Report 2019-118 Recommendation 21 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 #21 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 April 2020, Los Angeles should review all user accounts and deactivate accounts for separated employees, inactive users, and others as necessary.

Annual Follow-Up Agency Response From November 2022

On September 27, 2022, the Los Angeles Police Department's Board of Police Commissioners approved the Automated License Plate Recognition Audit that was conducted in 2021. The attached Audit states that all inactive accounts were deactivated immediately upon notification by auditors to Innovation Management Division (See Objective No. 3).

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From October 2021

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

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: Partially Implemented

Although Los Angeles has developed a policy related to who may use the ALPR system, it did not provide evidence that it reviewed user accounts to ensure access was appropriate.

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.