SCOPE

 

This policy governs the use of automated license plate reader systems and information by the UC San Diego Police Department (UCSD PD) on any property owned, leased, or controlled by the University of California, San Diego.

 

POLICY SUMMARY

 

This policy governs the use of Automated License Plate Reader (ALPR) Systems by UCSD PD. This policy serves as the usage and privacy policy required by CA Civil Code §§ 1798.90.51 and 1798.90.53 to ensure that the collection, use, maintenance, sharing, and dissemination of ALPR Information is consistent with federal, state, and local law and local practices. 

 

DEFINITIONS

 

ALPR means ALPR System and Information collectively.

 

ALPR Information means information or data collected using an ALPR System.

 

ALPR System means a searchable computerized database resulting from the operation of one or more mobile or fixed cameras combined with computer algorithms to read and convert images of registration plates and the characters they contain into computer-readable data. 

 

Authorized Users means the individuals permitted to install, operate or search within the UCSD PD ALPR System.

 

Campus ALPR Authority is the UC San Diego campus official who authorizes and oversees the operation of ALPR Systems and use of ALPR Information. 

 

Major Change(s) are changes that could have an effect on the privacy of individuals or security or governance of ALPR Systems or Information, including but not limited to changes related to ownership, technology, incidents, modification of scope, uses of AI, laws and regulations, risk assessments, vulnerabilities, or material updates or shifts in technologies.

 

PD ALPR System(s) is/are the ALPR System(s) procured, used, or accessed by UCSD PD to assist with law enforcement and campus safety functions.

 

POLICY STATEMENT

 

UCSD PD may utilize PD ALPR Systems but only in accordance with the rules and procedures and for the purposes authorized in this policy.

 

I.       Authorized Users

 

Only Authorized Users may access PD ALPR Systems or Information; however, access is only authorized when required to perform the duties of the user’s university job. Accessing a PD ALPR System or Information without authorization is a violation of this policy.

 

The following are the Authorized Users of the UCSD PD ALPR System(s): 

A.     The Physical Security Program Unit;

B.     Dispatchers;

C.    Patrol Operations;

D.    Specialized Services Division;

E.       UCSD PD command; and

F.       Audit and Management Advisory Services (for compliance, auditing, or advisory purposes)

 

All Authorized Users (with the exception of AMAS personnel) must complete all applicable background checks and all required training prior to accessing any PD ALPR System or Information.

 

II.     Authorized Purposes

 

Authorized Users may use or access PD ALPR Systems or PD ALPR Information only for Authorized Purposes. The Authorized Purposes are:

 

A.     Investigations of crimes chargeable as felonies under California State law;

 

B.     Investigations of stalking, domestic or relationship violence, and restraining order violations;

 

C.    Identification and recovery of vehicles or license plates that are stolen or wanted, including motorized scooters and motorized bicycles;

 

D.    Investigations of traffic accidents that result in significant bodily injury, death, or significant damage to property and investigations of hit-and-runs;

 

E.     Aiding with missing persons cases including at-risk individuals and Amber and Silver Alerts; and

 

F.     Monitoring, servicing, and maintaining the ALPR System for performance, reliability, and functionality, as well as to assess compliance with this policy, or assisting with monitoring, servicing, maintaining, or assessing compliance.

 

Using, or allowing others to use, the PD ALPR System or PD ALPR Information, including equipment or database records, for a purpose that is not an Authorized Purpose is a violation of this policy.

 

III.    Training

Authorized Users of the UCSD PD ALPR System (other than AMAS) must acknowledge that they have read and understood this policy and must complete the following required trainings:

 

A.     Manufacturer training and certification on the ALPR System;

 

B.     UC San Diego Privacy 101 Workshop or Privacy @ UC San Diego training;

 

C.    Annual UC Cyber Security Training Certification; and

 

D.    International Association of Directors of Law Enforcement Standards and Training (IADLST) and California Peace Officer Standards and Training (CA POST) course certifications (if the user is a member of the police department).

 

IV.   Privacy and Security of UCSD PD ALPR System

 

Any installation of an ALPR System or new use of ALPR Information must undergo a privacy and security review by the Campus Privacy Office and the Office of Information Assurance, respectively, for Protection Level 4, as defined by BFB-IS-3: Electronic Information Security, prior to implementation and upon any Major Changes to the system, vendor, or processes for access. The Campus ALPR Authority must ensure that Authorized Users use administrative, operational, technical, and physical safeguards to protect ALPR information from unauthorized access, use, destruction, modification, or disclosure, including the following minimum safeguards:

 

A.     Administrative: Username and password protected access to the ALPR system. Monitoring and auditing usage of database and ALPR Information. Appropriate training and access controls.

 

B.     Physical: Secure storage of computers with access to ALPR Systems and Information.

 

C.    Technical: Encryption of ALPR information in transit and at rest.

 

V.     Sharing of ALPR Information

 

ALPR Information may not be disclosed to any person except as authorized by this policy. Unless expressly permitted by this policy, disclosure of ALPR Information is a violation of this policy.

 

ALPR Information may be disclosed to:

 

A.     Authorized Users for an Authorized Purpose.

 

B.     The Campus ALPR Authority for oversight and compliance.

 

C.    Audit Management and Advisory Services (AMAS) for oversight and compliance.

 

D.    The Office of Campus Counsel and UC Legal for oversight and compliance and in the event of potential, anticipated, or actual litigation.

 

E.     IT staff assigned to maintain the ALPR System for maintenance and operational support.

 

F.     California City, County, or State prosecutors in connection with a criminal investigation or prosecution initiated by UCSD PD.

 

G.    Other Law Enforcement Agencies, but only if the purpose of the disclosure is:

 

a.     To assist UCSD PD in its investigation of a crime chargeable as a felony under California State law; or

 

b.     In response to a formal request from a Law Enforcement Agency from the State of California or a political subdivision of the State of California or from another University of California campus for assistance in locating a missing or endangered person or in investigating a crime chargeable as a felony under California State law, but only if the request is on official departmental letterhead and includes (i) contact information for the officer making the request, (ii) a case number, (iii) a description of the missing person or the crime under investigation, and (iv) a statement why the information being requested from UCSD PD is necessary for the investigation.

 

Disclosure to Law Enforcement Agencies requires written approval from the Campus ALPR Authority.

 

UCSD PD ALPR Information shall not be shared, disseminated, or used for civil immigration enforcement purposes. No access to UCSD PD ALPR Information will be provided to federal immigration authorities unless compelled by a valid court order or judicial warrant.

 

UCSD PD ALPR Information may be aggregated, anonymized, and kept for traffic reporting and maintenance needs, provided that anonymization meets reasonable standards to prevent re-identification. Aggregated and anonymized information may be provided to the Vice Chancellor – Operations Management and Capital Programs, who may use such aggregated, anonymized information for campus planning and traffic-related purposes.

 

VI.   ALPR Information Requirements

 

A.     Except as required for Auditing and Oversight as described below, ALPR Information in the UCSD PD ALPR System will be retained for no more than 60 days, unless required for an active criminal investigation or to comply with a court order or other valid legal requirement. Aggregated, anonymized information is not subject to the 60-day retention limit.

 

B.     Accuracy of Data. UCSD PD ALPR data collection is automated such that license plate images and details of collection are included in the system without human review. Although infrequent, license plate translation may be incomplete or inaccurate. Before initiating an arrest or seeking a warrant based upon data collected by an ALPR system, a UCSD PD officer must first visually verify that the license plate characters and the state of issuance match the data reported by the ALPR System and also confirm that the physical description of the vehicle (make, model, color) aligns with the reported ALPR data.

 

RESPONSIBILITIES

 

I.      Implementation and Enforcement

The Vice Chancellor – Operations Management and Capital Programs (OMCP) is the Campus ALPR Authority and is responsible for implementing and enforcing this policy in accordance with California Civil Code 1798.90.5 et seq. The Vice Chancellor ­– OMCP may delegate the role of Campus ALPR Authority, but the role may not be further redelegated. The Campus ALPR Authority is responsible for establishing and implementing operating procedures for ALPR access and use consistent with this policy.

II.     Auditing and Oversight

 

A.     UCSD PD shall be responsible for storing and monitoring all logins and queries of the UCSD PD ALPR System, as required by CA Civil Code 1798.90.52. At a minimum, the following information must be maintained for every query of the ALPR system: username; the date and time of access, the purpose for the access; the license plate number or other data element(s) used to query the ALPR System; and the purpose for accessing the information. 

 

B.     UC San Diego departments with Authorized Users must conduct periodic monitoring to review access rules, logs, configuration, and to confirm active individual accounts. The Campus ALPR Authority or their designee shall periodically monitor querying activity via electronic logs to ensure searches are tied to the purposes authorized by this Policy. In addition, Audit and Management Advisory Service is authorized to inspect all ALPR Systems and ALPR Information and related records to ensure compliance with this policy, other university policies, and legal requirements.

 

III.    Record Retention

 

Audit Logs shall be retained for 5 years and then destroyed. Records pertaining to pending, foreseeable, or ongoing litigation, open investigations, ongoing audits, or other lawful requests for records shall not be destroyed until these actions have been completed or resolved. 

 

 

 

IV.   Contracting

 

The Procurement unit is responsible for ensuring that ALPR contracts comply with this Policy and that any vendor supplying services related to an ALPR System warrants that it will not utilize ALPR Information for its own purposes or provide ALPR Information to third parties. The Procurement unit will also require all vendors to promptly notify the university in the event APLR Information is disclosed to third parties, for example in the event of a data breach.

 

V.     Publication and Posting

 

A.     In accordance with CA Civil Code 1798.90.53, the Campus ALPR Authority will ensure that this policy is posted conspicuously on the UCSD PD web site that is accessible to the public.

 

B.     The Chief of UCSD PD is responsible for ensuring that a public notice is posted at the entrance(s) of any facility with fixed ALPR cameras associated with UCSD PD.

 

VI.   Violations

 

Sanctions for violations of this policy may include disciplinary action up to and including termination of employment in accordance with the applicable disciplinary procedure.

 

PROCEDURES

 

None

 

FORMS

 

None

 

RELATED INFORMATION

 

A.    https://police.ucsd.edu/resources/immigration.html

 

B.    https://undoc.universityofcalifornia.edu/

 

C.    CA Civil Code §§ 1798.90.5

 

D.    CA Civil Code §§ 1798.90.51

 

E.     CA Civil Code §§ 1798.90.53

 

F.     CA Civil Code §§ 1798.90.55

 

G.    CA Civil Code § 1798.29(g) (1) (F).

 

H.    University of California BFB-IS-3: Electronic Information Security

 

I.       University of California PPSM-21 Selection and Appointment

 

J.     UC Protection Level Classification Guide

 

K.    UC Institutional Information Disposal Standard

 

L.     UC San Diego Policy and Procedure Manual PPM 135-3 Network Security

 

M.    UC San Diego Policy and Procedure Manual PPM 545-5 Automated License Plate Reader Policy (Department of Transportation Services)

 

N.    UC Records Retention Schedule

 

 

FREQUENTLY ASKED QUESTIONS (FAQs)

 

1.     What are ALPRs?

 

An Automated License Plate Recognition (ALPR or LPR) system is a computer based, information gathering system that utilizes specially designed cameras to rapidly capture an image of a vehicle license plate and recognize the plate characters using optical character recognition technology in addition to make, model, color and speed data. This data can then be searched for in a database.

The ALPR System collects: License plate image capture, license plate number, license plate state, portions of the vehicle and surrounding areas within frame, and the location of the vehicle, date, and time the image was taken, as well as the make, model, color, and speed of the vehicle (“ALPR Information”).

 

2.     How does UCSD PD use ALPRs?

 

UC San Diego PD uses both mobile and fixed ALPR Systems, which capture and store digital images that include license plates in areas visible to the public and use character recognition algorithms to identify and store plate information. The system creates a searchable computerized database. 

UCSD PD utilizes ALPR technology to scan, detect, and identify license plate numbers which appear on a list of license plate numbers and letters that law enforcement agencies use to identify vehicles of interest (Hot Lists) and locating stolen vehicles. In capturing license plates, ALPR systems also capture images that can be used for criminal investigations. ALPR data is law enforcement information and will be used solely for law enforcement purposes. Any non-law enforcement usage of UCSD PD ALPR Information is strictly prohibited.

 

REVISION HISTORY

 

05/05/2026       This policy was originally issued.