AUTOMATED LICENSE PLATE RECOGNITION POLICY
This policy governs the Automated License Plate Recognition System (ALPR system or system) in operation at the University of Southern California’s (USC or the university),and applies to Department of Public Safety (DPS) personnel and others who have access to or use the system.
WHAT IS AUTOMATED LICENSE PLATE RECOGNITION
Automated License Plate Recognition (ALPR or LPR) captures and stores digital images of license plates using mobile and fixed cameras at various locations on and around the USC University Park and Health Sciences campuses. ALPR uses character recognition algorithms to read and convert images of license plates and the charactersthey contain into computer-readable data maintained in a searchable computerized database. The information contained in the database includes images of license plates, the date, time and location when the images were collected, as well as the license plate characters and numbers associated with the image.
PURPOSE
ALPR identifies vehicles on and around USC’s campuses, including vehicles that enter USC parking lots and parking structures, for the purpose of improving access control, enforcement of USC parking policies, and enhancing the security and safety of the USC community.
PRIVACY POLICY
The policy of DPS is to utilize ALPR technology to capture and store digital license plate data and images to aid in DPS’ mission of creating a safe and secure environment for the USC community and the public at large, while recognizing the established privacy rights of the public. The images stored in the system are collected from areas visible to the public where there is no reasonable expectation of privacy. All data and images gathered by ALPR are for DPS use only and will be managed with appropriate safeguards to ensure proper access and maintain confidentiality in accordance with USC’s privacy policy.
For more information on USC’s privacy policy please visit: https://policy.usc.edu/data-privacy-policy/.
AUTHORIZED PERSONNEL AND TRAINING
The Director of Support Services Bureau (a division of DPS) will be the custodian and head administrator of the ALPR systems and its operation. The only persons who have access and ability to query ALPR data in the system are:
(a) The DPS Chief and Assistant Chief of Public Safety
(b) The Support Services Bureau Director
(c) DPS Surveillance Operations Monitors, Supervisors and Managers
(d) DPS Detectives
(e) IT personnel responsible for supporting and assisting DPS with the ALPR system
(f) Other trained persons designated by DPS
All DPS personnel with access to ALPR data will receive training, overseen by the Support Services Bureau Director or their designee, on the proper use and handling of ALPR data prior to being granted access. Such training includes system access safeguards, system use, collecting system data, privacy, and restrictions on the sharing of data. This ALPR policy shall be reviewed by all DPS personnel with access to the system on an annual basis. No DPS personnel shall be given a username or password to access ALPR data without being trained and having read the ALPR policy.
MONITORING
To track the use of ALPR data and identify if data has been accessed by unauthorized individuals, all logins and queries will be stored and monitored including:
(a)The username of the person who accessed the information.
(b)The date and time ALPR data is accessed.
(c)The IP address from which the ALPR data is accessed.
(d)The license plate number or other data elements used to query the system.
(e)The purpose for accessing the information.
The Support Services Bureau Director or their designee will run periodic audits to ensure access was made by authorized persons for legitimate business purposes.
DATA COLLECTION, RETENTION, STORAGE AND PURGING
The Support Services Bureau Director or their designee is responsible for ensuring security systems and processes are in place for the proper collection and retention of ALPR data. Data will be transferred to the designated storage in accordance with DPSprocedures.
All ALPR data downloaded to the server will be stored in accordance with the department’s established records retention schedule (currently one year) and will thereafter be automatically purged unless it has become, or it is reasonable to believe it will become, evidence in a criminal or civil action, is involved in a citation, or is subject to a discovery request or other lawful action to produce records. In those circumstances,the applicable data may be downloaded from the server onto portable media and stored at DPS.
The Support Services Bureau Director or their designee will be in charge of data collection, retention, storage and purging, so as to assure security and privacy protections at all times.
SALE, SHARING OR TRANFERS OF ALPR DATA
ALPR data will not be sold, published or exchanged for commercial reasons, nor disseminated to unauthorized persons.
ALPR data may be shared only with law enforcement or prosecutorial agencies for official law enforcement purposes or as otherwise permitted by law.
ALPR data may be shared with Title IX university investigators, USC Human Resources, or senior members of USC’s administration in connection with official university investigations.
Any other requests for ALPR data will require a subpoena through the USC Office of the General Counsel.
ACCURACY OF ALPR DATA
The collection of ALPR data is electronically automated so the license plate images anddetails of collection are included in the system without review. Although infrequent,license plate translation may be incomplete or inaccurate. The Support Services Bureau Director, who is in charge of system oversight, or their designee will ensure accuracy and correct license plate translation errors when identified. DPS personnel will also confirm the computer translation prior to taking any action based on ALPR results. 407470.2
