City of Santa Barbara Automated License Plate Recognition Policy

City of Santa Barbara

Automated License Plate Recognition Policy

What is it: Automated License Plate Recognition (ALPR) technology utilizes cameras

to capture and store digital images of license plates, and uses character recognition

algorithms to identify license plate characters. An ALPR system creates a searchable

computerized database resulting from the data collected by fixed cameras located at

the entrance/exit of numerous City-operated public parking lots, and vehicle-mounted

or handheld cameras for on-street parking spaces designated as priced or paid parking.

ALPR system data includes license plate number as well the date, time, and location

when the image was collected.

Purpose: The purpose of this policy is to define the City’s appropriate use,

maintenance, collection, security, and retention of all ALPR information, and the

authorized users of the City’s ALPR technology, in compliance with all applicable

federal, state, and local laws. This policy is separate from any ALPR technology used

by the Santa Barbara Police Department (SBPD). The SBPD maintains their own policy

for ALPR.

The City of Santa Barbara utilizes ALPR technology to capture, analyze, and store

digital license plate data and images to enable the rapid identification of vehicles in

support of parking operations and compliance activities. ALPR shall supplement or

replace paper tickets to log the times at which a vehicle enters or exits a City parking lot

in order to determine the fee due upon exit. ALPR and customer license plate data shall

also supplement or replace proximity access cards and permit stickers to grant lot entry

to monthly and annual parking permit holders.

License plate information paired to vehicles entering City-operated public parking lots is

used to improve access control and the enforcement of City parking ordinance violations

in the lots that utilize ALPR. For example, information on vehicles coming into a lot is

anonymized and aggregated to analyze various metrics including parking patterns,

permit-type usage, and compliance.

Restricted Uses: The City only uses ALPR technology to collect license plate data within

public view. The City does not use ALPR technology for the purpose of monitoring

individual activities that are otherwise protected by the First Amendment to the United

States Constitution. The cameras shall not be used in areas where there is a reasonable

expectation of privacy, and shall not be used to harass, intimidate, or discriminate against

any individual or group.

Training: Pursuant to California Civil Code Section 1798.90.51(b), all authorized users

shall receive training prior to being granted access to an ALPR system and data. A record

of all completed training is maintained by the respective City departments. ALPR

operators receive initial training from the vendor providing the ALPR software and

hardware. The training includes the procedure and proper use of the system prior to being

granted access to an ALPR system. In addition, each user also receives an annual

refresher training from the Program Manager or designee. The training includes:

1. Applicable federal and state law;

2. Functionality of the equipment; and

3. Safeguarding of password information, access to ALPR systems, and ALPR

information.

Access: Authorized users with access to ALPR data shall include staff with a City operational

need to specifically oversee such a system and/or are responsible for parking operations and

enforcement within City Departments including Public Works, Waterfront, and Airport, as well

as City-contracted parking operations and enforcement vendors. The Program Manager for

each City Department employing an ALPR system is the custodian and head administrator

of its ALPR systems and their operation. The only individuals with access and the ability

to query data in the system are:

 Program Manager, and their designee(s);

 Parking Supervisors;

 Parking Coordinators;

 Parking Resources Specialist;

 Parking Office Specialist;

 Waterfront Operations Manager;

 Downtown Plaza and Parking Manager;

 Harbor Patrol Supervisor;

 Airport Patrol Supervisor;

 Harbor Patrol Officers; and

 Airport Patrol Officers.

All logins and queries are stored and monitored, and contain the following information:

 Username;

 Date;

 Time;

 Purpose of query; and

 License plate and other criteria used to query the system.

This data shall be stored and monitored by each respective Department’s Program

Manager, Harbor Patrol, Airport Patrol, Parking Services, and Parking Operations staff.

License plates are only referenced against the respective Department’s Annual

Parking/Parking Permit vehicle database, and tickets generated at the entrance columns.

The Program Manager or their designee shall also run quarterly audits to ensure access

to the data was made by authorized persons for authorized uses.

Information Collected: The following information may be collected by the ALPR system:

 License plate image captured;

 License plate number;

 License plate state;

 Date;

 Time; and

 Location.

Information Stored & Data Retention: ALPR data shall be sent to and stored in the

ALPR vendor’s regional database. The database stores license plate numbers of monthly

and annual parking permit holders and hourly customers. This information is used by the

ALPR system to allow permit holders to gain entry to the City parking lot for which their

permit is valid and to exit without having to provide payment. The permit holder’s license

plate number is used to supplement or replace proximity access cards, plastic hang tags,

stickers, and other permit materials.

Routine data collection for Airport and Waterfront parking shall not be stored beyond 30

days, and for Downtown parking 72 hours except when lawfully required to by court order.

After the aforementioned retention times elapse, the vendor shall purge routine data

records. The data records stored on the regional ALPR server include photographs of the

vehicle (close-up of the license plate and context photo of the rear of the vehicle), and

accompanying license plate number, date, time, and location in the field; such records do

not directly identify a particular person.

Security: The City of Santa Barbara uses administrative, operational, technical and

physical safeguards to protect ALPR information from unauthorized access, use,

destruction, modification or disclosure including the following safeguards:

 Administrative: Username and password-protected access to the ALPR system.

The system shall document all information access by username, and the database

usage shall be monitored and audited.

 Operational: Training system users on proper use and secure practices when

using ALPR and its database.

 Physical: All network equipment and servers containing sensitive data are

maintained in a secure off-site location, and accessed only by authorized

personnel. This includes the secure storage of computers with access to the off-

site database.

 Technical: All information is encrypted to protect any personally identifiable

information. ALPR system workstations and servers shall be updated with the

latest security patches on a regular basis. ALPR data shall be secured, encrypted,

and backed up regularly.

In the very unlikely event of an information breach that constitutes a violation under

California Penal Code Section 502, all individuals who are believed to be affected or

have their information compromised shall be notified by the City of Santa Barbara, via

the affected City Department(s).

Quality Assurance: Collection of ALPR is automated so the license plate images and

details of collection are included in the system without review. Although infrequent,

license plate translation may be incomplete or inaccurate. The Program Manager or their

designee ensure accuracy and correct license plate translation errors when identified.

Users also confirm the computer translation prior to taking any action based on ALPR

results.

Releasing ALPR Data: The City does not share ALPR information with any commercial

or private entity, other than City parking contractors and enforcement vendors, as

necessary to conduct City parking operations. The City includes confidentiality provisions

in its agreements with any parking contractors and/or vendors to prohibit any use or

distribution of ALPR information for any purpose other than the authorized Uses under

this Policy. Information gathered or collected and records retained by the City of Santa

Barbara must not be:

 Sold, published, exchanged, or disclosed for commercial purposes.

 Disclosed or published without authorization.

 Disseminated to persons not authorized to access or use the information.

The City shall provide ALPR data to a federal, state, or local law enforcement agency or

any other public agency only if a warrant or other court order is issued and served. In

addition, information gathered shall not be disclosed to the public or in a civil matter unless

such disclosure is required by law or court order.

Requests for Images from Members of the Public: Persons that have a Court Order

or preservation letter, and are interested in requesting ALPR, are directed to the Santa

Barbara City Clerk’s Office. Persons that do not have a Court Order or preservation letter,

and are interested in requesting ALPR data are also directed to the Santa Barbara City

Clerk’s Office.

Enforcement: Violation of this Policy by a City employee, contractor, or other authorized

user, may lead to suspension or termination of that user’s access to the ALPR system.