Search â–¸ Agenda item attachment
A communication transmitted from Yi-An Huang, City Manager, relative to Awaiting Report Item Number 25-53, regarding a request that the City Manager consult with relevant departments about the implications of deploying license plate readers and provide recommendations as to whether adjustments in plans for deployment should be made in light of changes since approval in February
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Yi-An Huang
City Manager
Christine Elow
Police Commissioner
To:
City Manager, Yi-An Huang
From:
Police Commissioner, Christine Elow
Date:
October 20, 2025
Ref.:
AR #25-53
This memorandum has been prepared in response to Awaiting Report 2025 #53 which inquired into the
implications of deploying license plate readers and provide recommendations as to whether adjustments in
plans for deployment should be made considering changes since approval in February.
The Cambridge Police Department has reviewed the City Council’s order regarding the deployment of
Automatic License Plate Readers (ALPRs) and the potential implications considering recent federal
immigration enforcement activity.
The Department is deeply committed to public safety, transparency, and maintaining the trust of our
community. We fully recognize and share the City Council’s concerns regarding data privacy, the misuse of
surveillance technology, and the importance of ensuring Cambridge remains a welcoming and safe city for
all residents—regardless of immigration status or other legally protected activities.
Although the technology was originally approved before the most recent updates to the City’s Welcoming
Ordinance, our ALPR policy was developed in alignment with those updated protections as well as with the
Commonwealth’s Shield Law. Our implementation framework was deliberately designed to ensure that
ALPR technology is not used to support or assist in any immigration enforcement efforts or in investigations
related to activities that are legally protected in Massachusetts, including reproductive or gender-affirming
care.
The intended use of ALPR technology is solely for legitimate public safety purposes—such as locating
stolen vehicles, investigating violent crimes, identifying vehicles connected to missing persons, and
improving traffic safety.
A comprehensive review is currently underway with relevant City departments to assess the legal,
operational, and community implications of ALPR deployment. This review will specifically focus on the
following areas:
Data Privacy and Security
•
Flock Group Inc. performs an annual SOC 2 Type 2 audit. The purpose of this audit is to ensure
that the Flock Safety Solution System has the proper organizational and system controls in place
and practices such controls to ensure relevant security, availability and confidentiality. This audit
also verifies that employee access to sensitive systems and data is appropriately restricted and
monitored in alignment with security best practices. In review of their most recent audit, which
covers February 16, 2024, to February 15, 2025, there were no exceptions noted. The audit is
conducted by Moss Adams, which is a reputable firm in the accounting industry.
ADDRESS ALL COMMUNICATIONS TO
125 SIXTH STREET, CAMBRIDGE, MASSACHUSETTS 02142
•
The Public Safety IT Team has deliberately not implemented single sign-on for the Flock Safety
Solution System; by doing this the system is isolated from our network and facilitates limiting user
access. It is also important to note that there are no data feeds to or from the Flock Safety Solution
System for any of the systems in the public safety network.
•
The City of Cambridge owns all data collected by the ALPR system. Section 4.1 of our contract
(Customer Data) explicitly states that all data is retained solely by the City.
•
Flock’s role is limited to providing technical services. It has no ownership of or open access to
Cambridge data. Any use of anonymized, non-identifiable information (Section 4.3) is limited to
improving system functionality, such as identifying new vehicle models.
•
The Cambridge Police Department does not share data with external agencies, including federal
immigration enforcement, except when legally required through a subpoena or court order. Flock is
required to notify the City if such a request is made.
•
The Department has activated restrictive administrative settings that prohibit access to data related
to immigration enforcement, gender-affirming care, and reproductive health care.
•
Data may be shared only with the Office of the District Attorney for court-mandated discovery in
criminal cases or through proper legal process (e.g., subpoena, warrant, or court order).
•
Requests from external agencies (e.g., for a missing person, Amber or Silver Alert, or stolen
vehicle) are reviewed on a case-by-case basis, with consideration of legal authority and community
impact.
Community Impact and Transparency
•
Quarterly audits will regularly assess data accuracy and policy compliance.
•
Public transparency reports will summarize audit outcomes, including data access, sharing
instances with the reason, and policy adherence.
•
All ALPR data access is fully logged, with metadata tracking user identity, date, time, and purpose.
•
The Department will host community information sessions and public forums to explain how the
system works, how data is protected, and how privacy safeguards are enforced.
Policy Oversight and Governance
•
The ALPR policy will be updated to reflect community feedback, changes in law, or evolving best
practices.
•
Access to ALPR data is strictly limited to authorized personnel with role-based permissions.
•
All data is encrypted, stored securely, and automatically deleted after 30 days if not actively used in
an authorized investigation. After 30 days, the data is not retrievable.
Contractual and Operational Review
•
Law Dept -The City and Police Department are reviewing contractual terms with Flock to ensure
continued alignment with the City’s Welcoming Ordinance and community values.
The Cambridge Police Department appreciates the City Council’s continued oversight and partnership in
ensuring that public safety tools are deployed responsibly, ethically, and transparently. Our shared goal
remains to enhance safety, protect victims, and uphold the privacy and rights of everyone in our community.
Respectfully,
Christine Elow
Police Commissioner