Automated License Plate Reader (ALPR) - Adoption, Use, and Data Retention Policies (Milton Police Department)

Mr. Maass:

We received your request for information Wednesday, December 26th via first-class mail. We did not receive any prior requests for information from you. We are currently reviewing your request to determine if we have responsive documents and expect to have this completed no later than Wednesday, January 9, 2019. Accordingly, the status of the following requests is as follows

"Materials related to this agency's acquisition of, access to, preservation of, or disclosure of automated license plate readers (ALPR) or ALPR data". Any open bidding process is protected under the ORA. O.C.G.A. 50-18-72 (10).

"Policies related to the adoption of ALPR technology, including those guiding the procurement process or necessary administrative obligations before acquisition"

1. "Training policies, requirements, and materials for automatic license plate reader system operators"
2. Policies related to the retention and security of captured ALPR data, including those regarding: the length of time after capture that data may be preserved, exceptions to general data preservation policies, internal data security and access, and data destruction"
3. Policies related to the sharing of captured ALPR data by this agency with other agencies, including those directing: the manner in which another agency may request data, the circumstances under which captured data may be shared, and the responsibilities of the recipient agency in regards to data retention and use, access by this agency to data obtained by automatic license plate reader systems not operated by the law enforcement agency"
4. Policies related to the sale of data or the sharing of data with non-law enforcement actors. If applicable, please provide all agreements between this agency and non-law enforcement actors."
5. Policies regarding oversight of automated license plate reader system use
6. "Policies related to maintenance and calibration"
7. "Any other policies or reports on subjects related to automatic license plate reader system use by the agency". Attached
.

Finally, several requests contained in your request are not subject to disclosure:

1. "The aggregate number of 'detections' (i.e. license plate scans and associated data) collected during 2016.
2. The aggregate number of detections collected during 2017
3. The aggregate number of detections collected during 2018
4. The aggregate number of 'hits' (i.e. times that a place on a hotlist was detected) during 2016
5. The aggregate number of 'hits' during 2017
6. The aggregate number of 'hits' during 2018.

This information is not subject to disclosure. As you may know, the legislature recently passed O.C.G.A. 35-1-22. O.C.G.A. 35-1-22(a)(2) defines "Captured license plate data" as "the global positioning device coordinates, date and time, photograph, license plate number, and any other data captured by or derived from an automated license plate recognition system or any other source." O.C.G.A. 35-1-22(f) states that all "Captured license plate data collected by a law enforcement agency shall not be subject to public disclosure pursuant to Article 4 of Chapter 18 of Title 50." Furthermore, the department may only access collected data for law enforcement purposes and may only retain that data for 30 months after it was originally collected, O.C.G.A. 35-1-22(b). Accordingly, any records that would require the department to access the ALRP data is not subject to disclosure. Most likely, the above listed items would fall under this exception, and would not be subject to disclosure.

The following requests are pending review and will be included in any documents that will be provided (if they exist) by January 9th.

1. The names of agencies and organizations with which the Agency shares ALPR data;
2. The names of agencies and organizations from which the Agency receives ALPR data;
3. The names of agencies and organizations with which the Agency shares "hot list" information
4. The names of agencies and organizations from which the Agency receives "hot list" information
5. "Databases used to compare data obtained by the automatic license plate reader system" Please note, any data collected or derived from the Automated License Plate Recognition System would not be subject to disclosure. Accordingly, we cannot release the databases but we will provide the name of the database/s with our January 9th response.

Please be advised that your request for "The aggregate number of 'detections' (i.e. license plate scans and associated data) collected during 2016. The aggregate number of detections collected during 2017. The aggregate number of detections collected during 2018. The aggregate number of 'hits' (i.e. times that a plate on a hotlist was detected) during 2016. The aggregate number of 'hits' during 2017. The aggregate number of 'hits' during 2018", does not request any records or documents. However, even if we construe this request as containing a request for documents or records, such records are exempt from the Open Records Act and are not subject to production, pursuant to O.C.G.A. § 35-1-22(f)."

Attached are the final documents as requested. This is now closed.

Have a good day.

Suzanne Johnson
Records Clerk
Milton Police Department
13000 Deerfield Parkway, Suite 107F, Milton, GA 30004
678-242-2606 (O)
Suzanne.johnson@cityofmiltonga.us<mailto:Suzanne.johnson@cityofmiltonga.us>
www.cityofmiltonga.us<http://www.cityofmiltonga.us>

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