25-011 MOU Agreement with County of Santa Clara for use of ALPR's
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MEMORANDUM OF UNDERSTANDING BETWEEN THE COUNTY OF SANTA
CLARA AND THE CITY OF CUPERTINO REGARDING THE USE OF AUTOMATIC
LICENSE PLATE READERS (ALPRs)
This Memorandum of Understanding (“MOU”) is made between the County of Santa
Clara (“County”) and the City of Cupertino (“City”) (collectively referred to as the “Parties” and
each one a “Party”) regarding the administration of the City’s Automatic License Plate Reader
system (“ALPRs”).
I. PURPOSE
In 2014, the County entered into a Law Enforcement Contract with the City pursuant to
which the County of Santa Clara Office of the Sheriff (“Sheriff’s Office”) provides law
enforcement services within the corporate limits of the City. In 2024, the Parties entered into a
First Amendment to the Law Enforcement Contract. The Law Enforcement Contract and First
Amendment to the Law Enforcement Contract are attached as Exhibit A to this MOU.
The City has leased ALPRs for use within the corporate limits of the City.
The City desires that the Sheriff’s Office administer the ALPR system pursuant to the
Law Enforcement Contract and First Amendment to the Law Enforcement Contract between the
County and the City.
The purpose of this MOU is to govern the Parties’ obligations with respect to the ALPRs.
II. ROLES AND RESPONSIBILITIES
A. Acquisition and Maintenance of ALPRs
The City will be responsible for the acquisition, installation, and maintenance of the
ALPRs, and any associated costs. The City shall consult with the Sheriff’s Office on the
placement of the ALPRs.
B. Authorized and Prohibited Uses
The ALPRs will only be used for the purposes identified in the City’s ALPR Policy
(attached as Exhibit B) and the County ALPR Surveillance Use Policy (attached as Exhibit C).
Where a conflict exists between the City’s ALPR Policy and the County ALPR Surveillance Use
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Policy, the County ALPR Surveillance Use Policy shall govern the conduct of the County and
the Sheriff’s Office, and any officers, employees, or agents thereof, with respect to the ALPRs.
C. Data Collection, Storage, Access, Sharing, and Retention
Data collection, storage, access, sharing, and retention will be in accordance with the
City’s ALPR Policy and the County ALPR Surveillance Use Policy. Where a conflict exists
between the City ALPR Policy and the County ALPR Surveillance Use Policy, the County
ALPR Surveillance Use Policy shall govern the conduct of the County and the Sheriff’s Office,
and any officers, employees, or agents thereof, with respect to the ALPRs.
The City further agrees that it will delegate the administrative account with two-factor
authentication enabled for the ALPR system to a Sheriff’s Office employee designated by the
Sheriff’s Office. The City shall at no time maintain an account for the ALPR system that allows
the City access to the data collected or stored by the ALPR system.
D. Data Ownership
As between the County and the City, the City shall own any data captured by the ALPR
system. The County shall own any data input by the Sheriff’s Office into the ALPR system and
any data or records generated by the ALPR system or by the ALPR vendor reflecting a match
between an image and a vehicle of interest.
E. Training
All Sheriff’s Office personnel authorized to use and access the ALPR system and data
pursuant to this MOU shall receive all required training from the Sheriff’s Office. Said Personnel
shall also review and receive copies of the City’s ALPR Policy and the County ALPR
Surveillance Use Policy.
F. Oversight
Each Party will be responsible for ensuring that its officers, employees, and agents
comply with this MOU, including the City’s ALPR Policy and County Surveillance Use Policy.
All access to ALPR Data shall be logged, and the Sheriff’s Office shall maintain an audit
trail of requested and accessed information, including the purpose of the search. The Sheriff’s
Office shall conduct an audit on at least an annual basis to determine compliance with this MOU,
the incorporated exhibits, and all applicable laws. The Sheriff shall provide copies of the audit
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report to the City as requested, but is entitled to withhold any law enforcement sensitive portions
of the report (e.g. California Department of Justice or other criminal justice data released on a
need to know/right to know basis).
G. Compensation
The Sheriff’s Office will be compensated for services performed under this MOU in
accordance with Section II of the Law Enforcement Contract and the First Amendment to the
Law Enforcement Contract.
III. TERM OF AGREEMENT
The term of this MOU shall commence upon the date of execution by all Parties and shall
expire on June 30, 2026, unless otherwise terminated by the Parties as provided herein. The
Parties may, by written amendment to this MOU executed by all Parties, extend the term of the
MOU.
IV. TERMINATION
Any Party may terminate this MOU, at any time and without cause, upon 60 days’
written notice given to the other Party pursuant to Section VI, “NOTICES”.
The County (through the Board of Supervisors) may immediately terminate the MOU for
cause if it determines that the City is violating the terms of this MOU, including the attached
Exhibits. Prior to terminating for cause, the County must provide the City with notice of the
alleged breach, and provide the City 5 business days to respond and remedy the breach. The
County (through the Board of Supervisors) may immediately terminate the MOU if City fails to
timely remedy the breach.
Notwithstanding Section III, the MOU shall immediately terminate upon the termination
of the Law Enforcement Contract (including any extensions or amendments thereof).
Should the City revoke or amend the City ALPR Policy, or the County revoke or amend
the County ALPR Policy, either Party has the option to either terminate this MOU or to offer an
amendment to the MOU.
V. AMENDMENTS
This MOU may only be amended by a written instrument signed by the Parties.
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VI. NOTICES
Any notice required to be given under this MOU shall be in writing and addressed as
follows:
Notice to County: Robert Jonsen, Sheriff
Santa Clara County Office of the Sheriff
55 W. Younger Avenue
San Jose, CA 95110
County of Santa Clara Board of Supervisors
70 West Hedding Street
East Wing, 10th Floor
San Jose, CA 95110
James R. Williams, County Executive
70 West Hedding Street,
East Wing, 11th Floor
San Jose, CA 95110
Tony LoPresti, County Counsel
70 West Hedding Street
East Wing, 9th Floor
San Jose, CA 95110
Notice to City: Pamela Wu, City Manager
10300 Torre Avenue
Cupertino, CA 95014
Christopher Jensen, City Attorney
10300 Torre Avenue
Cupertino, CA 95014
Thomas Chin, Emergency Manager
10300 Torre Avenue
Cupertino, CA 95014
Notice required by this MOU shall be effective when deposited in the United States mail, first
class postage prepaid.
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VII. INDEMNIFICATION AND INSURANCE
Indemnification and insurance for purposes of this MOU will be governed by Sections IV
and V of the Law Enforcement Contract.
VIII. RECORDS REQUESTS
The Parties are public agencies subject to the disclosure requirements of the California
Public Records Act (“CPRA”).
To the extent a Party’s proprietary information is contained in documents or information
submitted to any other Party, and the Party submitting the document or information (“submitting
Party”) claims that such information falls within one or more CPRA exemptions, the submitting
Party must clearly mark such information “CONFIDENTIAL AND PROPRIETARY” or with
similar language, and identify the specific lines containing the information. In the event of a
request for such information, the Party in receipt of such information (“receiving Party”) will
make best efforts to provide notice to the submitting Party prior to such disclosure pursuant to a
CPRA request. If the receiving Party receives a CPRA request seeking or partially seeking
information clearly marked as confidential or proprietary of the submitting Party, the receiving
Party will provide written notice to the submitting Party in a reasonably prompt manner. If the
submitting Party contends that any documents are exempt from the CPRA and wishes to prevent
disclosure, it is required to obtain a protective order, injunctive relief or other appropriate remedy
from a court of law in Santa Clara County before the receiving Party is required to respond to the
CPRA request. If the submitting Party fails to obtain such remedy within the time the receiving
Party is required to respond to the CPRA request, the receiving Party may disclose the requested
information.
Data collected by the ALPRs shall not be made public unless required by federal or state
law or court order. The Parties agrees that they will notify and consult with the other with respect
to any CPRA request seeking records relating to the ALPR system.
Each Party agrees that it shall defend, indemnify and hold harmless the other against any
claim, action or litigation (including but not limited to all judgments, costs, fees, and attorney’s
fees) that may result from denial of a CPRA request for information arising from any
representation, or any action (or inaction) of the indemnifying Party.
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IX. CONFLICTS OF INTEREST
The Parties shall comply, and shall ensure that their employees, contractors and
subcontractors comply, with all applicable (i) requirements governing avoidance of
impermissible client conflicts; and (ii) federal, state and local conflict of interest laws and
regulations including, without limitation, California Government Code section 1090 et. seq., the
California Political Reform Act (California Government Code section 87100 et. seq.) and the
regulations of the Fair Political Practices Commission concerning disclosure and disqualification
(2 California Code of Regulations section 18700 et. seq.). In accepting this MOU, the Parties
covenant that they presently have no interest, and will not acquire any interest, direct or indirect,
financial or otherwise, which would conflict in any manner or degree with the performance of
this MOU. Each Party is responsible for assuring compliance of its subcontractors and
employees with the requirements of this provision.
X. NON-DISCRIMINATION
The Parties shall comply with all applicable laws concerning nondiscrimination and equal
opportunity in employment and contracting, including but not limited to the following: Title VII
of the Civil Rights Act of 1964 as amended; Americans with Disabilities Act of 1990; the Age
Discrimination in Employment Act of 1967; the Rehabilitation Act of 1973 (Sections 503 and
504); the Equal Pay Act of 1963; California Fair Employment and Housing Act (Gov. Code §
12900 et seq.); California Labor Code sections 1101, 1102, and 1197.5; and the Genetic
Information Nondiscrimination Act of 2008. In addition to the foregoing, the Parties shall not
discriminate against any subcontractor, employee, or applicant for employment because of age,
race, color, national origin, ancestry, religion, sex, gender identity, gender expression, sexual
orientation, mental disability, physical disability, medical condition, political belief,
organizational affiliation, or marital status in the recruitment, selection for training (including but
not limited to apprenticeship), hiring, employment, assignment, promotion, layoff, rates of pay or
other forms of compensation. Nor shall the Parties discriminate in the provision of services
provided under this contract because of age, race, color, national origin, ancestry, religion, sex,
gender identity, gender expression, sexual orientation, mental disability, physical disability,
medical condition, political beliefs, organizational affiliations, or marital status.
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XI. GOVERNING LAWS AND VENUE
This MOU has been executed and delivered in, and shall be construed and enforced in
accordance with, the laws of the State of California. Proper venue for legal action regarding this
MOU shall be in Santa Clara County.
XII. ENTIRE AGREEMENT
This MOU and its Exhibits and/or Attachments constitute the final, complete, and
exclusive statement of the terms of the agreement between the Parties regarding the subject of
this MOU. All Exhibits and/or Attachments to this MOU are incorporated herein as one
agreement. This MOU incorporates and supersedes all the agreements, covenants and
understandings between the Parties concerning the subject matter hereof, and all such
agreements, covenants and understandings have been merged into this MOU. In the event that
any term, condition, provision, requirement, or specification set forth in the body of this MOU
conflicts with or is inconsistent with any term, condition, provision, requirement, or specification
in any Exhibit and/or Attachment to this MOU, the provisions of the body of the MOU shall
prevail. No prior or contemporaneous agreement or understanding, verbal or otherwise, of the
Parties or their agents shall be valid or enforceable unless embodied in this MOU.
XIII. THIRD PARTY BENEFICIARIES
This MOU does not, and is not intended to, confer any rights or remedies upon any
person or entity other than the Parties.
XIV. SIGNATORIES NOT AGENTS/INDEPENDENT CONTRACTOR
Parties to this MOU shall have no authority, express or implied, to act on behalf of any
signatory in any capacity whatsoever as an agent. The Parties shall have no authority, express or
implied, pursuant to this MOU to bind each other to any obligation whatsoever. This MOU is not
a contract of employment and does not create an employer-employee relationship between the
Parties and neither Party shall be considered the employees of the other and shall not qualify for
or become entitled to any claims for employment and retirement benefits from the other.
XV. NON-ASSIGNMENT
No assignment of this MOU or of the rights and obligations hereunder shall be valid
without the prior written consent of all Parties.
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XVI. WAIVER
No delay or failure to require performance of any provision of this MOU shall constitute
a waiver of that provision as to that or any other instance. Any waiver granted by a party shall be
in writing and shall apply to the specific instance expressly stated.
XVII. COUNTERPARTS
This MOU may be executed by the Parties in separate counterparts, each of which when
so executed and delivered shall be an original, but all such counterparts shall together constitute
one and the same instrument.
XVIII. CONTRACT EXECUTION
Unless otherwise prohibited by law or County, the Parties agree that an electronic copy of
a signed contract, or an electronically signed contract, has the same force and legal effect as a
contract executed with an original ink signature. The term “electronic copy of a signed contract”
refers to a transmission by facsimile, electronic mail, or other electronic means of a copy of an
original signed contract in a portable document format. The term “electronically signed contract”
means a contract that is executed by applying an electronic signature using technology approved
by the County.
XIX. COVID-19 REQUIREMENTS (IF APPLICABLE)
City shall comply with all County requirements in effect relating to COVID-19 for
persons who routinely perform services for County onsite and share airspace with or proximity to
other people at a County facility as part of their services for County as set forth in a County
Health Order (or similar directives) available at https://covid19.sccgov.org/home, and
incorporated herein by this reference. City shall comply with all reasonable requests by County
for documentation demonstrating City’s compliance with this Section.
XX. LEVINE ACT COMPLIANCE
City will comply, and will ensure that its agents (as that term is defined under 2 Cal.
Code Regs. § 18438.3(a)) and its subcontractors identified in City’s proposal responding to a
County solicitation and/or identified in this Agreement (“Subcontractors”) comply, with
California Government Code section 84308 (“Levine Act”) and the applicable regulations of the
Fair Political Practices Commission concerning campaign disclosure (2 California Code of
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Regulations sections 18438.1 – 18438.8), which (1) require a party to a proceeding involving a
contract to disclose on the record of the proceeding any contribution, as defined by Government
Code section 84308(a)(6), of more than $250 that the party or their agent has made within the
prior 12 months, and (2) prohibit a party to a proceeding involving a contract from making a
contribution, as defined by Government Code section 84308(a)(6), of more than $250 to any
County officer during the proceeding and for 12 months following the final decision in the
proceeding. City agrees to submit any disclosures required to be made under the Levine Act at
the Office of the Clerk of the Board of Supervisors website at http://www.sccgov.org/levineact,
and Contractor shall require Subcontractors to do the same. If this Agreement is to be
considered or voted upon by the County’s Board of Supervisors, City shall complete the Levine
Act Contractor Form: Identification of Subcontractors and Agents, and if applicable, shall ensure
that any Subcontractor completes the Levine Act Subcontractor Form: Identification of Agents,
and City must submit all such forms to the County as a prerequisite to execution of the
Agreement.
WITNESS THE EXECUTION HEREOF on the day and year first hereinabove written.
COUNTY OF SANTA CLARA (“County”)
_______________________ Dated: _______________________
Otto Lee, President
Board of Supervisors
Signed and certified that a copy of this
document has been delivered by electronic
or other means to the President, Board of Supervisors.
Attest:
_______________________ Dated: _______________________
Curtis Boone
Acting Clerk of the Board of Supervisors
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Approved as to form and legality:
_______________________ Dated: _______________________
Stephanie M. Jackson
Deputy County Counsel
CITY OF CUPERTINO (“City”)
___________________________ Dated: _______________________
Pamela Wu
City Manager
APPROVED AS TO FORM:
___________________________ Dated: _______________________
Christopher D. Jensen
Cupertino City Attorney
___________________________ Dated: _______________________
Kirsten Squarcia
City Clerk
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Board of Supervisors: Sylvia Arenas, Cindy Chavez, Otto Lee, Susan Ellenberg, S. Joseph Simitian
County Executive: James R. Williams
First Amendment to Agreement By and Between the County of Santa Clara and the City of Cupertino.
FIRST AMENDMENT TO AGREEMENT BY AND BETWEEN THE COUNTY OF SANTA CLARA AND
THE CITY OF CUPERTINO
This is the First Amendment to the Agreement between the County of Santa Clara (County) and the City
of Cupertino (City) entered into on August 5, 2014, for law enforcement services to the City.
On August 5, 2014, the Board of Supervisors approved this Agreement.
This Agreement is amended as follows effective May 21, 2024:
1.Key Provision Change: Compensation
Key Provision, AGREEMENT TERM II. A. 1. the first sentence, related to Compensation for
Law Enforcement Services Provided by the Sheriff, on page 4 of the Agreement is amended
to read: “The City shall compensate the County utilizing the Fiscal Year 2024/2025 base rate
established for general law enforcement and county communications (hereinafter “law
enforcement”). The remainder of the language in Section II. A. 1. shall remain in effect .
2.Key Provision Change: Base Rent and Operating Costs of Westside Substation
Key Provision, AGREEMENT TERM II. C. 1. a. on pages 6-7, related to Base Rate and
Operating Costs of Westside Substation is amended to read: “The City’s share of the base
rent and operating cost of Westside Substation will be based upon the lease agreement
between the County and Dollinger Properties, LLC. The monthly base rent will increase 2.5%
each year commencing November 8, 2024, and City shall be responsible for its share of this
base rent increase. City shall be responsible for any increase in operating expenses and real
estate taxes allocated to the building to the extent that such expenses exceed costs incurred
in the FY2024/2025 Base Year. Yearly increases in controllable operating costs (other than
insurance, taxes, and utilities) shall be capped at 5%. These operating costs may be adjusted
only one (1) time per year to be effective at the start of each fiscal year on July 1.” The
remainder of the language in Section II. C.1. a. shall remain in effect.
3.Key Provision Change: Term of Agreement
Key Provision, AGREEMENT TERM VI. related to Term of Agreement, on page 9 of the
Agreement is amended to read: “This agreement shall become effective on July 1, 2024, and
may be terminated without cause by County or City upon the giving of one-hundred and
eighty (180) days written notice of such termination to the other party. In the absence of such
notice of termination, this agreement shall be effective for a term of twenty -four (24) months
through June 30, 2026, subject to any modifications which are made in accordance with the
terms and conditions of this agreement. If City elects to terminate this Agreement prior to the
expiration of the term, the City shall nonetheless pay the full amount of its pro -rata share
remaining on the County tenant improvements, moving costs, and remaining lease
commitments for the West Valley substation.” The following language is hereby deleted: “At
the expiration of this ten (10) year contract, this contract can be renewed for an additional five
(5) year period upon written notice of renewal by the City and the County to the other parties
at least one hundred eighty (180) days prior to the expiration of this contract.”
4.Add Exhibit A: Fiscal Year 2024-2025 Proposed Costs:
Exhibit A: Fiscal Year 2024-2025 Proposed Costs attached hereto this First Amendment is
added to the Agreement and incorporated herein by this reference.
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5. Replace Exhibit B:
Remove Exhibit B: Compensation for Seruices in its entirety and replace with Exhibit B:
Law Enforcement Contract Compensation for Services, attached hereto this First
Amendment and incorporated herein by this reference.
All other terms and conditions of the Agreement remain in full force and effect. ln the event of a conflict
between the original Agreement and this First Amendment, this First Amendment controls.
The Agreement as amended constitutes the entire agreement of the parties concerning the subject matter
herein and supersedes all prior oral and written agreements, representations and understandings
concerning such subject matter.
IN WITNESS WHEREOF, COUNTY and CITY OF CUPERTINO hereby agree to the terms of
this First Amendment to the Contract.
COUNTY OF SANTA CLARA CITY OF CUPERTINO
6r^*t^^6ut*r^txn-
Susan Ellenberg
President, Board of Supervisors
Date: illAY 2 1.2024
Wu
City , City of Cupertino
Date:b /+ b-'ry
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Signed and certified that a copy ofthis document
has been delivered by electronic or other means to
the President, Board of Supervisors.
A ST:
Acting Clerk of the
llAY 2 I 202f
LEGALITY
Date:
APPROVED AS TO FORM AND LEGALITY
DocusiEned by:
Stephanie
Deputy County Counsel
Date: 5/L5/2024
Board of Supervisors: Sylvia Arenas, Cindy Chavez, Otto Lee, Susan Ellenberg, S. Joseph Simitian
County'Executive: James R. Williams
First Amendment to Agreement By and Between the County of Santa Clara and the City of Cupertino.
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Cupertino
Los Altos
Hills Saratoga
Unincorporated
Areas Total
General Law Enforcement Services (Primary Rate)
Proposed Hours 41,881 5,421 20,060 14,696 82,058
Supplemental Services ‐ Traffic Enforcement ‐ Day
Proposed Hours ‐ Enforcement Vehicle ‐ Deputy Sheriff 1,803 ‐ ‐ ‐ 1,803
Proposed Hours ‐ Motorcycle ‐ Deputy Sheriff 5,447 1,860 4,195 ‐ 11,502
Total Proposed Hours 7,250 1,860 4,195 ‐ 13,305
Investigative Services
Proposed Hours 5,100 750 2,400 ‐ 8,250
Supplemental Reserve Services
Proposed Hours 200 22 68 ‐ 290
Total Proposed Hours 54,431 8,053 26,723 14,696 103,903
Traffic Sergeant
Number of Traffic Sergeant 1 ‐ ‐ ‐
School Resources Officer
Number of SRO 2 ‐ 1 ‐
Proposed Hours
Fiscal Year 2024‐2025
Exhibit A: 2024-2025 Proposed Costs
Exhibit A: Page 1 of 5
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Cupertino Los Altos Hills Saratoga
Unincorporated
Areas
General Law Enforcement Services
Proposed Costs $12,788,363 $1,655,302 $6,125,321 $4,487,424
Supplemental Services ‐ Traffic Enforcement ‐ Day
Proposed Costs $2,193,343 $562,555 $1,269,219 $0
Investigative Services
Proposed Costs $1,325,235 $194,888 $623,640 $0
Supplemental Reserve Services
Proposed Costs $15,400 $1,694 $5,236 $0
Traffic Sergeant
Proposed Costs $570,774 $0 $0 $0
School Resources Officer
Proposed Costs $725,330 $0 $317,332 $0
(Cupertino ‐ 1 SRO @ 85% and 1 SRO @ 75%; Saratoga ‐ 1 SRO @ 70%)
Operating Costs Of West Valley Substation
Proposed Costs $279,769 $41,389 $137,355 $75,536
Overtime $0 $200,000 $0 $0
Total Proposed Contract Costs $17,898,214 $2,655,828 $8,478,103 $4,562,960
Total Capped Costs *$17,916,051 $2,661,025 $8,479,808 $4,553,260
Amount in Excess of of/ (Below Budget Cap)($17,837) ($5,197) ($1,705)$9,700
PROPOSED CONTRACT COSTS
Fiscal Year 2024‐2025
*Increase in costs capped at the lesser of CPI+2% or the average compensation increase and PERS increase
Exhibit A: Page 2 of 5
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Cupertino Los Altos Hills Saratoga
Unincorporated
Areas
Budgeted Costs FY 2023‐2024 $11,756,416 $1,521,729 $5,631,043 $4,125,314
Proposed Costs FY 2024‐2025 $12,788,363 $1,655,302 $6,125,321 $4,487,424
Change ($)$1,031,947 $133,573 $494,278 $362,110
Change (%)8.78% 8.78% 8.78%8.78%
Budgeted Costs FY 2023‐2024 $2,509,784 $516,755 $1,165,888 $0
Proposed Costs FY 2024‐2025 $2,193,343 $562,555 $1,269,219 $0
Change ($)($316,441)$45,800 $103,331 $0
Change (%)‐12.61% 8.86% 8.86%
Budgeted Costs FY 2023‐2024 $1,815,480 $189,113 $605,160 $0
Proposed Costs FY 2024‐2025 $1,325,235 $194,888 $623,640 $0
Change ($)($490,245)$5,775 $18,480 $0
Change (%)‐27.00% 3.05% 3.05%
Budgeted Costs FY 2023‐2024 $24,090 $1,606 $4,964 $0
Proposed Costs FY 2024‐2025 $15,400 $1,694 $5,236 $0
Change ($)($8,690)$88 $272 $0
Change (%)‐36.07% 5.48% 5.48%
Budgeted Costs FY 2023‐2024 $539,190 $0 $0 $0
Proposed Costs FY 2024‐2025 $570,774 $0 $0 $0
Change ($)$31,584 $0 $0 $0
Change (%)5.86% 0.00% 0.00%
Budgeted Costs FY 2023‐2024 $637,308 $0 $278,822 $0
Proposed Costs FY 2024‐2025 $725,330 $0 $317,332 $0
Change ($)$88,022 $0 $38,510 $0
Change (%)13.81% 0.00% 13.81%
COSTS COMPARISON BETWEEN
Fiscal Years 2023‐2024 and 2024‐2025
Supplemental Services ‐ Traffic Enforcement ‐ Day
General Law Enforcement Services
Investigative Services
Supplemental Reserve Services
School Resources Officer
Traffic Sergeant
Exhibit A: Page 3 of 5
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Cupertino Los Altos Hills Saratoga
Unincorporated
Areas
Budgeted Costs FY 2023‐2024 $284,858 $38,064 $126,322 $69,468
Proposed Costs FY 2024‐2025 $279,769 $41,389 $137,355 $75,536
Change ($)($5,089)$3,325 $11,033 $6,068
Change (%)‐1.79% 8.74% 8.73%8.73%
Budgeted Costs FY 2023‐2024 $0 $200,000 $0 $0
Proposed Costs FY 2024‐2025 $0 $200,000 $0 $0
Change ($)$0 $0 $0 $0
Change (%)0%
Total Budgeted Costs FY 2023‐2024 $17,567,126 $2,467,267 $7,812,199 $4,194,782
Total Proposed Costs FY 2024‐2025 $17,898,214 $2,655,828 $8,478,103 $4,562,960
Change ($)$331,088 $188,561 $665,904 $368,178
Change (%)1.88% 7.64% 8.52%8.78%
Overtime
Operating Costs Of West Valley Substation
Exhibit A: Page 4 of 5
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Cupertino Los Altos Hills Saratoga
Unincorporated
Areas
Total Budgeted Costs FY 2023‐2024 $17,567,126 $2,467,267 $7,812,199 $4,194,782
Adjusted Total Budgeted Costs ‐
Excluding Operating Costs of West
Valley Substation and Overtime FY 2024‐2025 $16,248,254 $2,229,203 $7,685,877 $4,125,314
Annual Allowable Increase Including
PERS 8.54% $1,388,028 $190,433 $656,576 $352,410
FY2024‐2025 Capped Costs $17,636,282 $2,419,636 $8,342,453 $4,477,724
FY2024‐2025 Operating Costs of West Valley Substation $279,769 $41,389 $137,355 $75,536
Overtime $0 $200,000 $0 $0
Total FY2024‐2025 Budget Cap $17,916,051 $2,661,025 $8,479,808 $4,553,260
FY 2024‐2025 Proposed Costs $17,898,214 $2,655,828 $8,478,103 $4,562,960
Amount in Excess of or (Below Budget Cap)($17,837) ($5,197)($1,705)$9,700
FY 2024‐2025 Budget Cap
Exhibit A: Page 5 of 5
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Exhibit B:
Law Enforcement Contract
Calculation of Annual Compensation
To calculate the annual projected budget increase to this contract, the following shall
apply:
ANNUAL COST OF LIVING INCREASE IN TOTAL COMPENSATION:
1.Total compensation refers to the amount Santa Clara County Sheriff Department
provides for total compensation (salary and benefits) at top step for a 40-hour patrol
deputy.
2.At the subsequent July 1, the new total compensation amount (exclusive of PERS)
will be divided by the total compensation effective on the prior July 1 ( exclusive of
PERS), to derive a percentage change in total compensation.
The annual projected budget increase in contract costs shall be computed as follows:
Fiscal Year 2024/2025:
Base Year 2024/2025 costs = costs as shown in Exhibit A to
this Agreement.
Fiscal Years 2024/2025 through 2025/2026:
Preceding Base Year Costs
X
Lesser of Percentage change in total compensation or Consumer Price
Index-Urban Wage Earners and Clerical Workers (CPVW) plus 2% (For
years in which compensation is increased in a multi-year contract, the
annual increase to law enforcement service costs shall be limited to the
average compensation increase for each year of the co ntract, not to exceed
CPVW plus 2% for each individual year.)
Plus
Percentage Change (Increase/Decrease) in Actual County PERS Costs
...
Exhibit B: Page 1 of 1
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RESOLUTION NO. 24-094
A RESOLUTION OF THE CUPERTINO CITY COUNCIL
ESTABLISHING A POLICY FOR AUTOMATED LICENSE PLATE READERS
WHEREAS, Automated License Plate Reader (ALPR) cameras are used by police
departments across the United States to instantly capture license plate information
and compare it against lists of license plates associated with stolen vehicles, people
who have committed a crime, and for other investigative purposes; and
WHEREAS, many organizations that have used ALPR technology have found it
to be an effective tool in fighting crime; and
WHEREAS, California Civil Code section 1798.90.5 requires that public agencies
with ALPRs adopt and implement a usage and privacy policy that identifies the
individuals who will have access to the ALPR data, describes how the ALPR
system will be monitored, lists parameters for sharing of ALPR data, describes
measures that will be taken to protect the accuracy of ALPR data, and specifies the
retention period for ALPR data.
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of
Cupertino hereby adopts the attached Automated License Plate Reader Policy for
the use of ALPR cameras in the City of Cupertino.
PASSED AND ADOPTED at a regular meeting of the City Council of the City of
Cupertino this 1st day of October, 2024, by the following vote:
Members of the City Council
AYES: Mohan, Fruen, Chao, Moore
NOES: None
ABSENT: Wei
ABSTAIN: None
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Resolution No. 24-094
Page 2
ATTEST:
Kirsten Squarcia, City Clerk Date
SIGNED:
Sheila Mohan, Mayor City
of Cupertino
Date
10/10/2024
10/10/2024
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Resolution No. 24-094
Page 3
CITY OF CUPERTINO AUTOMATED LICENSE PLATE READER POLICY
I. Purpose
The City of Cupertino ("City") leases an Automated License Plate Reader (ALPR)
system within the City operated by the Santa Clara County Sheriff's Office
("Sheriff's Office") for certain law enforcement and public safety purposes. ALPR
systems use high-speed cameras to photograph vehicle license plates. The City
intends to contract with vendors to install and maintain the ALPR system. The City
ALPR system may also obtain data from ALPR cameras not owned or leased by
the City. This policy applies to data held within the City's ALPR system but does
not apply to data held independently by the owners or lessors of ALPR cameras not
owned or leased by the City. The City ALPR system is intended only for authorized
law enforcement and public safety purposes, and its data are only intended to be
accessed by authorized users.
California Civil Code section 1798.90.5 requires public agencies operating ALPR
systems to adopt and implement a usage and privacy policy to ensure that the
collection, use, maintenance, sharing, and dissemination of information collected
pursuant to such system protects individual privacy and civil liberties. Consistent
with the City's commitment to individual privacy and civil liberties and the State
law mandate, the City has adopted this policy to regulate the use, management,
retention, and other aspects of the City's ALPR system. This policy shall be made
available to the public in writing and posted on the City's website.
II. Authorized and Prohibited Uses
The City ALPR system shall only be utilized for the following purposes:
• To locate stolen, wanted, and/or other vehicles that are the subject of an
investigation
• To locate and/or apprehend individuals subject to arrest warrants or who are
otherwise lawfully sought by law enforcement
• To locate victims, witnesses, suspects, and others associated with a law
enforcement investigation
• To locate missing persons, including in response to Amber Alerts and Silver
Alerts
• To support local, State, Federal, and regional public safety departments in the
identification of vehicles associated with targets of criminal investigations,
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Resolution No. 24-094
Page 4
including investigations of serial crimes
• To analyze traffic patterns using anonymized data
• To protect participants at special events; and
• To protect critical infrastructure sites.
Any data obtained from the City ALPR system shall be used and handled pursuant
to this policy and applicable State and Federal law. All other uses not referenced
above are prohibited. Under no circumstances shall the ALPR system be used for
personal or commercial purposes or other purposes not specifically authorized
above. Access to the ALPR system does not negate the need to comply with other
laws or regulations, including obtaining a search warrant when legally required.
The City shall at no time maintain an account for the ALPR system that allows the
City to access the data collected or stored by the ALPR system.
III. Data Collection
The City ALPR system shall collect digital images of vehicle license plates and their
associated license plate numbers. The ALPR system shall collect the date and time
the license plate passes a digital-image site where an ALPR is located, a captured
vehicle's geographical location, and vehicle details (make, model, type, and color).
Live video, vehicle speeds, and audio shall not be provided or recorded. To the
extent practicable, the ALPR system shall be designed to blur images of
individuals that the system may inadvertently collect.
IV. Installation and Maintenance
This policy addresses the installation and maintenance of city-owned or leased
ALPR devices. An Encroachment Permit will be required for the installation of
these devices. While there will be no fee for the permit, an insurance certificate
will be necessary. A traffic control plan will also be required if traffic is obstructed
during installation.
No privately leased or owned ALPR devices will be permitted on City
infrastructure. The City will lease the ALPR devices from a vendor responsible for
installation and maintenance. The vendor will not be authorized to access data
collected by the ALPR system under any circumstances. Their role will be limited
to operating, inspecting, troubleshooting, and maintaining the system hardware,
software, associated cloud storage mechanisms, and servers, as necessary. To the
extent feasible, cameras should be directed toward public property and away
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Resolution No. 24-094
Page 5
from private property.
V. Data Access, Storage, and Protection
The City's ALPR system may only be used by, and data collected thereunder shall
be accessible only by, personnel of the Sheriff's Office pursuant to a contract
providing law enforcement services to the City. The City's ALPR system shall be
accessible only through a login and password-protected system capable of
documenting individual user access by name, date, and time.
In addition to this policy, Sheriff's Office personnel shall observe and comply with
the Sheriff's Office Surveillance Use Policy and any additional guidelines and
regulations that are in place governing ALPR use and access. Prior to the City
granting use and access, the Sheriff's Office shall execute an agreement with the City
and/or the City's contracted ALPR vendor(s), to the satisfaction of the City
Attorney, agreeing to comply with this policy.
Contracts with vendors for the operation, maintenance, and repair of the ALPR
system shall provide that the vendor is not authorized to access data collected by
the ALPR system under any circumstances. Such vendors shall only be tasked with
operating, inspecting, troubleshooting, and maintaining the system hardware,
software, associated cloud storage mechanisms, and servers, as necessary.
Data collected by the City ALPR system is automatically uploaded to the ALPR
system's associated cloud storage at the time of capture. The City's contracted
ALPR vendor shall provide and maintain cloud storage and server capacity as part
of the scope of services. The City shall confirm that the contracted vendor installs
and implements appropriate security measures for such storage, including
encryption, firewalls, authentication, and other reasonable data protection
measures.
Data stored in the City ALPR system cloud space shall not be downloaded to a local
server, stored locally on a hard drive or portable device, or provided in a physical
printout, except in the following cases:
• Where the ALPR system has identified vehicle license plate images and
numbers as a match to a law enforcement registry
• Where data retrieval is necessary for conducting or assisting with a
criminal investigation or to facilitate an authorized use identified in Section II
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Resolution No. 24-094
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above
Only personnel from the Sheriff's Office working in an investigative or enforcement
function may download ALPR data for local storage or printout (collectively,
"Local Data") for authorized purposes stated herein. Data from the City ALPR
system may not otherwise be downloaded for any other purpose, whether by
Sheriff's Office authorized personnel, City staff, or other individuals or entities.
Local Data shall be maintained in accordance with applicable State and Federal
evidentiary laws and in accordance with appropriate chain of custody practices.
Additionally, the Sheriff's Office shall implement physical security, encryption,
firewalls, authentication, and other reasonable security measures to protect Local
Data retrieved from the system.
Local Data shall be accessible only through a login and password-protected system
capable of documenting individual user access by name, date, and time.
VI. Data Retention
Data stored in the ALPR cloud system shall be purged after thirty (30) days from
the date it was uploaded to the cloud system unless downloaded or stored pursuant
to Section IV above.
Data that is downloaded or stored pursuant to Section IV above shall be purged no
later than tweleve (12) months from the date it was downloaded for local storage
unless the data thereafter becomes associated with a criminal investigation or an
ongoing case for an authorized purpose identified in Section II above. In the latter
case, the data shall be retained for the duration of the criminal investigation and
the criminal proceedings through adjudication of the case in the same manner as
other evidence in the matter unless otherwise ordered by the court to be retained
for a longer period or permanently.
VII. Public Access
Data from the City ALPR system shall not be sold, shared, or transferred except as
explicitly authorized by this policy. Data from the City ALPR system shall not be
made public unless specifically required by State or federal law or court order. If
a public request for data is received, the Sheriff's Office shall consult with the Santa
Clara County Counsel's Office to determine whether the requested data is exempt
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Resolution No. 24-094
Page 7
from disclosure pursuant to the California Public Records Act or other State of
Federal law provisions, and whether any additional steps are required in response
to such a request for data.
VIII. Third-Party Data Sharing
Data-sharing from the City's ALPR system shall be limited to only the following:
• District Attorney's Office for use as evidence to aid in prosecution, in
accordance with laws governing evidence
• Public Defender's Office or criminal defense attorney via the District Attorney's
Office in accordance with California criminal discovery laws; and
• Other law enforcement agencies, as part of a formal criminal or administrative
investigation
• Parties to civil litigation in response to a court order.
IX. Training
All personnel authorized to use and access the ALPR system and data pursuant to
this policy shall receive all required training from the Sheriff's Office. Said personnel
shall also review and receive copies of this policy and the Sheriff's Office
Surveillance Use Policy.
X. Oversight
The Sheriff's Office shall ensure compliance with this policy as the provider of law
enforcement services to the City.
All-access to ALPR system data shall be logged, and the Sheriff's Office shall
maintain an audit trail of requested and accessed information, including the
purpose of the search. Periodic, random audits shall be conducted by the Sheriff's
Office and on at least an annual basis. Audits shall ensure compliance with this
policy and all applicable laws and shall be used to ensure the accuracy of ALPR
information and correct data errors. Audit reports shall contain at least the
following information:
• Name of law enforcement agency that accessed the data
• Date and time of access
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Resolution No. 24-094
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• Reason for accessing data
• Activity executed, including any license plate numbers searched identified in a
separate confidential appendix
• Incident number associated with the investigation
• The number of arrests resulting from the ALPR system
• The number and type of data requests, disclosures, and denials
• The number and nature of any violations of this policy or applicable laws
• The number and resolution of any complaints received
• Any challenges or problems encountered with the ALPR system
• Any recommendations for improvement or enhancement of the ALPR system
Upon completion of each audit, the Sheriff's Office shall provide a copy of the audit
report to the City Manager or the City Manager's designee within five (5) business
days of completion.
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County of Santa Clara
Office of the Sheriff
Surveillance Use Policy
City of Cupertino's
Automated License Plate Readers
1. Purpose
Automated license plate readers (ALPRs) use high speed cameras to photograph vehicle
license plates. The Office of the Sheriff s pu{pose for using ALPR Technology is to assist
the Sheriff s Office in implementing a strategy to assist in criminal investigations, protect
residents, and deter crime.
Under the Sheriff s Office's contract to provide law enforcement services to the City of
Cupertino (CitV) and pursuant to a specific, Board-approved agreement between the City
and the Sheriffls Offrce goveming ALPRs, it shall be permissible for the Sheriff s Office to
manage andlor operate the City's Flock Safety Falcon ALPR (Flock Safety ALPR). To the
extent managed andlor operated by the Sheriff s Office, the Flock Safety ALPR shall only
be placed at fixed locations for the authorized law enforcement and public safety pu{poses
set forth in this Surveillance Use Policy.
The Flock Safety ALPR may collect license plate information from vehicles on roadways,
on property accessible to the public, and on private property. ALPR cameras shall not be
installed with the specific pu{pose of monitoring vehicles on private property. When an
ALPR camera is installed, reasonable efforts shall be made to reduce the amount of
incidental monitoring of vehicles on private property. A search warrant shall be obtained
when legally required.
For purposes of this Policy, the following definitions shall apply:
Automated License Plate Reader (ALPR): A device that uses cameras and
computer technology to compare digital images to lists of known information of
interest.
Vehicles of Interest: Vehicles which are reported as stolen; display stolen license
plates or tags; vehicles linked to missing andlor wanted persons and vehicles flagged
by the Department of Motor Vehicle Administration or law enforcement agencies.
o
a
2.
Office of the Sheriff
Surveillance Use Policy - City of Cupertino
Automated License Plate Readers (ALPR)
Authorized and Prohibited Uses
With Board approval of a specific agreement between the County and City goveming the
use of ALPRs, it shall be permissible for the Sheriff s Office to manage andlor operate the
Page I of6 January 2025
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Flock Safety ALPR for the City. The Flock Safety ALPR shall only be attached to fixed
locations.
The Flock Safety ALPR shall be used for only the following pu{poses, consistent with
Section I of this Surveillance Use Policy:
To locate stolen, wanted, andlor other vehicles that are the subject of specific
investigation;
To locate and/or apprehend individuals subject to arrest warrants or who are
otherwise lawfully sought by law enforcement;
To locate victims, witnesses, suspects, and others associated with a specific law
enforcement investigation;
To locate missing children, adults, and/or elderly individuals, including in
response to Amber Alerts and Silver Alerts;
To support public safety departments in the identification of vehicles associated
with targets of specific criminal investigations, including specific investigations
of serial crimes; and
To protect critical infrastructure sites.
Any data obtained from Flock Safety ALPR shall be used and handled pursuant to this
Surveillance Use Policy and applicable state and federal law.
All other uses not referenced above shall be prohibited. The Flock Safety ALPR shall not
be used to unlawfully invade the privacy of individuals. Neither the Flock Safety ALPR
nor its data shall be used for personal, non-1aw-enforcement-related pu{poses; and they
shall not be used to harass, intimidate, or discriminate against any individual or group.
Additionally, the Flock Safety ALPR shall not be used to identify individuals engaged in
activity protected by the Constitution of the State of California or Constitution of the
United States, such as peaceful, non-violent demonstrations or protests. Flock Safety
ALPR shall not use Artificial Intelligence (A.I.) or facial recognition software.
Data Collection
Digital images of vehicle license plates and their associated license plate numbers shall
be collected by the Flock Safety ALPR cameras and uploaded to the encrypted cloud-
based database. The Flock Safety ALPR shall collect an image of the license plate, the
date and time that the license plate passes a digital-image site where an ALPR is located,
as well as a captured vehicle's geographical location and vehicle details (make, model,
type and color). Live video, vehicle speeds, and audio shall not be provided or recorded.
a
a
a
o
o
3.
Office of the Sheriff
Surveillance Use Policy - City of Cupertino
Automated License Plate Readers (ALPR)
Page2 of 6 January 2025
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4.Data Access
It shall be permissible for data collected by the Flock Safety ALPR to be accessible by
trained, authorized Sheriff s personnel.
It shall be permissible for technical and customer support staff from vendors, such as
Flock, to access the Flock System ALPR for maintenance and repair of ALPRs on an as-
needed basis, and such vendors shall only be tasked with the inspection, troubleshooting,
and maintenance of the ALPR system hardware and software configuration, associated
cloud storage mechanism and server, as necessary. Vendors shall not be authorized to
access specific data collected by ALPRs under any circumstances.
5.Data Protection
The Flock Safety ALPR data shall be stored in a secured cloud environment. Flock Safety
ALPR shall maintain multiple layers of physical security and security protection or utilize a
cloud service compliant with Criminal Justice Information Services requirements.
Encryption for data at rest and in transit, firewalls, authentication, and other reasonable
security measures, including the following, shall be utilized to protect ALPR data:
All ALPR data downloaded to the mobile workstation or in storage shall be
accessible only through a login/password-protected system capable of
documenting all access of information by name, date, and time.
Only those employees of the Sheriff s Office working in an investigative or
enforcement function shall access ALPR data, and that access shall be only for a
pu{pose authorized in this Surveillance Use Policy.
6. Data Retention
ALPR data from the Flock Safety ALPR associated with a specific criminal investigation
may be downloaded onto an electronic storage device or printed. Downloaded, copied, and
printed data shall be maintained in accordance with applicable state and federal evidentiary
laws, to include retaining the data through the adjudication of a case in a recognized court
of law, as well as allotment of time for an appeals process and statute of limitations.
Flock Safety ALPR data collected shall be purged no later than 30 days from the date it
was collected unless the data is needed for a specific investigation. Under those
circumstances, the data shall be retained for the duration of the specihc criminal
investigation and the criminal proceedings through adjudication of the case or in
accordance with local, state, and federal court orders or laws governing its use. Data that is
flagged as a Vehicle of Interest by Flock Safety ALPR, or otherwise downloaded and
stored pursuant to this section shall be purged no later than six months from the date it was
flagged or downloaded for local storage, unless the data is associated with a specific
criminal investigation or an ongoing case for an authorized purpose identified in Section 2
above.
Office of the Sheriff
Surveillance Use Policy - City of Cupertino
Automated License Plate Readers (ALPR)
a
a
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7 Public Access
Flock Safety ALPR data shall be made public or deemed exempt from public disclosure
pursuant to state or federal law. For public requests for data, the Sheriffls Office shall
confer with County Counsel to determine whether the requested data is exempt from
disclosure pursuant to the California Public Records Act (CPRA), or is legally required to
be disclosed, and shall respond to requests in compliance with applicable law. CPRA
requests to the County for data from the Flock Safety ALPR shall follow this same review
process, but with the inclusion of the City's City Attomey's Office.
Third-Party Data-Sharing
Data from the Flock Safety ALPR may be shared with the following:
o District Attorney's Office for use as evidence to aid in prosecution, in
accordance with laws governing evidence;
. Public Defender's Office or criminal defense attorney via the District
Attorney's Office in accordance with California discovery laws;
o Local and state law enforcement offices as part of a specific criminal or
administrative investigation; and
o Parties to civil litigation, in response to a court order.
The City shall delegate any administrative account for the Flock Safety ALPR to the
Sheriff s Office and shall not have direct access to data collected and stored by the Flock
Safety ALPR. However, it shall be permissible to provide the City with City-owned data
produced by the Flock Safety ALPR, within any parameters set forth in the Board-
approved agreement between the Sheriff s Office and the City.
Additionally, it shall be permissible for ALPR data to be shared with law enforcement
agencies and County-retained investigative personnel to assist with the identification,
assessment, investigation, reporting, and prosecution of specific behavior or specific
activity that reasonably appears to be unauthorized, illegal, or in furtherance of illegal
activity.
Beginning as a two-year pilot program, the Sheriff s Office will be permitted to operate an
active ALPR data sharing program that enables active ALPR system data sharing with state
and local law enforcement agencies in compliance with state and federal law. Under this
program, the Sheriff s Office will grant automated data sharing to another law enforcement
agency only after the outside agency signs a memorandum of understanding (MOU) that
outlines rules and restrictions for sharing. To ensure appropriate oversight of this program,
outside law enforcement agencies with a data sharing MOUs shall be required to provide a
law enforcement event number when running inquiries or searches to ALPR data collected
by the Sheriff s Office. The Sheriff s Office shall immediately revoke active data sharing
to any law enforcement agency that violates any active data sharing agreement or rule. The
8
Office of the Sheriff
Surveillance Use Policy - City of Cupertino
Automated License Plate Readers (ALPR)
Page 4 of 6 January 2025
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Sheriff s Office may reinstatethat law enforcement agency's participation once the law
enforcement agency has demonstrated appropriate corrective measures. I
Notwithstanding the parties identified above, no data shall be shared in a manner that
contradicts Board Policy 3.54 - Cooperation with U.S. Immigration and Customs
Enforcement. Additionally, to the extent required by Senate Bill 34 (codified as California
Civil Code section 1798.90.5 et seq.), Flock Safety ALPR data shall not be shared with
federal agencies or any state or local agency outside ofCalifornia.
9. Training
Training for the operation of the Flock Safety ALPR utilized by the Sheriff s Office shall
be provided to all Sheriff s Office personnel who manage or use ALPRs. All Sheriff s
Office employees who utilize ALPR Technology shall be provided a copy of this
Surveillance Use Policy.
10. Oversight
Sheriff s Administration shall ensure compliance with this Surveillance Use Policy
All access to and sharing of ALPR data obtained through the Flock ALPR System shall be
logged, and the Sheriff s Office shall maintain an audit trail of requested and accessed
information, including the purpose of the search. Periodic, random audits shall be
conducted by the Sheriff s Office on at least an annual basis. Audits shall ensure
compliance with this policy and all applicable laws and shall include:
o Date and time of access;
o ' Reason for accessingdata;
o Name of law enforcement agency accessing data;
o Activity executed, including any license plate numbers searched; and
o Incident number associated with the investigation.
Required yearly audit reports shall include the name of an agency(s) seeking ALPR data
for the purpose of a specific criminal or administrative investigation as well as the
frequency of such request. Information shall be presented in a manner that protects the
integrity of the request, information, and investigation. Additionally, the Sheriff s Office
shall cooperate with the County Privacy Office with occasional assurance reviews.
I The active ALPR data sharing pilot program shall automatically expire two years after the approval of this
Surveillance Use Policy. The program may only be extended upon further review and approval of the program by
the Board of Supervisors.
Office of the Sheriff
Surveillance Use Policy - City of Cupertino
Automated License Plate Readers (ALPR)
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It shall be permissible for audit reports to be shared with government agencies responsible
for the costs of those systems requesting more frequent audits, including the City with
respect to the Flock Safety ALPRs. Audit reports for the Flock Safety ALPRs shall be
provided to the Crty's City Manager within five (5) business days of completion or within
the time frame decided pursuant to other mutually agreed upon affangement. Audits shall
be in a format that maintains the confidentiality of the data.
Approved as to Form and Legality
, lt lzolz\
Sohayl
Deputy County Counsel
Office of the Sheriff
Surveillance Use Policy - City of Cupertino
Automated License Plate Readers (ALPR)
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