California State University San Bernardino
Automated License Plate Recognition Usage and Privacy Policy
Purpose and Scope
The purpose of this policy is to provide guidance for the capture, storage and use of digital data obtained through the use of Automated License Plate Recognition (ALPR) technology. This policy ensures that the access, use, sharing and dissemination of ALPR information is consistent with respect for individuals’ privacy and civil liberties. This policy applies to all persons authorized by the University to operate, configure, manage and/or administer ALPR systems and related equipment and information.
ALPR - What is it:
Automated License Plate Recognition (ALPR or LPR) captures and stores digital images of vehicles and license plates and utilizes character recognition algorithms to identify and store plate characters. The system creates a searchable computerized database resulting from mobile and/or fixed stationary cameras. ALPR system data includes license plate numbers along with date, time and location associated to the images that were collected.
“ALPR information” means information or data collected through the use of an ALPR System.
ALPR Access:
The Director of Parking and Transportation Services (PATS) or designee will be the custodian and head administrator of the ALPR system and its operation. The ALPR System is to be utilized solely by CSUSB’S Public Safety Team – access will be limited to Parking & Transportation Services Bargaining Unit Employees and Parking Managers who have been properly trained in its use. No PATS employee may access the ALPR data/system unless otherwise authorized to do so.
Training:
ALPR operators and those who have access to ALPR data will receive initial mandatory training from approved ALPR vendors. Training will consist of system procedure, proper use, and system security. ALPR users and operators will receive annual refresher training from the Director or designee.
ALPR Data Collection and Retention:
ALPR captures an image of the vehicle’s license plate and generates an alphanumeric version of the license plate number which is also stored with the record and used to determine the vehicle’s parking permission. While no owner or driver information is stored or collected directly by the LPR system, vehicle LPR data is linked to individual patron parking accounts within the parking management system. The specific data captured includes: -
- Vehicle license plate image
- License plate number
- License plate state
- Time
- Date
- Location
ALPR data (scanned license plates) will be purged no longer than 365 days of storage UNLESS a citation was issued, there exists an open appeal case for a citation and/or a law enforcement ongoing investigation linked to the specific license plate.
Use of ALPR Data:
ALPR shall only be used by CSUSB’s Public Safety Department for official parking management, enforcement operations and police investigations as required by law. The information will not be used to track employee attendance or used for corrective or disciplinary action or performance evaluation. The PATS Department members shall not use or allow others to use the equipment or database records for any unauthorized purpose.
- No member of the department shall operate ALPR equipment or access ALPR data without first completing department-approved training.
- No ALPR operator may access ALPR data unless otherwise authorized to do so and solely for the purpose of parking management.
Quality Assurance:
Capturing of ALPR data is automated and therefore the license plate images, and the details of the information collected will be imputed into the system without review. However, prior to taking any action based on the ALPR data system authorized users will confirm the accuracy of the computer translation. The following will be observed to safeguard the access and use of the ALPR data.
- All ALPR data processed by the mobile workstation and in storage shall be accessible only through a login/password-protected system capable of documenting all access of information by name, date and time.
- Users approved to access ALPR data under these guidelines are permitted to access the data for legitimate parking management purposes only.
- All data transmission and storage will follow CSUSB Security guidelines based on the applicable data level.
- Security or data breaches shall be handled pursuant to CSUSB’s Information Security Program.
Releasing ALPR Data:
ALPR information gathered shall not be sold or transferred to any person or entity.
- ALPR information may be shared with law enforcement agencies as permitted by law and at the discretion of the agency. This information is not to be duplicated or transferred in any way and remains under the management and control of Parking & Transportation Services.
- ALPR information may only be shared or released to persons or entities as specifically authorized by this Policy, except as required by law.