At a glance
- Status
- Documented timing gap; governing rules for 2023–2025 unresolved
- System operating since
- 2023 (contract March 3; installation June)
- Formal policy dated
- October 6, 2025 (Policy 428, DOC-000475)
- Detailed procedure
- December 19, 2025 — marked “DRAFT” (Procedure 417, DOC-000474)
- Gap in the record
- Roughly two years and four months
- Conclusion strength
- Documented dates — not proof that safeguards were absent
Key quotations
“ALPR system audits should be conducted on a regular basis.”
“Failure to adhere to the policies and procedures pertaining to any of our ALPR systems shall result in disciplinary action, up to and including termination.”
“Additional guidelines will be codified in departmental policy.”
View original record(06_Police_Department_Communications.pdf, PDF p. 34)
Timeline
November 23, 2022
While Prescott police were evaluating Flock, a commander at Cottonwood Police Department forwarded his city’s council work-session presentation on its own LPR project. One slide says additional guidelines “will be codified in departmental policy.” These are a neighboring agency’s slides, circulated inside Prescott PD as reference material.
View original record(06_Police_Department_Communications.pdf, PDF pp. 33–34)
March 3, 2023
Prescott executed City Contract No. 2023-151 for 16 fixed ALPR cameras on a test-and-evaluation basis.
View original record(01_Contracts_and_Amendments.pdf, PDF pp. 10–12)
June 2023
Installation records show a technician onsite, with Flock reporting all but three locations installed by June 16. The system was operating.
View original record(10_Installation_and_Maintenance_2023.pdf, June 2023 installation thread)
October 6, 2025
The formal ALPR policy in the supplied records — Policy 428 — carries this date. It limits use to legitimate law enforcement business, requires department-approved training before access, logs access by name, date, and time, and says system audits “should” be conducted regularly.
December 19, 2025
A more detailed procedure — Procedure 417 — sets out the specific safeguards: a documented reason for each search, the searcher’s badge or employee number, a Department Report or CAD incident number, discipline up to termination for misuse, quarterly supervisor review of hot-list entries, and monthly official audits of custom hot lists. Every page of it is stamped “DRAFT.”
Issues & possible violations
How to read the labels
- Documented fact
- Directly stated or shown in a primary record.
- Supported inference
- A conclusion reasonably supported by multiple records.
- Unresolved
- Requires missing records, audit work, or legal interpretation.
- Not established
- An allegation the available evidence does not prove.
A. The cameras were operating more than two years before the supplied policy is dated
#Evidence: The contract was executed March 3, 2023 and installation records place cameras in service that June. The formal ALPR policy the City supplied is dated October 6, 2025.
Argument: Written rules that arrive after a surveillance system is already running cannot have governed its first two years of operation. Whatever did govern that period is not in the policy records the City produced.
Status: Documented fact — the dates are on the face of the records.
Original evidence: View original record(01_Contracts_and_Amendments.pdf, PDF pp. 10–12) View original record(14_Policies.pdf, PDF pp. 4–5)
Evidence: Procedure 417 — the document containing the case-number requirement, the documented search reason, the sanctions provision, and the monthly hot-list audits — is dated December 19, 2025 and carries a “DRAFT” marking on each of its pages.
Argument: The provisions that would make ALPR searches individually attributable and auditable are exactly the ones that had not been adopted. Policy 428 by itself says audits “should” happen; it does not require a case number or a written reason for a search.
Status: Documented fact. Whether the draft has since been adopted is not shown in the supplied records.
Original evidence: View original record(14_Policies.pdf, PDF pp. 9–11)
Argument: The City may have had earlier policies, state-law constraints, or vendor system controls in force. None appear in the policy file produced, and a records production is not necessarily complete. Closing this requires the City to identify the rules in effect during that period.
Status: Unresolved — requires records the City has not supplied.
Original evidence: View original record(14_Policies.pdf, PDF pp. 4–5)
Evidence: Policy 428 requires department-approved training before access and says audits “should” be conducted regularly. The draft procedure would add monthly hot-list audits and quarterly supervisor review.
Argument: A safeguard on paper and a safeguard in practice are different things. The supplied records contain no audit results, no training completion records, and no disciplinary findings either way.
Status: Unresolved — no audit, training, or discipline records were produced.
Original evidence: View original record(14_Policies.pdf, PDF p. 5) View original record(14_Policies.pdf, PDF p. 11)
Argument: The timing gap is a governance question, not evidence of misuse. No record in this production identifies an improper search, a missed audit, or any disciplinary matter. Treating the gap as proof of misconduct would go well beyond what these documents support.
Status: Not established — and not asserted here.
Original evidence: View original record(14_Policies.pdf, PDF pp. 4–5)
Unanswered questions
- What binding rules governed ALPR searches from 2023 through October 2025?
- Were users required to enter a case number and a documented reason for each search before the December 2025 draft?
- Were the audits described in Policy 428 and the draft procedure actually conducted, and are the results available?
- Were any inappropriate searches identified, and what discipline followed?
- Was department-approved training completed before users were given access to the system?
Evidence
Every quotation and material claim above links to the exact page of the full original public record. The complete source documents:
- 01_Contracts_and_Amendments.pdf — PDF, 224 pages · record detail & provenance
- 06_Police_Department_Communications.pdf — PDF, 121 pages · record detail & provenance
- 10_Installation_and_Maintenance_2023.pdf — PDF, 1406 pages · record detail & provenance
- 14_Policies.pdf — PDF, 11 pages · record detail & provenance