Res 2017-077/establishing a Policy Regarding Mobile License Plate Recognition (MLPR) Data Privacy

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Policy Regarding Mobile License Plate Recognition (MLPR) Data Privacy Section 1. Purpose. The City of San Marcos utilizes Mobile License Plate Recognition hardware and software ("MLPR")for vehicle parking enforcement and law enforcement.The purpose of this Policy is to provide guidelines for the collection, retention and privacy of license plate recognition data. Section 2. Locations of license plate data collection. MLPR data is collected on public streets and parking lots owned or leased by the City.The City utilizes a number of mobile vehicle-mounted systems operated by trained personnel in parking locations throughout the municipality. Section 3. Data collected. The MLPR system captures two photos of observed vehicles: (1) a context photo of the vehicle and its immediate surroundings and (2)a photo of the license plate.Typically,these photos are taken from the rear of the vehicle, although there are occasions where a photo is taken from the front of a vehicle backed into a space or standing in a driving aisle.The photos are not of a resolution that allows identification of the vehicle occupants if they are present.Along with the photographic data, the system also records the global positioning system coordinates and date/time information of the observation. Further software processing of the license plate image generates an alphanumeric version of the license plate number that is also stored with the record. While no owner or driver information is stored directly with the MLPR record,vehicle MLPR data is linked to individual accounts within the parking management system. Section 4. Use of data.The intended use of data collected by the MLPR system is for parking enforcement and law enforcement investigations, and associated prosecutions. MLPR data is used to determine a vehicle's location and time of use of a given parking area and support the issuance of a parking citation if needed.The data is also used by the City of San Marcos Police Department in conducting ongoing criminal investigations and investigations of complaints. Any use by the City of the data for purposes outside of these stated purposes must be detailed and approved in writing by the City Manager. Section 5.Data retention.Data collected by the MLPR system not resulting in parking enforcement action or not part of an ongoing law enforcement investigation or prosecution is retained for 180 days. Data resulting in parking enforcement action is retained with the citation record according to established City data retention policies. Data associated with an ongoing law enforcement investigation or prosecution is retained until the investigation or prosecution is completed or as directed by investigators, prosecutors or courts. Section 6.Access to records. Access to records created and maintained by the MLPR system is restricted to trained City of San Marcos personnel performing their duties, and including a limited number of City law enforcement personnel.All personnel with access to the system use unique identifiers and passwords to access records and all login activity, record additions,and other activity is logged. Access to the system by others within the City organization is prohibited. Section 7. Public notification. The City of San Marcos will notify the public of its MLPR data collection activities and policies by posting of this policy on the City's website. 1