Jury report: Is Our Flock of ALPR Cameras Properly Tended? · PDF page 16
Permanent linkSan Mateo County Civil Grand Jury
2025–2026: from findings to follow-through
Overview
Explore the jury’s recommendations, read matching agency responses, and join the discussion. Everything in this cycle is connected to its original source.
Recommendations & responses
Every recommendation made by the jury, with matching agency responses alongside it.
Recommendations & responses
Showing 12 of 12 recommendations
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Is Our Flock of ALPR Cameras Properly Tended?
9 recommendations
Recommendation R1
The ALPR operator should conspicuously post the current version of their ALPR Policy as required by Civil Code sections 1798.90.51(a)–(b).
No response recorded
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Recommendation R1
The ALPR operator should conspicuously post the current version of their ALPR Policy as required by Civil Code sections 1798.90.51(a)–(b).
No response recorded
View recommendation and responsesHide detailsRecommendation R2
The ALPR operator with outdated ALPR policies should revise those policies to accurately reflect current operational practices.
No response recorded
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Recommendation R2
The ALPR operator with outdated ALPR policies should revise those policies to accurately reflect current operational practices.
No response recorded
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Permanent linkOfficial responses
Recommendation R3
The ALPR operator currently identified as sharing ALPR data with private university security entities should obtain and retain a written legal and factual determination that the recipient is a “public agency” under Civil Code section 1798.90.5(f), or that the sharing is otherwise permitted by law; if no lawful basis exists, the operator should terminate the sharing relationship.
No response recorded
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Recommendation R3
The ALPR operator currently identified as sharing ALPR data with private university security entities should obtain and retain a written legal and factual determination that the recipient is a “public agency” under Civil Code section 1798.90.5(f), or that the sharing is otherwise permitted by law; if no lawful basis exists, the operator should terminate the sharing relationship.
No response recorded
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Permanent linkOfficial responses
Recommendation R4
The ALPR operator should prepare audit reports in accordance with the frequency stated in the operator’s published ALPR policy.
No response recorded
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Recommendation R4
The ALPR operator should prepare audit reports in accordance with the frequency stated in the operator’s published ALPR policy.
No response recorded
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Permanent linkOfficial responses
Recommendation R5
The audit reports produced by the ALPR operator should substantiate compliance with applicable California law and the operator’s published ALPR policy.
No response recorded
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Recommendation R5
The audit reports produced by the ALPR operator should substantiate compliance with applicable California law and the operator’s published ALPR policy.
No response recorded
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Permanent linkOfficial responses
Recommendation R6
Upon contract renewal, the ALPR operator should incorporate contractual language requiring vendor compliance with applicable California law and prohibiting vendors from disclosing ALPR data to unauthorized third parties. Operators should consider provisions similar to those contained in the Town of Colma contract with Flock.
No response recorded
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Recommendation R6
Upon contract renewal, the ALPR operator should incorporate contractual language requiring vendor compliance with applicable California law and prohibiting vendors from disclosing ALPR data to unauthorized third parties. Operators should consider provisions similar to those contained in the Town of Colma contract with Flock.
No response recorded
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Permanent linkOfficial responses
Recommendation R7
The ALPR operator should update its ALPR policy to accurately reflect the process used to approve ALPR data-sharing relationships.
No response recorded
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Recommendation R7
The ALPR operator should update its ALPR policy to accurately reflect the process used to approve ALPR data-sharing relationships.
No response recorded
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Permanent linkOfficial responses
Recommendation R8
The ALPR operator should include in their ALPR policies written criteria governing the approval, denial, periodic review, and termination of in-state ALPR network-sharing relationships.
No response recorded
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Recommendation R8
The ALPR operator should include in their ALPR policies written criteria governing the approval, denial, periodic review, and termination of in-state ALPR network-sharing relationships.
No response recorded
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Permanent linkOfficial responses
Recommendation R9
The ALPR operator should update their ALPR policy or Flock contract terms, as necessary, so that the stated retention rule accurately reflects operations.
No response recorded
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Recommendation R9
The ALPR operator should update their ALPR policy or Flock contract terms, as necessary, so that the stated retention rule accurately reflects operations.
No response recorded
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Permanent linkOfficial responses
More Food for Thought: County Sustainability Department Has Not Implemented Required SB 1383 Edible Food Recovery Enforcement Procedures
3 recommendations
Recommendation R1
By December 31, 2026, SMCSD should adopt and implement written SB 1383 edible food recovery enforcement procedures for services performed under its MOUs, including criteria for inspections, re-inspections, Notices of Violation, Penalty Orders, or other enforcement when required.
1 response · San Mateo County Sustainability Department
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Recommendation R1
By December 31, 2026, SMCSD should adopt and implement written SB 1383 edible food recovery enforcement procedures for services performed under its MOUs, including criteria for inspections, re-inspections, Notices of Violation, Penalty Orders, or other enforcement when required.
1 response · San Mateo County Sustainability Department
View recommendation and responsesHide detailsJury report: More Food for Thought: County Sustainability Department Has Not Implemented Required SB 1383 Edible Food Recovery Enforcement Procedures · PDF page 8
Permanent linkOfficial response
San Mateo County Sustainability Department
Agency says further analysis neededRequires further analysis. SMCSD describes developing inspection, deadline, notice, citation and appeal procedures with MOU jurisdictions; it will explore funding/cost recovery and prepare the matter for discussion by February 3, 2027.
Read official response · PDF page 2Recommendation R2
By June 30, 2027, SMCSD should develop and implement a standardized inspection form and publicly accessible database of inspection reports and enforcement information, subject to Public Records Act requirements and any applicable exemptions.
1 response · San Mateo County Sustainability Department
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Recommendation R2
By June 30, 2027, SMCSD should develop and implement a standardized inspection form and publicly accessible database of inspection reports and enforcement information, subject to Public Records Act requirements and any applicable exemptions.
1 response · San Mateo County Sustainability Department
View recommendation and responsesHide detailsJury report: More Food for Thought: County Sustainability Department Has Not Implemented Required SB 1383 Edible Food Recovery Enforcement Procedures · PDF page 8
Permanent linkOfficial response
San Mateo County Sustainability Department
Agency says further analysis neededRequires further analysis. SMCSD says a standardized inspection form is implemented; a public database needs evaluation of public-records exemptions, confidentiality, resources and County systems, with analysis and County Attorney discussion by February 3, 2027.
Read official response · PDF page 3Recommendation R3
By June 30, 2027, SMCSD should develop an anonymous complaint process that can be adopted by participating jurisdictions.
1 response · San Mateo County Sustainability Department
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Recommendation R3
By June 30, 2027, SMCSD should develop an anonymous complaint process that can be adopted by participating jurisdictions.
1 response · San Mateo County Sustainability Department
View recommendation and responsesHide detailsJury report: More Food for Thought: County Sustainability Department Has Not Implemented Required SB 1383 Edible Food Recovery Enforcement Procedures · PDF page 8
Permanent linkOfficial response
San Mateo County Sustainability Department
Agency plans to implementWill be implemented in the future. SMCSD will coordinate a standardized receiving, routing, investigating and documenting process by June 30, 2027; each jurisdiction controls its adoption decision/timing, and SMCSD will track adoption.
Read official response · PDF page 3Findings
The jury’s formal findings, with source citations and any recorded responses.
Findings & responses
Showing 11 of 11 findings
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Is Our Flock of ALPR Cameras Properly Tended?
9 findings
Finding F1
The ALPR operator’s ALPR policy was not posted in a manner that appears consistent with the California Attorney General’s guidance on “conspicuous” posting.
No response recorded
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Finding F1
The ALPR operator’s ALPR policy was not posted in a manner that appears consistent with the California Attorney General’s guidance on “conspicuous” posting.
No response recorded
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Permanent linkOfficial responses
Finding F2
The ALPR operator’s ALPR Policy appears to be outdated because it describes ALPR operations as mediated by NCRIC, a practice the investigation found was discontinued several years ago.
No response recorded
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Finding F2
The ALPR operator’s ALPR Policy appears to be outdated because it describes ALPR operations as mediated by NCRIC, a practice the investigation found was discontinued several years ago.
No response recorded
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Permanent linkOfficial responses
Finding F3
The ALPR operator shared ALPR information with private university security entities but did not establish that the receiving entity was a “public agency” as defined in Civil Code section 1798.90.55(b), or that the sharing was otherwise permitted by law within the meaning of Civil Code section 1798.90.55(b).
No response recorded
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Finding F3
The ALPR operator shared ALPR information with private university security entities but did not establish that the receiving entity was a “public agency” as defined in Civil Code section 1798.90.55(b), or that the sharing was otherwise permitted by law within the meaning of Civil Code section 1798.90.55(b).
No response recorded
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Permanent linkOfficial responses
Finding F4
The ALPR operator did not produce records demonstrating that audits required by its ALPR policy had been conducted.
No response recorded
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Finding F4
The ALPR operator did not produce records demonstrating that audits required by its ALPR policy had been conducted.
No response recorded
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Permanent linkOfficial responses
Finding F5
The audit reports produced by the ALPR operator were insufficient to substantiate compliance with applicable California law and the operator’s published ALPR policy.
No response recorded
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Finding F5
The audit reports produced by the ALPR operator were insufficient to substantiate compliance with applicable California law and the operator’s published ALPR policy.
No response recorded
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Permanent linkOfficial responses
Finding F6
The ALPR operator’s Flock Safety contract does not include provisions specifically requiring compliance with applicable California ALPR laws.
No response recorded
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Finding F6
The ALPR operator’s Flock Safety contract does not include provisions specifically requiring compliance with applicable California ALPR laws.
No response recorded
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Permanent linkOfficial responses
Finding F7
The operator’s ALPR policy described a process requiring written requests and executed agreements for ALPR data-sharing relationships; however, the records produced did not substantiate that this process was followed or that the required agreements were obtained.
No response recorded
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Finding F7
The operator’s ALPR policy described a process requiring written requests and executed agreements for ALPR data-sharing relationships; however, the records produced did not substantiate that this process was followed or that the required agreements were obtained.
No response recorded
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Permanent linkOfficial responses
Finding F8
The operator’s ALPR policy did not establish criteria governing the approval of in-state ALPR data-sharing requests or the termination of existing network-sharing relationships.
No response recorded
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Finding F8
The operator’s ALPR policy did not establish criteria governing the approval of in-state ALPR data-sharing requests or the termination of existing network-sharing relationships.
No response recorded
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Permanent linkOfficial responses
Finding F9
The retention period specified in the operator’s ALPR Policy does not match the retention period as reported by the Flock transparency portal or Flock contract.
No response recorded
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Finding F9
The retention period specified in the operator’s ALPR Policy does not match the retention period as reported by the Flock transparency portal or Flock contract.
No response recorded
View finding and responsesHide detailsJury report: Is Our Flock of ALPR Cameras Properly Tended? · PDF page 16
Permanent linkOfficial responses
More Food for Thought: County Sustainability Department Has Not Implemented Required SB 1383 Edible Food Recovery Enforcement Procedures
2 findings
Finding F1
Since January 1, 2024, 14 CCR §§ 18995.1 and 18995.4 require jurisdictions to enforce SB 1383 requirements. Under MOUs reviewed by the Grand Jury, SMCSD is responsible for enforcement for participating jurisdictions. Inspection records reviewed by the Grand Jury do not show a consistent documented process for conducting inspections and re-inspections, setting compliance deadlines, or issuing Notices of Violation, Penalty Orders, or other enforcement when required.
1 response · San Mateo County Sustainability Department
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Finding F1
Since January 1, 2024, 14 CCR §§ 18995.1 and 18995.4 require jurisdictions to enforce SB 1383 requirements. Under MOUs reviewed by the Grand Jury, SMCSD is responsible for enforcement for participating jurisdictions. Inspection records reviewed by the Grand Jury do not show a consistent documented process for conducting inspections and re-inspections, setting compliance deadlines, or issuing Notices of Violation, Penalty Orders, or other enforcement when required.
1 response · San Mateo County Sustainability Department
View finding and responsesHide detailsJury report: More Food for Thought: County Sustainability Department Has Not Implemented Required SB 1383 Edible Food Recovery Enforcement Procedures · PDF page 8
Permanent linkOfficial response
San Mateo County Sustainability Department
SMCSD partially disagrees: it accepts the MOU delegation but says an HF&H Consultants internal enforcement protocol has existed since June 2024, with outreach, inspections and follow-up to achieve voluntary compliance.
Read official response · PDF page 2Finding F2
During the investigation, SMCSD’s online edible food recovery complaint form was not functional when tested, and the Grand Jury could not locate publicly accessible written complaint procedures for the jurisdictions reviewed. Although a countywide form is not mandated, 14 CCR § 18995.3 requires each jurisdiction to provide a procedure for receipt and investigation of written complaints and to allow anonymous complaints.
1 response · San Mateo County Sustainability Department
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Finding F2
During the investigation, SMCSD’s online edible food recovery complaint form was not functional when tested, and the Grand Jury could not locate publicly accessible written complaint procedures for the jurisdictions reviewed. Although a countywide form is not mandated, 14 CCR § 18995.3 requires each jurisdiction to provide a procedure for receipt and investigation of written complaints and to allow anonymous complaints.
1 response · San Mateo County Sustainability Department
View finding and responsesHide detailsJury report: More Food for Thought: County Sustainability Department Has Not Implemented Required SB 1383 Edible Food Recovery Enforcement Procedures · PDF page 8
Permanent linkOfficial response
San Mateo County Sustainability Department
SMCSD labels its position partial disagreement, accepts the complaint-procedure requirement, neither agrees nor disagrees that the form failed because it cannot verify the test, and identifies email/telephone alternatives and a newly added direct web link.
Read official response · PDF page 2Questions
Editorial discussion prompts inspired by the reports. These are separate from the jury’s formal findings and recommendations.
Civic question
What information should explain why an agency grants, reviews or ends an in-state ALPR data-sharing relationship?
Supporting report
Is Our Flock of ALPR Cameras Properly Tended? · Findings F7–F8; Recommendations R7–R8
Civic question
What should public ALPR audit summaries show about policy compliance and follow-up while protecting sensitive investigations?
Supporting report
Is Our Flock of ALPR Cameras Properly Tended? · Findings F4–F5; Recommendations R4–R5
Civic question
What should a written edible food recovery enforcement process explain about inspections, follow-up and compliance deadlines?
Supporting report
More Food for Thought: County Sustainability Department Has Not Implemented Required SB 1383 Edible Food Recovery Enforcement Procedures · Findings F1; Recommendations R1
Civic question
How should public inspection information show compliance status and follow-up while respecting applicable records exemptions?
Supporting report
More Food for Thought: County Sustainability Department Has Not Implemented Required SB 1383 Edible Food Recovery Enforcement Procedures · Recommendations R2
Civic question
What would help residents find and understand anonymous edible food recovery complaint options?
Supporting report
More Food for Thought: County Sustainability Department Has Not Implemented Required SB 1383 Edible Food Recovery Enforcement Procedures · Findings F2; Recommendations R3
Civic question
How should the County and participating jurisdictions explain who receives, routes, investigates and documents a complaint?
Supporting report
More Food for Thought: County Sustainability Department Has Not Implemented Required SB 1383 Edible Food Recovery Enforcement Procedures · Discussion, Anonymous Complaint Process
Related coverage
Superior Court of California, County of San Mateo
Official San Mateo County Civil Grand Jury
County of San Mateo Board of Supervisors
Board file 26-825: food-recovery response approval
County of San Mateo Board of Supervisors
Food report: separate Board attachment original
Sources
Original reports and response documents provide the evidence behind this cycle’s findings, recommendations, and discussions.
Official report
Is Our Flock of ALPR Cameras Properly Tended?
Response available