Facial recognition audit logs/usage statistics (Massachusetts State Police)

Todd Feathers filed this request with the Massachusetts State Police of Massachusetts.
Multi Request Facial recognition audit logs/usage statistics
Est. Completion None


From: Todd Feathers

To Whom It May Concern:

Pursuant to the Massachusetts Public Records Law, I hereby request the following records:

1) Copies of all user guides, handbooks, technical manuals, or comparable documents in the department's possession regarding department facial recognition system(s). These systems are commonly provided by vendors including, but not limited to, NEC, Dataworks Plus, Clearview AI, Cognitec, and others. The entirety of this request should be construed to include facial recognition systems provided by commercial vendors or developed internally.

2) Copies of all audit logs for the department's facial recognition system from Jan. 1, 2020 until the date this request is processed. Facial recognition vendors commonly include daily, weekly, or monthly audit log capabilities in their products and the U.S. Department of Justice recommends that all law enforcement agencies maintain audit logs for facial recognition systems (see: https://it.ojp.gov/GIST/1204/Face-Recognition-Policy-Development-Template-For-Use-In-Criminal-Intelligence-and-Investigative-Activities). If the department's facial recognition system provides options for the time period covered in the audit logs, I ask that you provide weekly logs (rather than daily, monthly, etc.).

3) All reports detailing aggregated usage/transaction statistics for the department's facial recognition system from May 1, 2020 until the date this request is processed. Commercial facial recognition systems include the ability to easily view these daily, weekly, or monthly aggregate reports, which often detail the number of queries per day, number of daily users, number of photographs/facial templates uploaded to the database, etc. If the department's facial recognition system provides options for the time period covered in the aggregate usage or transaction statistics, I ask that you provide daily reports (rather than hourly, weekly, monthly, etc.).

4) Any documents (this includes screenshots of program dashboards) detailing the number of photographs or facial templates included in the database linked to the department's facial recognition system as of the date this request is processed.

I ask that all fees be waived as I am a journalist (examples of my recent work can be found at toddfeathers.com) and I intend to use the requested records to publish articles in the public interest and not for any commercial purpose.

I also request that, if appropriate, fees be waived as we believe this request is in the public interest, as suggested but not stipulated by the recommendations of the Massachusetts Supervisor of Public Records. The requested documents will be made available to the general public free of charge as part of the public information service at MuckRock.com, processed by a representative of the news media/press and is made in the process of news gathering and not for commercial usage.

I expect the request to be filled in an accessible format, including for screen readers, which provide text-to-speech for persons unable to read print. Files that are not accessible to screen readers include, for example, .pdf image files as well as physical documents.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 business days, as the statute requires.


Todd Feathers

From: Massachusetts State Police

Mr. Feathers,
I have been assigned to handle your public records request. I wanted to connect to inform you of a few things before we proceed. First and foremost, the Massachusetts State Police (MSP) only utilizes the facial recognition system through the Massachusetts Registry of Motor Vehicles. MSP has not developed any internal facial recognition systems nor does it utilize any commercial vendor services for facial recognition. Therefore, MSP does not have care, custody or control of any audit logs for that system given that we do not maintain that system. Any records related to this system can be obtained by submitting a public records request directly to the RMV.

MSP does have access to a facial recognition program through a database known as COPLINK. This facial recognition system was provided to us for free as a feature to the existing COPLINK platform that we had already been utilizing. MSP has used the facial recognition feature within COPLINK in the past. However, while the COPLINK system is still utilized for other purposes, MSP no longer utilizes COPLINK for facial recognition as we have elected to exclusively utilize the RMV system. Additionally, MSP does not maintain audit logs for the COPLINK facial recognition system as the audit capabilities are handled by the company that owns the and maintains the system.

We receive a lot of records requests related to facial recognition and most people are surprised to learn that the MSP has not purchased a facial recognition system from a commercial vendor such as Clearview AI or Dataworks. Please let me know how you wish to proceed with this request at this point.

Jason R. Stelmat | Privacy Officer
Massachusetts State Police | Commonwealth Fusion Center
124 Acton Street, Maynard MA 01754
direct 978-451-3752 | fax 978-451-3767

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