Automated License Plate Recognition (ALPR) Usage and Privacy Policy

Palm Court publishes a public, always-available transparency portal for this camera, hosted by Flock Safety at transparency.flocksafety.com/palm-court-community-ca. Anyone — residents, visitors, neighbors, and the general public — may review it at any time without an account or request.

The portal is the authoritative, continuously updated companion to this document. Where a figure in this policy and a figure on the portal differ, the portal reflects the live configuration of the system.

• What's Detected: License plates and vehicles.
• What's Not Detected: Facial recognition, people, gender, and race.
• Acceptable Use Policy: Data is used for law enforcement purposes only. Data is owned by Palm Court Community and is never sold to 3rd parties.
• Data Sharing: Palm Court Community (CA) is not sharing data with any partner or law enforcement networks.
• Prohibited Uses: Immigration enforcement, traffic enforcement, harassment or intimidation, usage based solely on a protected class (i.e. race, sex, religion), and personal use.
• Access Policy: All system access requires a valid reason and is stored indefinitely.
• SOC 2 Type II: Independently audited controls covering security, availability, and confidentiality.
• ISO 27001: Information security management aligned with international standards.
• Adherence to Key Privacy Principles: Built to focus on data minimization, purpose limitation, and transparency.

This policy governs the management, collection, storage, and use of Automated License Plate Recognition (ALPR) data captured by the Flock Safety camera system installed at the entrance of our private residential road. The sole purpose of this system is to enhance the safety, security, and situational awareness of our private residential community.

In addition to license plate captures, the system provides a live video feed of the community entrance. This live video feed is used solely for the same limited safety and security purposes described above, is accessible only to the authorized system operators identified in this policy, and is subject to the identical audit logging, access restrictions, data sharing limitations, security safeguards, and 30-day automatic deletion practices that apply to all other data covered by this policy.

The trust and safety commitments published on our transparency portal are restated here so they are binding on this community, not merely descriptive of the vendor platform.

• No Facial Recognition: The system does not perform facial recognition. The live video feed captures a full view of the community entrance, which can include people walking or passing through, but no facial recognition, biometric matching, or other person-identification analysis is performed on that footage or on any still capture.
• No Personal Records: The system has no access to driver, registration, or DMV records, and does not attach names, addresses, or any personally identifying information to a capture.
• No Traffic Enforcement: The system does not measure speed and is not used to issue citations, fines, or any form of traffic enforcement against residents or visitors.
• No Live Person Tracking: The system does not follow individuals across locations. Each capture is a single, fixed observation at our community entrance.
• No Sale of Data: Captured data is never sold, licensed, rented, or provided to advertisers, data brokers, insurers, or any commercial third party.
• No Network Enrollment: This camera is not enrolled in any state, regional, or nationwide ALPR sharing network, and its data is not pooled with data from other agencies or communities.
• Community Ownership: The data captured by this camera belongs to the Palm Court community. Flock Safety hosts it as a processor and does not use it for its own purposes.

Access to the ALPR system, including live feeds, historical image captures, and search queries, is strictly restricted to designated authorized residents within our private residential community.

• User Logging: Every single login, camera view, data search, and administrative action taken within the system is automatically and permanently recorded in an uneditable electronic audit log.
• Search Justification: Operators must record a reason and, where applicable, an incident or case reference for every search. Reason-for-search entries are surfaced in anonymized form on the public transparency portal.
• Prohibited Acts: System access may not be used for personal, commercial, or non-security monitoring of individuals or neighbors.

To ensure strict adherence to California law and individual privacy rights, the system's electronic audit logs will be audited and reviewed quarterly (every three months).

• The quarterly review will cross-reference search queries against documented security incidents (e.g., package thefts, property damage, unauthorized trespassing).
• Any unauthorized use, personal tracking, or general abuse of system access will result in the immediate and permanent revocation of that user's database credentials.

Privacy of data is a paramount priority for this private community.

• No Automatic Integration: This ALPR system is strictly private. It is not connected to local, state, or federal law enforcement databases, networks, or hotlists by default or automatically.
• Case-by-Case Sharing: Data is considered privately held. It will only be exported and shared manually with local law enforcement if a specific, verifiable criminal incident occurs within or immediately adjacent to our private community road, or if required to comply with a valid legal subpoena or court order.
• No Commercial Sharing: Data is never sold, licensed, or shared with advertisers, data brokers, insurers, employers, landlords, or any other commercial party.
• No Federal or Immigration Use: Data is not shared for federal immigration enforcement or for any purpose unrelated to a specific criminal incident affecting this community, absent a valid court order.
• Documented Exports: Every manual export is recorded in the audit log with the requesting party and the incident it relates to, and remains subject to quarterly review.

This community utilizes Flock Safety's standard cloud-based architecture for all data hosting and cybersecurity safeguards.

• Information Security: All captured data is encrypted both in transit and at rest using industry-standard administrative, physical, and technical security protocols to prevent unauthorized access, alteration, or destruction.
• Strict Deletion Timeline: In accordance with Flock Safety's standard data retention policies, all captured images and associated metadata are automatically, permanently, and irreversibly deleted after 30 days on a rolling basis, unless a specific clip is manually saved and exported as evidence for an active security investigation.