Replicate Our Work Central Sierra Foothills DSA · DeFlock Working Group
How We Got The Data.
Every figure on this site came from records the public is legally entitled to under the
California Public Records Act. If you live in California and you want to know how Flock is
being used in your community, here is exactly how to ask, what to ask for, and what to do
when the answer comes back.
Flock claims to support transparency, and California law actually requires it. The records
that prove what is happening with your local cameras are already sitting in your agency's
Flock admin console, waiting for someone to ask.
What is the CPRA?
The California Public Records Act (Cal. Gov't Code § 7920.000 et seq., formerly
§ 6250) gives any person the right to inspect or obtain copies of public records held
by state and local agencies, with narrow exceptions. ALPR audit logs are public records.
Who can file?
Anyone. You do not have to be a journalist, an attorney, a resident of the jurisdiction
you are asking, or even a California resident. You do not have to explain why you
want the records.
What does it cost?
Generally nothing if records are emailed in their existing electronic format. Agencies
may charge for physical reproduction (paper copies, USB drives) at the direct cost of
duplication, but they cannot charge for staff time spent searching or compiling.
Does Flock have to comply?
Flock itself is a private company and not subject to CPRA, but the public agencies
that operate Flock cameras are. Those agencies have direct admin access to the audit
data through Flock's portal and can export it on request.
// The Targets
Who To Send It To.
Send a separate request to every law enforcement agency in your county that operates Flock
cameras. In Nevada County, that meant the Sheriff's Office, Grass Valley PD, and Nevada
City PD. Most agencies have a public records or "custodian of records" email address listed
on their website.
How do I find local Flock cameras?
Start with
deflock.me,
which crowdsources ALPR camera locations nationwide. Cross-reference with city
council agendas, police department press releases, and budget documents that mention
"Flock Safety," "ALPR," or "automated license plate readers."
How do I find the right contact?
Search the agency website for "public records request," "CPRA," or "custodian of
records." If you cannot find a dedicated address, send it to the agency's general
public information email or the city clerk. Cities and counties are required to have
someone who handles these requests.
// The Magic Words
What To Ask For.
Flock generates a few distinct report types out of its admin console. Asking for each by
name dramatically increases the odds you get what you actually want, instead of a summary
document the agency thinks is sufficient.
Officer Audit
A log of every search performed by officers within the agency itself. Smaller file
(typically 20–100 KB). Useful for understanding how often local officers query the
system and what kinds of searches they run.
Network Audit
The most important file. This is the log of every external agency, anywhere in the
country, that has searched your agency's cameras. Often very large (5–80 MB+). This is
where the federal access shows up. Always ask for this by name.
The "Reason" field
Flock requires (or recommends) officers enter a reason for each search. Most agencies
strip the reason column before releasing the audit logs, citing investigatory
exemptions. Ask for it explicitly. If they refuse, get the refusal in writing so you
can show that "transparency" without reasons is not transparency.
Contracts and policies
Ask for the full Flock contract, any data-sharing agreements with other agencies
(including federal), and any internal policies governing officer use, retention, and
sharing of ALPR data. These documents establish what the agency told the public the
cameras would do, which you can then compare against what the audit logs show
actually happened.
// Copy & Paste
Sample Request Letter.
Edit the bracketed fields and send. Email is fine. Many agencies have a dedicated public
records portal; the same language works in those forms.
[Date]
[Agency Name]
Attn: Public Records / Custodian of Records [Mailing or email address]
Re: Request for Records under the California Public Records Act
Dear Records Custodian,
Pursuant to the California Public Records Act (Cal. Gov't Code § 7920.000 et seq.), I
request the following records related to your agency's use of Flock Safety automated
license plate recognition (ALPR) cameras for the period from
[start date] to
[end date]:
1. A complete export of the Flock Safety "Audit" report (sometimes
labeled "Officer Audit") covering the period above, including all columns: officer
name, organization, search timestamp, network and devices searched, time frame
searched, license plate or filter values, search type, text prompt, moderation status,
and any other available fields.
2. A complete export of the Flock Safety
"Network Audit" report for the same period, including all columns:
organization name searching, search timestamp, license plate or filter values, search
type, text prompt, moderation status, and any other available fields. This is the
report showing external agencies that searched your camera data.
3. The "Reason" or "Reason for Search" field for every record in both
audit reports above. If your agency does not collect or store this field, please
confirm that in writing.
4. Any policies, procedures, training materials, or memoranda of understanding
governing your agency's use of Flock Safety cameras, including data-sharing agreements
with other agencies (including federal agencies).
5. The full text of your agency's current and any prior contracts with Flock Safety.
Records may be provided in their original electronic format (CSV preferred) via email
to [your email] at no charge.
Under Cal. Gov't Code § 7922.535, you must respond within ten (10) calendar days
indicating whether records exist and when they will be produced. Per § 7922.000(b), any
withholding must cite the specific exemption relied upon.
Please confirm receipt of this request. I look forward to your response within the
statutory window.
Sincerely, [Your name] [Address] [Email] [Phone]
// The Reply
When They Respond.
The law gives them ten days to acknowledge, with up to fourteen additional days for
"unusual circumstances." A complete production may take longer. Stay patient and
persistent.
What does a normal response look like?
An acknowledgement email or letter within ten days, usually citing § 7922.535 and
estimating when the records will be produced. Many agencies will produce contracts and
policies quickly and the audit logs more slowly because they need to be exported and
(in their view) reviewed.
What format will the data come in?
Flock exports are CSV files. Some agencies will convert them to PDF, which is much
harder to analyze. Ask for the original CSV. If they insist on PDF, push back: there
is no exemption that justifies converting electronic records into a less-usable
format.
What if some fields are redacted?
Common redactions include the Reason field, license plate strings, and case numbers.
Some redactions are legitimate (active investigations, victim information). Many are
overreaching. Ask for the specific exemption cited, in writing, for every redaction.
That paper trail becomes your evidence when you go public with the data.
// Escalation
If They Refuse Or Stall.
Agencies routinely delay, narrow, or deny CPRA requests in ways the law does not actually
permit. You have options.
Step 1: Pin them down in writing
Reply to any refusal asking for the specific Government Code section being cited as
the basis for withholding, and the agency's reasoning. Agencies often back down when
they realize their stated exemption does not apply.
Step 2: Escalate to leadership
Copy the city attorney, the city manager, the chief or sheriff, and your elected
representatives on follow-up correspondence. Public records compliance is a leadership
issue and elected officials generally do not want a CPRA fight in the press.
Step 3: Bring in help
Contact the
First Amendment Coalition legal hotline
(free), the ACLU of Northern California, EFF, or a local newsroom. A reporter asking
the same question often moves the request faster than a resident asking alone.
Step 4: Sue
CPRA violations are litigated in superior court. If you prevail, the agency pays your
attorneys' fees. The threat of a fee-shifting lawsuit is often what produces records.
Talk to FAC, ACLU NorCal, or a public records attorney before filing.
// After You Have The Data
Now What?
Raw CSVs are not a story until someone reads them. Here is what to look for first.
Count and group
Total searches. Searches by external agency. Searches by federal agency. Searches by
out-of-state agency. Searches that name immigration enforcement (HSI, CBP, ICE,
Border Patrol, USBP) in the Reason field. Each one of those buckets is a finding.
Compare to Flock's "transparency portal"
Flock publishes a public dashboard for every agency. Compare the search count it
shows for the same time window to the count in your CSV. In Nevada County the
difference was a factor of two thousand. That comparison is one of the most damning
data points you can produce.
Cross-reference against the law
California Civil Code § 1798.90.55(b) prohibits sharing ALPR data with non-California
entities. Cal. AG Bulletin 2023-DLE-06 (October 2023) prohibits sharing with federal
immigration enforcement. Anything in your data that violates either is a legal claim,
not just a policy concern.
Share what you find
Publish the numbers. Tell other communities. We are happy to compare notes, share
analysis scripts, or help interpret your data. Reach out at
deflocknevadacounty@proton.me.
Got The Receipts?
If you used this toolkit and got results in your own community, we want to hear from you.
The more communities that pull this data, the harder Flock's defaults become to defend.
[Date]
[Agency Name]
Attn: Public Records / Custodian of Records
[Mailing or email address]
Re: Request for Records under the California Public Records Act
Dear Records Custodian,
Pursuant to the California Public Records Act (Cal. Gov't Code § 7920.000 et seq.), I request the following records related to your agency's use of Flock Safety automated license plate recognition (ALPR) cameras for the period from [start date] to [end date]:
1. A complete export of the Flock Safety "Audit" report (sometimes labeled "Officer Audit") covering the period above, including all columns: officer name, organization, search timestamp, network and devices searched, time frame searched, license plate or filter values, search type, text prompt, moderation status, and any other available fields.
2. A complete export of the Flock Safety "Network Audit" report for the same period, including all columns: organization name searching, search timestamp, license plate or filter values, search type, text prompt, moderation status, and any other available fields. This is the report showing external agencies that searched your camera data.
3. The "Reason" or "Reason for Search" field for every record in both audit reports above. If your agency does not collect or store this field, please confirm that in writing.
4. Any policies, procedures, training materials, or memoranda of understanding governing your agency's use of Flock Safety cameras, including data-sharing agreements with other agencies (including federal agencies).
5. The full text of your agency's current and any prior contracts with Flock Safety.
Records may be provided in their original electronic format (CSV preferred) via email to [your email] at no charge.
Under Cal. Gov't Code § 7922.535, you must respond within ten (10) calendar days indicating whether records exist and when they will be produced. Per § 7922.000(b), any withholding must cite the specific exemption relied upon.
Please confirm receipt of this request. I look forward to your response within the statutory window.
Sincerely,
[Your name]
[Address]
[Email]
[Phone]