropriate response. Some records have been redacted to protect nonpublic contact information and/or other sensitive personal data pursuant to Gov. Code section 7922.000. Some records are exempt from disclosure pursuant to Evid. Code sections 1040 and 1041 and Gov. Code section 7927.705, under the official information privilege and/or confidential informant exemptions. Date of Request Information Requested Information Provided 3/6/2026 1. A log of all queries by outside police agencies into the city's Flock Safety database since the ALPR cameras were turned on, including the date of the query, the reason for the query, the date the query was fulfilled and the name of the requesting agency. 2. A list of settings that are offered by Flock Safety showing whether the police department has enabled them or not. Please show the settings that were enabled on March 1, 2026, and on March 1, 2025, to compare the two dates. 3. Any audit reports on Flock Safety and the ALPR data. 4. All emails between police department employees and Flock Safety employees since Jan. 1, 2026. “The City has reviewed its files and has located records responsive to the request. Beginning this week, recognizing public interest on this topic, the Police Department will begin proactively posting on a monthly cadence partially redacted Flock search logs on the City’s ALPR website. These logs include information concerning ALPR queries performed by PAPD users, as well as queries performed by other agencies, that has not previously been released pursuant to a legal exemption. Additionally, the City continues to use best practices to secure Palo Alto ALPR data, including a 30-day limit on data retention, requiring MOUs with other agencies for data sharing, and internal policy controls. In late 2023, unbeknownst to many users including PAPD, Flock added a new “Nationwide Lookup” search feature. Using this feature, an out-of-state local law enforcement or federal agency could perform a broad search of data from Flock’s entire nationwide network of over 6000 cameras, including the 20 cameras then-deployed in Palo Alto. The feature did not enable targeted searches of any specific agency’s data. These searches could only be performed system-wide when a full 7-digit license plate number was known and only based on the articulation of a legitimate law enforcement purpose. PAPD was first made aware of this issue in December of 2025 and subsequently learned that Flock had already disabled the feature for PAPD by late October 2024 and for all California law enforcement agencies by March 2025. While its data was included in the “Nationwide Lookup” searchable dataset during this period, PAPD has worked with Flock to confirm that no PAPD data (i.e., license plates captured by Palo Alto cameras) was actually received by any out-of-state agency or federal agency as a result of any “Nationwide Lookup” search. In other words, PAPD had no records that matched the “Nationwide Lookup” searches performed by out of state or federal agencies. Even though no PAPD data was shared, PAPD reviewed the searches performed by out-of-state local law enforcement and federal agencies via the “Nationwide Lookup” feature and found no instances where a search appeared to have been performed for an improper purpose. Additionally, PAPD found that no searches had been performed by ICE, Customs and Border Patrol, or the Department of Homeland Security, and that no searches appeared to be associated with immigration enforcement or reproductive rights enforcement. In January 2026, the Department added initial information on this issue to its ALPR webpage and previously updated the information in February of 2026. PAPD has been in contact with Flock’s executive leadership to express our concerns and, in response to PAPD’s suggestion, Flock has expressed a strong Date of Request Information Requested Information Provided willingness to pursue third party verification that this issue has been resolved. While the City’s Auditor is unable to perform this task, work is underway to identify an alternate auditor. Our goal in this review would be to conduct a technical as well as operational review to confirm that Flock’s practices address the City’s expectations for security, transparency, and reporting of system features and changes. The Department is confident that its training, Surveillance Use Policy, 30-day data retention period, and requirement of an MOU for each agency with which it shares, meet or exceed industry standards. With that, as recommended by the City Council’s Policy & Services Committee, PAPD has discussed with the Independent Police Auditor a review of its internal policies and procedures with an eye toward areas where we may be able to do even better. Staff anticipates reporting to Council in early June with further updates on this topic. James Reifschneider, Chief of Police” The audits have been published in a way that does not compromise law enforcement efforts of the Palo Alto Police Department and other law enforcement agencies. Certain data has been excluded from these audits to protect these interests pursuant to California Government Code sections 7922.000 and 7923.600. Please access the Records Center at the following LINK to access records responsive to your request. Date of Request Information Requested Information Provided 3/10/2026 The monthly network audit and organization audit from Flock Safety for each month from Jan. 1, 2025, until March 10, 2026. “The City has reviewed its files and has located records responsive to the request. Beginning this week, recognizing public interest on this topic, the Police Department will begin proactively posting on a monthly cadence partially redacted Flock search logs on the City’s ALPR website. These logs include information concerning ALPR queries performed by PAPD users, as well as queries performed by other agencies, that has not previously been released pursuant to a legal exemption. Additionally, the City continues to use best practices to secure Palo Alto ALPR data, including a 30-day limit on data retention, requiring MOUs with other agencies for data sharing, and internal policy controls. In late 2023, unbeknownst to many users including PAPD, Flock added a new “Nationwide Lookup” search feature. Using this feature, an out-of-state local law enforcement or federal agency could perform a broad search of data from Flock’s entire nationwide network of over 6000 cameras, including the 20 cameras then-deployed in Palo Alto. The feature did not enable targeted searches of any specific agency’s data. These searches could only be performed system-wide when a full 7-digit license plate number was known and only based on the articulation of a legitimate law enforcement purpose. PAPD was first made aware of this issue in December of 2025 and subsequently learned that Flock had already disabled the feature for PAPD by late October 2024 and for all California law enforcement agencies by March 2025. While its data was included in the “Nationwide Lookup” searchable dataset during this period, PAPD has worked with Flock to confirm that no PAPD data (i.e., license plates captured by Palo Alto cameras) was actually received by any out-of-state agency or federal agency as a result of any “Nationwide Lookup” search. In other words, PAPD had no records that matched the “Nationwide Lookup” searches performed by out of state or federal agencies. Even though no PAPD data was shared, PAPD reviewed the searches performed by out-of-state local law enforcement and federal agencies via the “Nationwide Lookup” feature and found no instances where a search appeared to have been performed for an improper purpose. Additionally, PAPD found that no searches had been performed by ICE, Customs and Border Patrol, or the Department of Homeland Security, and that no searches appeared to be associated with immigration enforcement or reproductive rights enforcement. In January 2026, the Department added initial information on this issue to its ALPR webpage and previously updated the information in February of 2026. PAPD has been in contact with Flock’s executive leadership to express our concerns and, in response to PAPD’s suggestion, Flock has expressed a strong willingness to pursue third party verification that this issue has been resolved. While the City’s Auditor is unable to perform this task, work is underway to identify an alternate auditor. Our goal in this review would be to conduct a technical as well as operational review to confirm that Flock’s practices address the City’s expectations for security, transparency, and reporting of system features and changes. The Department is confident that its training, Surveillance Use Policy, 30-day data retention period, and requirement of an MOU for eac Date of Request Information Requested Information Provided h agency with which it shares, meet or exceed industry standards. With that, as recommended by the City Council’s Policy & Services Committee, PAPD has discussed with the Independent Police Auditor a review of its internal policies and procedures with an eye toward areas where we may be able to do even better. Staff anticipates reporting to Council in early June with further updates on this topic.James Reifschneider, Chief of Police”The audits have been published in a way that does not compromise law enforcement efforts of the Palo Alto Police Department and other law enforcement agencies. Certain data has been excluded from these audits to protect these interests pursuant to California Government Code sections 7922.000 and 7923.600. Please access the Records Center at the following LINK to access records responsive to your request. 3/13/2026 1. Organization Audit in Flock. 2. Network Audit in Flock. 3. A list of network share settings The City has reviewed its files and has located records responsive to your request. Please log in to the Public Records Center at the following LINK to retrieve the appropriate response. In addition, the records mentioned in your request may also be found here: www.paloalto.gov/PAPDalpr Date of Request Information Requested Information Provided 3/13/2026 All correspondence (email, text or otherwise) between March 1, 2024 and the date of this request between representatives of the Palo Alto Police Department and Flock Safety. Various email messages 3/17/2026 Network Audit in Flock for the specific dates below:12/02/2024,12/04/2024,12/13/2024,01/15/2025,12/30/2024,01/24/2025,01/27/2025,01/08/2025,10/17/2024,11/09/2024,12/14/2024,05/20/20 25,04/29/2025, The City has reviewed its files and has located responsive records to your request. This request is very similar to your request referenced R000487-031326 and the records in this request have been released in that request. Please log in to the Public Records Center Portal at the following LINK to retrieve the appropriate responsive documents. The records mentioned in this request may be found here www.paloalto.gov/PAPDalpr 4/13/2026 The location of the Flock Camera within the city The City has reviewed your request and has determined that the records requested are exempt from disclosure under the California Public Records Act for the following reasons: The City considers records showing the locations of Flock ALPR cameras exempt from disclosure pursuant to Gov. Code sections 7923.600 (Investigatory Records) and 7922.000 (Public Interest). The Palo Alto Police Department considers these files exempt under GC sec. 7923.600 because they are “records of… investigations conducted by” PAPD, ”records of intelligence information” of PAPD, and “investigatory… files” of PAPD. Releasing the location of the ALPRs would severely compromise ongoing investigations conducted by the Department and are contained in records of investigations conducted by PAPD. Releasing ALPR locations publicly would allow suspected criminals to evade areas monitored by PAPD’s ALPRs, thus defeating their purpose. For the Date of Request Information Requested Information Provided same reasons, records detailing the locations of ALPRs are exempt from disclosure pursuant to GC sec. 7922.000 because the public interest in not disclosing the locations significantly outweighs the public interest in disclosure. There is a high public interest in stopping criminal activity that occurs within the City of Palo Alto and releasing ALPR locations would severely hinder that public interest. For more information on the City’s use of ALPRs, please visit the City’s website (https://www.paloalto.gov/Departments/Police/P ublic-Information- Date of Request Information Requested Information Provided Portal/Automated-License-Plate-Recognition-ALPR) or the City’s Flock Transparency Portal (https://transparency.flocksafety.com/palo-alto-ca-pd) 4/20/2026 PAPD Flock Organization and Network Audit Reports 2023 to 2026 “The City has reviewed its files and has located records responsive to the request. Beginning this week, recognizing public interest on this topic, the Police Department will begin proactively posting on a monthly cadence partially redacted Flock search logs on the City’s ALPR website. These logs include information concerning ALPR queries performed by PAPD users, as well as queries performed by other agencies, that has not previously been released pursuant to a legal exemption. Additionally, the City continues to use best practices to secure Palo Alto ALPR data, including a 30-day limit on data retention, requiring MOUs with other agencies for data sharing, and internal policy controls. In late 2023, unbeknownst to many users including PAPD, Flock added a new “Nationwide Lookup” search feature. Using this feature, an out-of-state local law enforcement or federal agency could perform a broad search of data from Flock’s entire nationwide network of over 6000 cameras, including the 20 cameras then-deployed in Palo Alto. The feature did not enable targeted searches of any specific agency’s data. These searches could only be performed system-wide when a full 7-digit license plate number was known and only based on the articulation of a legitimate law enforcement purpose. PAPD was first made aware of this issue in December of 2025 and subsequently learned that Flock had already disabled the feature for PAPD by late October 2024 and for all California law enforcement agencies by March 2025. While its data was included in the “Nationwide Lookup” searchable dataset during this period, PAPD has worked with Flock to confirm that no PAPD data (i.e., license plates captured by Palo Alto cameras) was actually received by any out-of-state agency or federal agency as a result of any “Nationwide Lookup” search. In other words, PAPD had no records that matched the “Nationwide Lookup” searches performed by out of state or federal agencies. Even though no PAPD data was shared, PAPD reviewed the searches performed by out-of-state local law enforcement and federal agencies via the “Nationwide Lookup” feature and found no instances where a search appeared to have been performed for an improper purpose. Additionally, PAPD found that no searches had been performed by ICE, Customs and Border Patrol, or the Department of Homeland Security, and that no searches appeared to be associated with immigration enforcement or reproductive rights enforcement. In January 2026, the Department added initial information on this issue to its ALPR webpage and previously updated the information in February of 2026. Date of Request Information Requested Information Provided PAPD has been in contact with Flock’s executive leadership to express our concerns and, in response to PAPD’s suggestion, Flock has expressed a strong willingness to pursue third party verification that this issue has been resolved. While the City’s Auditor is unable to perform this task, work is underway to identify an alternate auditor. Our goal in this review would be to conduct a technical as well as operational review to confirm that Flock’s practices address the City’s expectations for security, transparency, and reporting of system features and changes. The Department is confident that its training, Surveillance Use Policy, 30-day data retention period, and requirement of an MOU for each agency with which it shares, meet or exceed industry standards. With that, as recommended by the City Council’s Policy & Services Committee, PAPD has discussed with the Independent Police Auditor a review of its internal policies and procedures with an eye toward areas where we may be able to do even better. Staff anticipates reporting to Council in early June with further updates on this topic.James Reifschneider, Chief of Police”The audits have been published in a way that does not compromise law enforcement efforts of the Palo Alto Police Department and other law enforcement agencies. Certain data has been excluded from these audits to protect these interests pursuant to California Government Code sections 7922.000 and 7923.600. Please access the Records Center at the following LINK to access records responsive to your request. Date of Request Information Requested Information Provided 4/28/2026 For the time period of January 1, 2023 to present: 1. Documents showing compliance with Section 7 of the City’s Surveillance Use Policy 2. The annual audits of the City’s Flock system as required in Paragraph 7 of the Surveillance Use policy and the annual memos to Police Chief prepared pursuant thereto; 3. For each search by an unauthorized outside agency (defined as out-of-state or federal or non public agency), please submit the reason for the search. (Note the search column in previously produced audits was improperly redacted in that the searches did not appear to relate to ongoing Palo Alto or even California investigations.) 4. All communications between representatives of PAPD and any Palo Alto city councilmember regarding Flock. The Palo Alto Police Department has reviewed its files and has located responsive records to your request. The City will not be releasing the reason listed in the network Flock audit pursuant to Cal. Gov. Code § 7923.600(a) as the records are exempt from from the CPRA ad investigation conducted by any state or local police agency. Please direct your question to the agency you would like to obtain "reason for the search" information. The City is searching for records listed in your request #4 and will respond on or before May 26, 2026. Please log in to the Public Records Center at the following LINK to retrieve the appropriate responsive documents. 4/29/2026 Email correspondence related to a webinar conducted by Flock Group Inc. DBA Flock Safety with the subject line containing "How to Speak to City Councils: Meeting the Moment with Confidence" and/or "Thank you for registering" with "do_not_reply@on24event.com" in any of the email headers.For this request, please include records from the following date range:March 1, 2026 through May 28, 2026. The City has reviewed your request and has determined that the records requested are exempt from disclosure under the California Public Records Act for the following reasons: The City considers records showing the locations of Flock ALPR cameras exempt from disclosure pursuant to Gov. Code sections 7923.600 (Investigatory Records) and 7922.000 (Public Interest). The Palo Alto Police Department considers these files exempt under GC sec. 7923.600 because they are “records of… investigations conducted by” PAPD, ”records of intelligence information” of PAPD, and “investigatory… files” of PAPD. Releasing the location of the ALPRs would severely compromise ongoing investigations conducted by the Department and are contained in records of investigations conducted by PAPD. Releasing ALPR locations publicly would allow suspected criminals to evade areas monitored by PAPD’s ALPRs, thus defeating their purpose. For the same reasons, records detailing the locations of ALPRs are exempt from disclosure pursuant to GC sec. 7922.000 because the public interest in not disclosing the locations significantly outweighs the public interest in disclosure. There is a high public interest in stopping criminal activity that occurs within the City of Palo Alto and releasing ALPR locations would severely hinder that public interest. For more information on the City’s use of ALPRs, please visit the City’s website (https://www.paloalto.gov/Departments/Police/Public-Information-Portal/Automated- License-Plate-Recognition-ALPR) or the City’s Flock Transparency Portal (https://transparency.flocksafety.com/palo- alto-ca-pd) Date of Request Information Requested Information Provided 5/28/2026 Email correspondence related to a webinar conducted by Flock Group Inc. DBA Flock Safety with the subject line containing "How to Speak to City Councils: Meeting the Moment with Confidence" and/or "Thank you for registering" with "do_not_reply@on24event.com" in any of the email headers. For this request, please include records from the following date range: March 1, 2026 through May 28, 2026. The City has reviewed its files and has located records responsive to your request. These are all records the City has related to this Webinar. No staff member attended the webinar, so the invitations are the only relevant records. Please log in to the Records Center at the following LINK to retrieve the appropriate response. 6/4/2026 1. All Surveillance Reports as required under PAMC Section 2.30.670 for Flock Safety ALPRs. 2. All documents related to a webinar conducted by Flock Group Inc. DBA Flock Safety titled "How to Speak to City Councils: Meeting the Moment with Confidence", including an Updated social toolkit for PIOs, Chief-to-Council guide with added trust and compliance guidance and Objection-handling playbook, including: Clear ways to reframe common concerns and respond to misinformation. For this request, please include records from the following date range: March 1, 2026 through May 28, 2026. The City has reviewed its files and has located records responsive to your request. These are all records the City has related to this Webinar. No staff member attended the webinar, so the invitations are the only relevant records. Please log in to the Records Center at the following LINK to retrieve the appropriate response. Date of Request Information Requested Information Provided 6/15/2026 1. Organization Audit in Flock. 2. Network Audit in Flock. The Palo Alto Police Department has reviewed its files and has located responsive records to your request. Please log in to the Public Records Center at the following Link https://paloaltoca.mycusthelp.com/WEBAPP/_rs/(S(sfh1dmqmcw0w21dmxzr2rum3))/RequestEdit.aspx?sSessio… to retrieve the appropriate responsive documents. The City will not be releasing the reason data listed in the Network Flock audit pursuant to Cal. Gov. Code § 7923.600(a) as the data is exempt from the CPRA as investigation conducted by any state or local police agency. Please direct your question to the agency you would like to obtain "reason for the search" information.