I wrote about Chatrie the day it dropped; I have since realized that my first thoughts have some gaps and flaws, but I believe its underlying ideas are correct: Chatrie is a “blockbuster,” as Kerr puts it; it will affect ALPR; and it will land on the side of privacy.

This post looks at Kerr’s analysis and the tests he distills from the court’s opinion, and tries to apply them to ALPR. I say “try,” not because I think I failed, but because, as an incoming 1L in early August, I am only nominally a law student, and definitely not a legal scholar. Some additional audacity will have to carry the work, or maybe the other way around.

With Schmidt v. Norfolk still pending at the Fourth Circuit, the only circuit holding on plate readers I was able to find was United States v. Porter, 170 F.4th 381 (5th Cir. Mar. 17, 2026). It predates Chatrie by three months, so we’re venturing out into some uncharted territory here.

Here Be Dragons.

Kerr’s three tests

Kerr flags three tests. He doesn’t name them, so I did. The first quote is the Court’s, the other two are Kerr’s summaries. (Section numbers refer to the draft; they may shift.)

1. The relationship test—§II(D): protection follows what “a user reasonably understands as his own.”
2. The nature test—§III(A): “the private nature of the information in the abstract—rather than where it is, who holds it, or how much was obtained” controls.
3. The capacity test—§II(C): “the capacity to easily obtain the whole of a person’s physical movements” is what makes accessing records a search.

The draft also flags the Court’s “novice user” choice when faced with Kerr’s “magic box” problem^[1] in §III(A), as well as the apparent scope problem should a court try to decide what is “ordinary use” of a cell phone.

The ownership question

Chatrie appears to rest in part on a largely presupposed notion that Chatrie’s location history data was his in some sense. If you were to assume that Google owns the location history data, Gorsuch’s concurrence^[2] would collapse in its entirety and the majority’s strongest analogies (the personal journal, records a user “reasonably understands as his own”) would weaken.^[3]

While an argument that “Google owns the software, therefore Google’s observation of a location is Google’s property” might appear strained here, it is available for data gathered on unwitting subjects by cameras and other sensors in the public sphere.

Taking Flock as an example, the government’s vendor observes a subject (not a user, like Google’s) and then creates a record using hardware and software owned and operated by that vendor. The vendor then stores the resulting record(s) on its servers.

The government has various arguments available to say it owns that record.^[4] If a court were to accept the argument the government owns the record, it could shift the posture of any ALPR case to the government querying its own records, making it less likely that any “search,” for purposes of the Fourth Amendment, occurred.

Even if a court accepted government ownership of the file, that has never been the dispositive factor. The carrier owned the CSLI in Carpenter, and the DEA owned the beeper in Karo.

If the record and the information about a person contained in the record were to be considered one and the same, government ownership could kill a Gorsuch-style property theory. But his theory is not the majority’s.

A secret database of public information

The tension shines through in the question Judge Abudu raised at the Slaybaugh oral argument: even if the information contained in Flock’s database was gathered in public, if Flock’s database is not public, why should the court treat it as public information?

The government had no real answer. The one it gave was grounded in Knotts and collection: each individual observation or collection was of something non-private (a car on a public road). It never addressed Carpenter and Chatrie’s post-collection frameworks dealing with the aggregate and the resulting search of aggregate data.

No user, only a subject

When applied to a vendor-operated, government-accessed ALPR model like Flock’s, Chatrie may already reveal some answers Kerr’s draft article tells lower courts to look for.

Most importantly: with ALPR, there is no user, only a subject. There is nobody who can consent, disclose, own, or control information.

That idea culls some of Chatrie’s open questions and transforms how the rest can be applied.

The tests that drop out

The third-party doctrine as a whole is not in play, because the subject never disclosed information to a third party — at most, you might argue the license plate requirement forces the subject to make disclosures to the government, which would weigh toward a “search,” not away from it. The Slaybaugh argument tracks this: in thirty-five minutes, neither side mentioned the third-party doctrine.

To the extent voluntary disclosure turns on whether records arise from “ordinary use” of a device (a cell phone in Chatrie, a car in an ALPR case): driving on a public road is the epitome of ordinary use of a car. Waiver-by-conduct is not plausible.

The relationship test drops out too: a “novice subject” may not even be aware that (ALPR) location data is being collected. Even for a subject who is fully aware of ALPR conceptually, whether the information is collected on any particular trip is unknown: the cameras are often inconspicuous by design, and the government typically does not disclose their locations.^[5] There can be no perceived ownership of records the subject doesn’t know exist.

While that answers the relationship test in the negative, the information is not left unprotected; Carpenter protected records that, as Chatrie put it, “most cell-phone users have no awareness of” and “would never try to retrieve.” Perhaps that means the test is generally unnecessary, but we don’t need to look at that here.

The deciding tests

The remaining two questions are about the nature of the information, and the government’s capacity to assemble the information into something revealing more than its constituent parts. The answers work in tandem, and, like a lithium-battery fire, cause the uncontrolled reaction Alito fears in his dissent. It’s wonderfully simple and destructive.

First, ALPR records are similar in substance to Google’s location history, but less avoidable (and so less voluntary) than either CSLI or location history: as Kerr’s draft notes, the defendants in Carpenter and Chatrie “could have just turned their phones off.” A subject can’t (legally) remove their license plate or turn off third-party cameras whenever they go out criming, having abortions, or visiting their therapists.

Control over the recording therefore also shapes the nature of the record. A Google user can pause or disable location history ahead of the trips he most wants kept private, like closing the blinds on the front window. An ALPR subject has no control over the recording and is compelled to display identifying information at all times.^[6]

Chatrie warned that even two hours of location data “allows officers to target one-off events of potential interest: a gun show, say, or a political rally.” A plate query against the same parking lot does the same work with less effort, and the subject, unlike the user, could not have kept that trip out of the database. If a sanitizable location history satisfies the nature test, an unsanitizable one must.

Second, the government has the capacity to easily assemble the information into something of a far more private nature. In Chatrie, a search occurred when the government accessed Chatrie’s location history; combining a location history with more information can hardly result in less private information being exposed.

Yet that’s what happens for Flock/ALPR data. The data is often accessed through Flock’s portal, or through RTCCs or fusion centers. These use the type of combining software that creates a more invasive record. Entering a license plate in software like FlockOS, Flock Nova,^[7] Fusus (now Axon’s), or Peregrine may bring up ALPR location history, the location of the vehicle on non-ALPR cameras, DMV records, criminal history information, previous 911 calls, OSINT, related drone and body cam footage, and so on.

The system queried spans databases and jurisdictions to deliver an ever-expanding aggregate of information of a highly private nature; its compiled result is not something anyone would ever expect to expose to the government through the act of driving on a public roadway. It is also exactly the “effortless” assembly of information required to satisfy the capacity test. And it answers Judge Abudu’s question from the other end: whatever the components were, the compiled result is not public.

Chatrie also distinguished Knotts because the beeper surveillance “was confined to public roads,” while “the movements that Location History reveals are not limited to public streets” (slip op. at 22). The government has already planted its flag there: its post-Chatrie supplemental authority letter in Slaybaugh leads with this passage, improperly reads footnote 10 as a safe harbor for “public-movements-only technology,”^[8] and adds that ALPR cameras don’t collect information a driver “reasonably views as his own.” But the flag doesn’t reach the queried system: the fusion aggregate of private-property cameras, 911 records, drone and body cam footage is no more confined to public streets than Location History was.

The government knows it’s on shaky ground; the same hastily-written letter tries a chiasmus: because a cell-phone user “is not to be viewed as sharing private information … which then can be freely passed on to the government,” a driver on public roads “is viewed as sharing public information which can be freely accessed by the government.” Sharing with whom? The third-party doctrine’s sharing applies to a counterparty who might turn the information over, but a driver never hands over his plate to a third party.

The last word of the government’s formulation was accessed. Not collected. (The defense’s reply letter engaged none of this.)

Downward decomposition

Kerr’s draft raises the classification problem with a public-camera hypothetical: a massive camera system can be decomposed into arbitrarily small pieces—one jurisdiction, one database, one camera, one photograph—and a single photograph does not seem sweeping. So at what point does the capacity exist? Are judges prepared to act, in Kerr’s words, as “the program designers who say exactly how much assembly and which querying capabilities” trigger the Fourth Amendment?

It’s the question Flock and the government love to ask, and, to an extent, it is the right question for Carpenter and the mosaic theory, where the quantum obtained decides the case. But asking what “make[s] the result sufficiently sweeping to trigger the Fourth Amendment” is patently the wrong question for Chatrie.

The question treats the unit of analysis as something a court must construct after the fact. But the government has already constructed the unit: it bought or contracted for cameras, pooled them into a shared database, possibly enriched it with other data, and then queried the pooled system. Chatrie’s reasoning attaches to the system as queried, not as it might hypothetically be sharded or decomposed. A general warrant is not saved by the observation that it could have been drafted narrower.

The Court said as much: the “sweep of the official invasion is not made less because the government, with the benefit of hindsight, can pinpoint exactly which few hours of movements it wants to review” (slip op. at 21).

Porter shows decomposition at work: the Fifth Circuit conceded that ALPR’s “historical record” lets police “travel back in time to retrace a person’s whereabouts,” then held there was no search because the system at issue was ten cameras in one Mississippi town providing “only periodic information.” The court ignored the system, measured its output, and disposed of the question based on the quality and quantity of the information obtained. Chatrie rejected that:

Still more fundamentally, we have never understood Fourth Amendment protections as kicking in only once an intrusion “goes too far.” … Where the Fourth Amendment applies, it applies—regardless of “the quality or quantity of information” the government obtains. … That approach makes all the more sense when, as with Location History, officials can select the time-limited set of materials they want from an all-encompassing database.

— Chatrie, slip op. at 20–21 (citations omitted)

The government’s Slaybaugh letter shows where the quantum argument lives now: it runs Porter’s “far less detailed log” point through footnote 10’s “less ‘comprehensive’ log” phrase — the government’s team of legal necromancers attempt to revive the mosaic method using the same opinion that killed it.

Slaybaugh shows that new problem in practice. The government asked the Eleventh Circuit to measure capacity jurisdiction by jurisdiction. It discussed two counties and a handful of cameras. But at argument, the government conceded “the query was actually much broader” than those counties.^[9]

Chatrie’s message is that whenever the government queries its RTCC systems and fusion centers, it doesn’t matter whether that query seeks a detailed, most intimate, history of a person’s every move from their birth through today, or whether it seeks one snapshot image from a particular camera at a particular time. What matters under Chatrie is the government’s effortless capacity to assemble information of a private nature “from an all-encompassing database.”

That means a warrant becomes the default for querying integrated surveillance systems, such as those in RTCCs and fusion centers today. It is not a defect in the argument; it is the “seismic waves” Alito’s dissent predicted, and exactly what we need to bring equilibrium^[10] to a world where the government has already built a secret “all-encompassing database” it can query at any time, in secret, for any reason, or no reason at all.

If the government wants effortless warrantless information, it can still have it, but it must decompose its systems ahead of time — not in court, after the fact.^[11] If querying ten cameras in one Mississippi town is not a search, the government can query a system that makes only information from ten cameras in one Mississippi town accessible. Or it can get a warrant.

At its core, Chatrie requires the Fourth Amendment to be evaluated at the point where the search happens, not at the point where the collection happens. It’s the “private database,” not the “public information” that matters now.

Monongalia County held a press-only session to clear up “misinformation.” Irmo titled its release “Setting the Record Straight.” Vernon Parish wanted to “stop the spreading of misinformation.” Louisiana, Missouri posted a point-by-point rebuttal of “misconceptions.” Mt. Sterling’s chief briefed his council to dispel “misinformation being spread on social media.” Pleasant Hill’s captain blamed vandalism partly on “a little misinformation.” Fresno’s chief came to a public forum to “clear up any misconceptions.” Kelso’s chief blamed “a considerable amount of misinformation.” The president of Rhode Island’s police chiefs’ association called the controversy “born from misconception” and the ACLU’s warnings “not based on fact.” Pea Ridge’s chief shut down his own program while attributing the opposition to “misunderstandings or misinformation.” Franklin, North Carolina — which has no Flock contract at all — had to issue a statement correcting false claims that it did.

A second group asked for regulation. Pickens County’s sheriff wants legislation with “real consequences for anyone who abuses that system.” Mt. Juliet’s chief said “I welcome strong legislation.” Greenville County’s sheriff, after firing two employees for misuse, predicted criminal penalties from his legislature by January.

Twenty agencies somehow converged on the same two talking points in three weeks.

Flock’s script

Flock distributes an ebook to its police customers titled How to Speak to City Councils About Public Safety Technology,^[1] built from a company webinar and staffed with named Flock personnel.^[2] Its conclusion is a chapter called “Own the Narrative Before Someone Else Does.” Chris Colwell, who runs product consulting and training at Flock,^[3] is quoted:

“This story is going to get told either way. The only question is whether you’re going to be the one telling it.”

The manual itself tells the story of what happened in July 2026.

Move the conversation from surveillance to governance

The ebook tells agencies not to debate whether ALPR is mass surveillance (“you’re not going to convince opponents that it’s not,” per Flock strategist Jamie Hudson) and instead to recite retention periods, access rules, and audit requirements.

That recitation is the entire content of the agencies’ “corrections” — see the appendix. Retention days, authorized-personnel-only access, audit trails, case-number requirements, in nearly identical order, from West Virginia to California to Kentucky.

Make accountability visible

The ebook promotes Flock’s Transparency Portal and Audit Assistance products as the way to “show safeguards rather than describe them.” Monongalia County’s sheriff performed the pitch almost verbatim: “Everything we have is right here. There’s not going to be any reason for anybody to send us a FOIA because it’s already on there.”

Of course, as we know, there is plenty left to FOIA.

Argue budgets with local outcomes

The manual: recovered vehicles, missing persons, arrest counts. July: Mt. Juliet’s 342 arrests, Fresno’s claim that the cameras helped solve 70% of the city’s murders, Irmo’s hypothetical abducted child, Mt. Sterling’s rescued dementia patient.

Forget about the national character of the system, and that if you vote to fund this in Maine, you’re also funding access to your city’s streets for cops in Wyoming. Never look past the end of your nose.

The agency owns the data

Flock’s Max Weinstein, in the ebook: “Flock does not own data, period.” Monongalia County: “the county owns the images.” Fresno: shared only with California agencies, never with federal immigration authorities. Mt. Sterling: allegations the department would sell the data are “simply false.”

Only “access to data” is being sold, which is totally different. Apparently.

The audit as alibi

The playbook’s cleverest move centers on audits.

The internal audit

When an audit finds nothing, the system works. Burke County’s sheriff announced July 30 that a six-month audit found no misuse, proof of “strict accountability through regular audits” — a genre with precedent. Pickens County: “audits have shown no misuse to date.” Alabaster, Alabama: “the combination of department policy, training, user accountability, the audit capabilities and the supervisory oversight that we do have safeguards and promotes appropriate use of the system.” Grand Traverse County’s sheriff, asked about oversight of a system 1,400 agencies can query, said his detective captain audits it twice a year: “if there were an attempt on something nefarious, it would be identified immediately.”

When an audit finds misuse, the system also works. Savannah PD put six employees on leave July 31 for searches involving “personal acquaintances and family members” — misuse “discovered through its auditing and oversight processes as part of the Flock Safety Audit Assistance Program,” per the department, which answered the scandal by adding weekly audits. Richmond County, Georgia arrested four of its own deputies after “a routine audit.” Greenville County fired two employees and called it accountability. Greer’s terminations came from Flock’s own “AI Audit Assistance tool.”

Flock itself issued a July 23 press release titled “Flock’s Audit Assistance Tool Identifies Misuse Across Multiple Cases, Reinforcing That Accountability Is Built into the Technology” — the sequel to a July 8 release announcing five officers arrested in Albany, Georgia. Every audit outcome is a press release, and every press release says the oversight is adequate.

The base rate says otherwise. By July 31, Georgia alone had arrested at least 20 officials for misusing Flock data. And the audit trail itself got less public the moment the public used it: Flock began anonymizing released audit data after “activists” (hello!) used it to identify officers by name. Milwaukee alderperson Marina Demitrijevic said the quiet part back in March: “It must be independently audited. We cannot police ourselves.”

The external audit

Better still, we have collected a few audit logs at haveibeenflocked.com — so let’s check. Burke County conducted a “successful audit,” finding no misuse. The logs show searches for vague reasons like “law enforcement”, “investigation”, “LEO”, “incident”, and “test” — vagueness the FBI itself recommends. 97.4% of searches have no associated case number. 14.6% of searches have a reason consisting of 3 characters or fewer. One plate was looked up 100+ times over 70 days. That same user looked up several other plates dozens of times, over multiple months. Audit successful. Moving on.

Alabaster, whose oversight “promotes appropriate use” shows similar patterns. Users conducting dozens of searches of a single plate over multiple months, many searches requesting 30-day national location histories labeled simply “Traffic infraction,” and reasons such as “susp person” and many, many “test” searches. Promoted. Appropriate. Next!

In Birmingham, where every search “is logged and subject to audit”, roughly 1,400 searches run against the live, national network are labeled “training,” “test,” or “practice”. Similar to the Illinois cop who used “test” to cover up stalking. Here too we see users follow the same plate for months on end. It’s fine, we’re logging it.

In Grand Traverse, where anything nefarious “would be identified immediately”, 73.8% of searches lack a case number. Most searches have an offense code and nothing else. If anything is entered into the field, it’s something like “atl”, “3500”, “training”, or “test”. Who knows how anyone can identify anything from this. And again, we have users tracking single plates for months on end. Identified. Next.

Vernon Parish, whose policies “ensure accountability”, lets its users enter “qq” to support a search. Not occasionally: “Other - qq” is the single most common reason in the logs — 3,263 of the 6,000 most recent searches, or 54%. The written-policy control the sheriff cited is, in majority practice, two letters typed with one hand. And here too, one user searched a single plate 121 times over 139 days. Accountability ensured.

In Monongalia County, where every search “requires an active case number”, the case numbers as well as the reasons show “test”. Requirement met.

This is how these agencies are succeeding at audits, and why they will always succeed at audits, no matter the guardrails, no matter the abuse.

Regulation, brought to you by the regulated

The chiefs asking for legislation sound brave until you hear the vendor asking first. On July 27, Flock’s CEO Garrett Langley posted a video to the company’s YouTube account:

“We push states, communities, and cities to adopt regulation. This is a technology that needs to be regulated. … Until every state passes an ALPR regulation, we’re not done.”

Flock wants ALPR statutes, and its customer agencies now publicly want them too. The appeal is not mysterious. A statute standardizes the product’s legal footing, replaces the patchwork of local fights (and local bans) with a single negotiable text, and relocates blame for scandals onto individual bad actors. And, of course, we can reduce the transparency while we’re at it, now that we’re required by statute to have successful audits. It’s a win-win, as long as you’re not the person under surveillance.

Greenville’s sheriff made the relocation explicit: “The Flock camera’s not doing anything wrong. It was the person who went in there and looked up the data when they shouldn’t have.” Penalties for abusers are the regulation a surveillance vendor can love: they concede the system will be abused and keep the system.

“Line!”

Two agencies show what the script for the play looks like when the actor skips the substance. Kelso and Pea Ridge both invoked “misinformation” but offered no corrections at all — no retention figures, no audit counts, only the word. The vocabulary has decoupled from content. That is what a playbook looks like from the outside: blank faces repeating blank phrases.

Flock’s manual warns agencies that “if you do not tell the story of your program, someone else will.”

Here, the logs speak for themselves.

Appendix A: the log

July 15: Irmo Police Department (SC)

Speaker: Police Chief Bobby Dale

The town published a statement titled “Setting the Record Straight” as it expanded from 11 to 33 cameras, correcting the record on what the cameras do.

“If a child is abducted, a violent criminal flees our town, or a family is desperately waiting for answers after a loved one goes missing, I never want to look them in the eye and say, ‘We could have used technology that might have helped, but we chose not to.’”

Lexington Ledger, July 15

July 18: Monongalia County Sheriff’s Department (WV)

Speakers: Sheriff Todd Forbes; Mark Ralston, Law Enforcement Administrator

The department held a press-only informational session explicitly framed as clearing “misinformation” about its Flock cameras.

“Everything we have is right here. There’s not going to be any reason for anybody to send us a FOIA because it’s already on there.” — Sheriff Forbes

“We don’t make arrests just because this thing tells us, period. It all has to be verified.” — Ralston

The Dominion Post, July 18; WAJR, July 16

July 20: Pickens County Sheriff’s Office (SC)

Speaker: Sheriff Tommy Blankenship

Addressing privacy concerns, Blankenship defended his program but explicitly called for legislation — including consequences for abusers.

“I support legislation that clearly defines when systems like Flock are to be used, who can access them, how long the information can be retained, mandatory audits, transparency, and reasonable limits on the number of cameras that can be placed in a single area. And real consequences for anyone who abuses that system.”

“We should not just take tools from deputies and punish our victims by abolishing our Flock program because of the misuse or overuse of Flock in another jurisdiction or other states.”

“My pledge to you is that if at any time I am made aware of factual evidence that our federal government is misusing our cameras to infringe on the rights of innocent citizens, I’ll cut them down myself and destroy them.”

Fox Carolina, July 20; Spectrum News, July 20

July 20: Richmond County Sheriff’s Office (GA)

Speaker: Office statements

Announced the arrests of three more of its own employees (after a first on June 26) for searching plates “for reasons unrelated to official law enforcement duties,” found via “a routine audit.” All four were charged and terminated. The office declined to say whether policy changes or additional safeguards would follow.

WJBF

July 23: Vernon Parish Sheriff’s Office (LA)

Speaker: Sheriff Sam Craft

Issued an in-depth statement, framed as an effort “to educate the public and stop the spreading of misinformation on the use of the technology.”

“Camera placement complies with applicable state law and relevant court decisions governing the use of technology in public spaces.”

“Access to LPR data is strictly limited to authorized personnel for legitimate law enforcement purposes. The system operates under departmental policies governing data access, retention, auditing, and appropriate use to ensure accountability.”

KJAS, July 23

July 23: Pleasant Hill Police Department (IA)

Speaker: Capt. Amy Kramer

After a Flock camera on Northeast 23rd Avenue was cut down ($7,000 in damage), Kramer attributed part of the backlash to bad information, citing incidents cataloged on DeFlock.

“I know there is a lot of controversy over cameras of this nature in general. Part of it, I think, is a little misinformation. These cameras don’t track people or follow people around.”

KCCI, July 23

July 24: Mt. Juliet Police Department (TN)

Speaker: Police Chief Tyler Chandler

Responding to Rep. Tim Burchett’s call to “ban these dadgum things,” Chandler rebutted:

“The use of automated license plate reader technology is not inherently unconstitutional.”

“Claims that ALPR technology automatically violates the Fourth Amendment are not supported by current federal case law.”

“I welcome strong legislation that ensures law enforcement across our State and Nation use license plate readers responsibly with clear policies, limited access, auditing, and a continued commitment to protecting the privacy, civil rights, and civil liberties of the public.”

On what current federal case law actually says, see the Chatrie decision and ALPR.

Fox17 Nashville, July 24

July 24: Grand Traverse County Sheriff’s Office (MI)

Speaker: Sheriff Michael Shea

Defended internal-only auditing of a system that 1,400+ agencies nationwide can query: twice-yearly audits conducted by the office’s own detective captain.

“The audits [of the Flock searches] are done by our detective captain. That report is forwarded to me. It’s done on a regular basis, so that if there were an attempt on something nefarious, it would be identified immediately.”

“We are trusting the captain to uphold public trust and do things appropriately. I think there is a level of confidence that we have to put in that individual.”

Interlochen Public Radio, July 24

July 25: Kelso Police Department (WA)

Speaker: Police Chief Rich Fletcher

Announced new Flock installations while attributing community fear to “a considerable amount of misinformation,” saying inaccurate information had fueled “unnecessary fear, misunderstandings about Fourth Amendment protections.”

“I believe our community deserves accurate information so residents can make informed judgments based on facts rather than assumptions.”

KIRO 7, July 25

July 26: Greenville County Sheriff’s Office (SC)

Speaker: Sheriff Hobart Lewis

After firing two employees for Flock misuse, Lewis pointed to coming legislation criminalizing abuse — framed as prediction more than advocacy, but supportive in tone.

“I think in January, you’ll see the legislator going forward, much like other parts of the country, enact some legislation that if you misuse this information, you can be charged criminally.”

“The Flock camera’s not doing anything wrong. It was the person who went in there and looked up the data when they shouldn’t have.”

Fox Carolina, July 26

July 27: Pea Ridge Police Department (AR)

Speaker: Police Chief Lynn Hahn

Ended the city’s Flock program under public pressure, while insisting the criticism rested on bad information.

“Many of the concerns raised about the city’s use of Flock are based on misunderstandings or misinformation.”

The decision should not be “interpreted as a belief that the technology is ineffective or that Pea Ridge police officers misused the system.”

Little Rock Public Radio, July 27

July 27: Louisiana Police Department (MO)

Speaker: Department Facebook post (no individual named)

Posted a point-by-point statement on Facebook to “clear up misconceptions” circulating about the city’s seven cameras — including a rumor that it had 14.

“These are automated license-plate readers, not traditional live-surveillance cameras.”

“They do not use facial recognition or collect biometric information.”

KHQA, July 27

July 27: Flock Safety (the vendor itself)

Speaker: CEO Garrett Langley, video posted to Flock’s YouTube account

Narrated the company’s three priorities: privacy, security, and legislation.

“We push states, communities, and cities to adopt regulation. This is a technology that needs to be regulated. It is the most impactful technology to be built for criminal justice and public safety. That deserves regulation. … Until every state passes an ALPR regulation, we’re not done.”

Flock Safety on YouTube, July 27

July 28: Town of Franklin (NC)

Speaker: Town officials

The inversion case: Franklin has no Flock contract and no plans for one, and issued a statement correcting false social-media claims that it did — while warning that “communicating threats could result in criminal charges.” Neighboring Macon County had voted unanimously to remove its 12 cameras.

WLOS, July 28

July 28–31: Alabaster and Birmingham Police Departments (AL)

Speakers: Department statements; Deputy Chief Rodarius Mauldin (Birmingham)

As Flock misuse cases renewed debate in Alabama, both departments assured the public existing oversight suffices.

“We believe the combination of department policy, training, user accountability, the audit capabilities and the supervisory oversight that we do have safeguards and promotes appropriate use of the system.” — Alabaster PD

“Every search is logged and subject to audit to ensure accountability and prevent misuse.” — Birmingham PD

ABC 33/40, July 28; Yellowhammer News, July 31

July 30: Burke County Sheriff’s Office (GA)

Speaker: Office statement (no individual named)

Announced the completion of a six-month audit finding no misuse by any agency member — while reporting $7,000 in vandalism damage to cameras across the county.

“The Flock camera system is an important public safety tool that helps law enforcement investigate crimes, locate stolen vehicles, and identify suspects while maintaining strict accountability through regular audits.”

“This successful audit demonstrates our continued commitment to transparency, responsible use of technology, and protecting the privacy of our community.”

WRDW, July 30; WJBF, July 30

July 30: Fresno Police Department (CA)

Speaker: Police Chief Mindy Casto

At a public forum on the city’s 70 Flock cameras, Casto framed her appearance as fact-correction.

“I just want to make sure I have an opportunity to get some facts out… to try to clear up any misconceptions.”

KVPR, July 30; YourCentralValley/CBS47

July 30: Rhode Island Police Chiefs’ Association / Barrington PD (RI)

Speaker: Chief Michael Correia, RIPCA president

After South Kingstown’s council voted July 27 to drop Flock (following hundreds of opposition letters), Correia — whose own town has no Flock cameras — called the ACLU’s warning “not based on fact” and the controversy “born from misconception.”

“There’s this misconception that this is just a free-for-all, and it’s anything but a free-for-all. It is closely monitored, audited, to make sure it’s not abused, because it is a powerful tool.”

“The data that’s collected and only held for 30 days is not an intrusion. It’s not an unreasonable search or seizure. You have no expectation of privacy when you register your car and drive down the roadway.”

WPRI

July 31: Savannah Police Department (GA)

Speaker: Chief Lenny B. Gunther; department statement

Placed six employees on leave for searches “unrelated to law enforcement purposes, including searches involving personal acquaintances and family members”; one allegedly gave an outside agency access. The department stressed the misuse was “discovered through its auditing and oversight processes as part of the Flock Safety Audit Assistance Program,” noted every search is logged, and added weekly audits.

“Misuse of law enforcement tools and technology by SPD staff will not be tolerated. The public places tremendous trust in us, and that trust must be earned every day.”

WJCL, July 31

July 31 (meeting July 21): Mt. Sterling Police Department (KY)

Speaker: Police Chief Aaron Noel

Briefed the city council “to dispel some of the misinformation being spread on social media”: 30-day retention, plates only, no facial recognition, no access to Social Security or bank data, and the claim the department would sell the data is “simply false.” Citizens, he added, have no right to privacy on public roadways.

Mt. Sterling Advocate, July 31

Near the window

• Sherwood PD (AR) — KATV, July 2: Capt. Scott Hicks, “it’s not used to track people… our cameras do not use facial recognition, they do not use biometrics”; THV11 later covered the city defending the cameras from “social media misinformation” on July 27.
• Rutherford County Sheriff’s Office (NC) — July 8, after a vandalized camera drew 20,000+ comments on the agency’s own post: “We’re seeing a lot of misconceptions that these cameras collect more data than they actually do.” (WLOS)

Appendix B: the “correct” information

What the agencies offered as fact:

Irmo PD (SC)

• Cameras capture rear vehicle images and license plates only; no facial recognition; not designed to identify drivers or passengers.
• Positioned primarily at major entry/exit points of town; expanded from 11 to 33 cameras.
• Investigative tools, not continuous monitoring; used for stolen vehicles, missing persons, kidnappings, violent offenses, burglaries.
• Do not track daily movements of law-abiding citizens.

Monongalia County Sheriff’s Department (WV)

• Cameras capture only license plate text, vehicle attributes, date/time, and camera location; no driver photos, no names, addresses, phone numbers, driver ID, or race data.
• Retention is 21 days, recently reduced from 30 in light of a pending Virginia court ruling.
• The county owns the images; Flock stores them, has “no contracts with any federal agencies and does not resell data.”
• System is CJIS-certified for NCIC access; searches require an active case number; every entry creates a permanent audit trail; access audited every 90 days.
• No arrests made on an alert alone; “It all has to be verified.”

Pickens County Sheriff’s Office (SC)

• Cameras record make, model, color, and plate of passing vehicles; data deleted after 30 days.
• 81 personnel have access, six with admin rights; all searches require a stated reason and are cataloged for review.
• ~4,700 searches year-to-date; ~330 custom watch lists for active investigations; alerts must be corroborated before acting.
• Audits have shown no misuse to date.

Vernon Parish Sheriff’s Office (LA)

• LPRs capture plates and vehicle characteristics visible from public roadways, plus direction of travel.
• Do NOT identify drivers or passengers, use facial recognition, or monitor cellular devices in vehicles.
• Access strictly limited to authorized personnel; departmental policies govern access, retention, auditing.
• Placement approved by Louisiana DOTD and State Police; complies with state law and court decisions.

Pleasant Hill PD (IA)

• Cameras “don’t track people or follow people around.”
• Replacement cost of the destroyed camera: about $7,000, paid by the city.

Mt. Juliet PD (TN)

• ALPR use is “not inherently unconstitutional”; claims it automatically violates the Fourth Amendment “are not supported by current federal case law.”
• Program has run since 2020 with, per the chief, the strictest data retention policies in Tennessee; 342 arrests in the first half of 2026.

Grand Traverse County Sheriff’s Office (MI)

• Searches audited twice yearly, internally, by the detective captain; report goes to the sheriff.
• No instances of abuse reported locally; 1,400+ agencies nationwide have access to the county’s data.

Greenville County Sheriff’s Office (SC)

• The misuse was the employees’, not the system’s: “The Flock camera’s not doing anything wrong.”
• Data survives vandalism: “Even if you tear the camera up, the information is stored.”

Louisiana PD (MO)

• Seven cameras, not 14 as rumored; still images only, no live feeds monitored.
• No facial recognition or biometric collection; not speed or red-light cameras.
• Access restricted to authorized law enforcement; data auto-deleted after 30 days unless preserved as evidence.
• Past 30 days: 54,389 unique vehicles captured, 16 search sessions; top use was hit-and-run/accident investigation. City council knew of the program for at least 7 months.

Town of Franklin (NC)

• Has no contract with Flock or any similar ALPR system, and no plans to purchase one.

Alabaster and Birmingham PD (AL)

• Alabaster: policy, training, user accountability, audit capabilities, and supervisory oversight together “promote appropriate use.”
• Birmingham: every search must be tied to a specific offense; users trained before access; searches audited every 30 days; “every search is logged and subject to audit.”

Burke County Sheriff’s Office (GA)

• Six-month audit found no instances of misuse by any agency member.
• Cameras vandalized across the county at a cost of $7,000; a felony investigation is underway.

Fresno PD (CA)

• 70 fixed cameras in high-crime areas; 30-day retention.
• Data shared only with California agencies under written agreements; no sharing with federal immigration authorities.
• Cameras helped solve 70% of the city’s 2026 murders, per the chief.

Savannah PD (GA)

• Every Flock search is recorded: user, date, time, and stated reason.
• The misuse was caught by the department’s own “auditing and oversight processes as part of the Flock Safety Audit Assistance Program”; weekly audits by the Office of Professional Standards added.

Mt. Sterling PD (KY)

• Video stored 30 days; cameras “not used for surveillance or spying on individuals”; capture license plates only.
• No facial recognition; no access to Social Security or bank account information; no images from inside vehicles.
• Claims the department will sell collected data are “simply false.”
• Officers and outside agencies must give a reason for access; violators face discipline; outside agencies that break protocol can be cut off.
• No right to privacy on public roadways; cameras funded with drug forfeiture money.

RIPCA / Barrington PD (RI)

• ALPR use in Rhode Island is “closely monitored, audited”; access limited mostly to investigators with a specific log-in; “you can’t just go on and start looking around.”
• 30-day retention “is not an intrusion”; no expectation of privacy on public roadways.

Kelso PD (WA) and Pea Ridge PD (AR)

Both invoked “misinformation” without specifying corrections — Fletcher offered only the program’s purpose (prevent/solve crime, recover stolen vehicles, locate missing persons); Hahn cited stolen-vehicle recoveries and suspect identifications but no operational specifics.

Bishop Fox’s offensive security experts will engage in complex, multistage and multilayer adversarial testing across all of Flock’s products, both hardware and software. The results and any ensuing updates will be communicated transparently to reinforce confidence in Flock’s strong security posture. — Flock Safety Engages Bishop Fox to Set the Industry Standard in Cybersecurity for its Public Safety Platform, Flock via GlobeNewswire, Feb 2, 2026

That February 2026 press release followed signifiicant bad press after a series of vulnerabilities had been discovered:

• In November 2025, Jon “GainSec” Gaines published a report with 51 security findings (22 assigned CVEs).
• That same month, Benn Jordan published the video “We Hacked Flock Safety Cameras in under 30 Seconds. 🫥”
• A month later, Jordan and 404 Media published “This Flock Camera Leak is like Netflix For Stalkers,” showing Flock PTZ cameras were completely unsecured and accessible on the Internet.
• Then, in January 2026, Nexanet.ai published “53 Times Flock Safety Hardcoded the Password for America’s Surveillance Infrastructure,” an incident which revealed “license plate detections, patrol car locations, drone telemetry, body camera locations, 911 call data, and surveillance camera locations from approximately 12,000 law enforcement, community, and private sector deployments nationwide.”

Despite having been independently validated and assigned CVEs (including severity 9.8, CVE-2025-59407), Flock’s response has been — and continues to be — a combination of outright denial and deflection.

To any critical observer, it was obvious from the outset that the security audit by Bishop Fox was never going to work, and that the engagement was little more than a PR stunt. Flock even said as much when saying the goal wasn’t to improve its security but “to reinforce confidence” in it.

In a March 27, 2026, blog post (archive), Flock already quietly downgraded the Bishop Fox engagement from the “complex, multistage and multilayer adversarial testing across all of Flock’s products, both hardware and software” from the month before to a “regular annual penetration test.”^[1]

Two months later, Flock’s CISO, Chris Castaldo, obliquely referenced outside audits in a YouTube video where he said, “[t]he really important thing when it comes to saying you’re secure — or your product is secure — is someone other than you doing that analysis.” He did not mention Bishop Fox — or anyone else — was conducting such an audit for Flock. Seems like something one might mention in a promotional video about security.

Another two months later — in July 2026, six months after the Bishop Fox announcement — Flock published a YouTube short where CEO Garrett Langley says: “We partnered with Bishop Fox months ago to start running an internal audit of how we can strengthen our security posture. We will continue to work with them for the years to come. Continuing to harden and protect this valuable technology.”^[2]

Flock’s CVE entries have not been updated since late 2025, meaning the same vulnerabilities still exist across tens of thousands of cameras deployed nationwide, and used to support warrants and as evidence in criminal trials. There is no telling how many people have been arrested or convicted because of evidence sourced from Flock’s insecure system. According to Flock, it’s many.

In the span of six months, Flock went from announcing a complex across-the-board red-team exercise, where findings would be “communicated transparently” to an “internal audit” that appears to be nothing more than the minimum pentest required for SOC.2 compliance. Its “public safety” hardware and software is as insecure as it was six months ago.

While Langley and Castaldo are publishing YouTube videos minimizing the issues and reframing the Bishop Fox engagement, Flock sales won’t answer questions about the whole ordeal because you can’t believe what you hear on YouTube. Maybe they have a point.

By executing this Order Form, Customer represents and warrants that it has read and agrees all of the terms and conditions contained in the Terms of Service located at https://www.flocksafety.com/terms-and-conditions and the Prepared911 Terms and Conditions, available at https://www.prepared911.com/prepared-live-terms-and-conditions.

That’s the language at the bottom of the “Order Form” for FlockOS 911 customers.

In February 2024, Flock announced FlockOS 911 in partnership with Prepared — legal name Invictus Apps, Inc. By all accounts, FlockOS 911 is a rebranded version of Invictus’ product: Prepared911. That product is an AI-integration to transcribe and translate emergency calls in real-time; it also allows police and others to listen in live, through FlockOS on their computers or mobile devices. Their own term for it is “assistive intelligence.”

About a year and a half later, Prepared911 was acquired by Axon, one of Flock’s biggest competitors in the LPR space. As part of that acquisition, Axon also acquired the website at https://www.prepared911.com/prepared-live-terms-and-conditions … you can see where this is going.

The effectiveness

Whether the terms that live on the website are binding is somewhat questionable. In addition to being a website that can be unilaterally modified, the terms only apply to agreements between Invictus (now Axon) and its customer:

…shall apply to and govern any Order placed by a Client (as identified in such Order) for a subscription to the Prepared™ Communications Service from Invictus Apps, Inc., a Delaware corporation, (‘Invictus’), to which these Standard Terms are attached or in which they are specifically referenced and which is signed by both Invictus and the Client.

But apply they must, because this agreement is the only “guardrail” ostensibly keeping 911 caller data secure.

Whether the terms apply is further complicated by there being at least three, probably four, versions. (Version 6 was authored three months after the FlockOS 911 launch, so whatever version was posted at launch was an earlier one nobody appears to have preserved.) Based on announcements, PDF metadata, website asset identifiers, and Wayback Machine captures:^[1]

@Axon/Prepared911 terms v6.0 @Axon/Prepared911 terms v7.0 @Axon/Prepared911 terms v8.0

Versions 6 and 7 name Invictus; version 8 names Axon.

Between version 6 and 7, the precedence of the agreements flipped. Version 6 says the order prevails:

In the event of any conflict or inconsistency between the Order and these Standard Terms or any Appendix or Exhibit to the Order to these Standard Terms, the terms and conditions of the Order shall prevail. — v6 §17.3

Versions 7 and 8 say the standard terms prevail (sort of — the grammar is broken):

In the event of any conflict or inconsistency between the Order and these Standard Terms or any Appendix or Exhibit to the Order to these Standard Terms shall prevail. — v7/v8 §17.3

Whatever controls, Invictus/Axon reserves the right to unilaterally modify the terms that Flock’s customer agrees to on the FlockOS 911 order form:

Invictus[/Axon] reserves the right to change these Standard Terms at any time by posting changed terms on the Invictus website. Any changes made to these Standard Terms will apply to the Agreement between Invictus and Client for any Order received by Invictus from Client before the changes are made. — v6–8 §17.15

The data

Which terms apply is, of course, largely irrelevant to anyone but lawyers, and they’re getting paid to figure that out. Those of us under surveillance 24/7 would ask the more important question: “what about our 911 calls and our data?” That’s where the deal gets even worse.

Start with what the terms call “Caller Data” — that’s you, when you call 911:

“Caller Data” shall mean (i) the data, including text, video, audio, image, and location data, regardless of form or media, that are submitted or transmitted by a Caller or Caller’s Mobile Device…

Who owns it? Not you. Not your police department, either:

All right, title and interest in and to the Caller Platform Extensions and the Prepared Platform and all Caller Data shall remain with Axon and its licensors. — v8 §6.2

Axon claims outright ownership of your 911 call. The agency that answered it gets a license back — “personal, non-exclusive, nontransferable” — to view its own residents’ emergencies (§6.1(b)).

Then there’s “Client Data” — the agency’s side of the system: user accounts, the caller phone numbers dispatchers enter, the messages they send. For that, the agency grants Axon this:

Client hereby grants to [Invictus/Axon] and its subcontractors and their respective successors and assigns, a royalty-free, fully-paid, non-exclusive, perpetual, irrevocable, fully sublicensable and transferable worldwide right and license to use, host, store, view, perform, copy, reproduce, modify and create derivative works of any Client Data submitted or otherwise made available by Client solely for purposes of (i) providing and performing the Service and otherwise performing this Agreement … and (iii) researching, developing, and improving the Service and the Caller Platform Extension and the Prepared Platform and other products and services of [Invictus/Axon] and its affiliates. — §6.5

After the acquisition, “affiliates” means the Axon product family. A perpetual, irrevocable license — granted to “successors and assigns,” so it survives the sale — to use agency data to improve the products of the company Flock competes with.

And in version 7 (the same revision that flipped the precedence clause) the definition of Client Data was quietly extended:

(iv) the data, including text and audio, that are transmitted between Responders and Telecommunicators and made available to [Invictus/Axon] during the Term of this Agreement, including any data resulting from the transcription, translation, synthesis or interpretation of that data.

Prepared edited its website to include dispatcher-to-responder audio, and the AI transcriptions of it, into the perpetual license.

Your caller data

But don’t worry:

The Axon Privacy Policy available at https://www.prepared911.com/privacy-policy describes how Axon will handle any personal information included in the Client Data

That’s the policy that presumably applies to you and me, should we call 911.

“At Prepared, privacy is more than just a priority \– it is a core value that drives everything we do.”

As of today, July 29, 2026, the “Axon privacy policy” at that address is dated May 2024. Aside from a banner announcing that “Prepared is now part of Axon 911,” the policy itself has not been touched: it still speaks for Invictus Apps, Inc. d/b/a Prepared, two owners ago.

That policy states that “sessions” — your 911 calls — may be used “for our business needs and purposes, including to make this service better; to identify other services we can provide to help before, during, and after emergencies.” Your emergency, their lead generation. As for how long they keep your information:

We will retain your Personal Information for 10 years as required by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) or as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies, whichever is shorter.

Ten years. For context: Apple requires emergency data deleted from dispatch centers within twelve hours, and Flock’s order forms promise a 30-day retention period on their face. Twelve hours, thirty days, or a decade — depending on which of three documents, maintained by three different companies, you choose to believe.

This Privacy Policy may be changed or updated from time to time. By visiting PREPARED at one of our websites or using one of our apps or services, you accept the practices described in this Privacy Policy.

Apparently, also by having a medical emergency.

Phones and medical data

If you call 911 from an iPhone, you can opt in to sending your Medical ID — conditions, medications, allergies, emergency contacts — along automatically with the call. Android phones send precise location through a parallel Google service, which can also carry “additional emergency information” from apps on the device; what that includes is spelled out only in Google partner documentation that isn’t public.

Apple and Google do not release this data to just anyone: it goes only to a provider your local 911 agency has expressly authorized, and Apple, at least, publishes strict conditions on how that data is used after it is received: deletion within hours, no logging, no analytics, no derived data.^[2]

Those conditions set a ceiling, but Axon’s terms are drafted to claim everything beneath it, wherever it moves. For Apple data, the agency pre-authorizes “[a]ll data retention and analytics services … permitted by Apple”. If Apple ever permits more, Axon — through Invictus, through Flock, through your local government — is automatically granted more. For Google data, the terms don’t even name a ceiling. And Axon’s privacy policy behind the next hyperlink already claims the right to use live 911 “sessions” for the company’s “business needs and purposes.”

Guardrails

This is what is supposed to pass for “guardrails” and “contractual safeguards.”

Flock, police agencies, city councils, and city attorneys across the country have represented that they read and agreed to the terms on prepared911.com — the unilateral-modification clause, the garbled precedence clause, the vendor’s claim of ownership over 911 caller data, and the standing authorizations to receive medical data from Apple and Google. And they kept doing it after the acquisition, still referring to the same website.

The only alternative is that nobody actually read the terms, or believes they will apply or keep the data — your 911 calls — where they’re supposed to be. In that version, Flock and Axon are running wild, unconstrained by contracts or guardrails.

Ultimately, it is irrelevant which version applies, or who claims to “own” your emergency: the guardrails are meaningless, and Axon, which has already openly feuded with Flock, can now unilaterally modify the terms between its competitor, Flock, and its competitor’s customers.

Meanwhile, the only things standing between your 911 call and “business needs and purposes” are a webpage Axon can rewrite tomorrow, and Apple’s goodwill. All in the name of public safety.

We also found that more than 3 out of 4 Flock agencies assist neighboring departments at least monthly, with 1 in 5 doing so daily, extending the technology’s reach well beyond our own customer base.

This is side-door access: an agency with Flock logins runs searches for one without.

The side door

Flock’s website promises oversight: transparency portals list which agencies data is shared with, every search is logged, and data is shared only with approval. None of it matters when someone can pick up the phone, or type in a password, and use another agency’s login.

The side door also compounds. An agency that shares its cameras with a trusted partner also shares them with everyone that partner will run searches for. ICE has no Flock contract; 404 Media documented local police running plate lookups for it anyway. Cleveland let outside departments search its camera network, and audit logs showed nearly 2,000 immigration-related searches through that network in 2025, before the city blocked such searches in November. The logs don’t show whether federal officers asked for those lookups.

What that looks like in Iowa City

Iowa City, where I live, has banned police ALPRs since 2013. The University of Iowa Police Department (UIPD) is not subject to the ban; 29 Flock cameras are on university property across the city. UIPD’s log files suggest the Iowa City Police Department (ICPD) regularly runs queries through UIPD’s account, bypassing the ban. Some example UIPD search reasons: “Drugs/Narcotics - IC14 Narcotics Inv”, “Welfare Check - ICPD SUICIDE/LAW REF ATL”, “Motor Vehicle Theft/Stolen - ICPD STOLEN VEHICLE”.

The UIPD logs do not say who at ICPD requested a lookup, or whether any investigation was open. The University of Iowa couldn’t say either, if it tried to audit its own users. Flock’s promise that every query is logged is technically fulfilled and practically broken.

And this is the best case: UIPD at least recorded which agency it was searching on behalf of and under which offense category. Thousands of searches record only “assist”, or worse, “inv”.

This is what “local control,” “accountability,” and “data ownership” look like in practice: unnamed third parties with no Flock contract run queries through your local police department, with no adequate logging and no oversight. The official policy, meanwhile, presents unique logins and user authorizations as meaningful safeguards: they don’t apply to outside requesters.

These are the best guardrails Flock can offer. By Flock’s own count, more than three out of four surveyed customers step around them at least monthly, and one in five does so daily.

“The cameras don’t track vehicles”

@vFlock demo of real-time tracking

In the video, someone clicks a button labeled “START REAL-TIME ROUTING,” which shows the route a car traveled. The narrator explains that Condor cameras “help identify where vehicles are traveling in between our various Falcon cameras placed throughout the community.”

The distinction Flock makes is that these are Condor (pan-tilt-zoom) cameras, not Falcon (license plate reader, or LPR) cameras. The LPR detects the plate. The Condor spots the same car by some other characteristic. The video does not say whether it works with third-party (“Wing”) cameras, while the marketing material says “various data sources.”^[2]

After all of the data is collected, FlockOS — software running in Flock’s cloud, not on the camera — puts all of it together to track the car from point A to point B, and through the rest of the alphabet.

To call it misinformation, Flock leans on a non-existent distinction between “FlockOS analyzes various data sources to determine where a suspect vehicle has been and its direction of travel” and its shorthand, “the camera tracks people.”

“It takes a picture of a car”

That same day, Flock CEO Garrett Langley had a similar message when responding to the LAPD suspending its use of Flock’s cameras, following a critical inspector general’s report:

@vGarrett Langley video

If people would understand what the technology actually does \— not what it might do in fifty years, not what someone thinks it could do, but what it actually does, day in and day out \— it takes a picture of a car. Most people go, “this makes a lot of sense. I want my kids to be safe.”

“External radar”

The (apparent) current model of Flock’s LPR camera has a small module attached to the bottom:

The module is labeled “external radar,” but its purpose is unclear. Flock has never said.

The FCC keeps public records on any device that emits radio signals (such as radar). Such devices are required to be labeled, but there is no FCC identifier visible on the module. Flock registered an FCC grantee code (2BKG8) in August 2024. As of July 26, 2026, no applications are listed under it, for the radar module or any other device.

The apparent FCC violation itself is problematic, but more relevant here is that the public can’t get any information. The entry for an Apple AirTag, by comparison, shows the device was tested by a third party to ensure its radio signal doesn’t cause harmful interference, e.g., on public safety communications frequencies. For Flock’s module: zero results. The company placed an unknown number of them, likely in the tens of thousands, at unknown locations, and we have no idea what they do, let alone if they do it without interfering with anything else.

Assuming the label is telling the truth about this being a radar module, it seems unlikely (but entirely possible) that it’s being used to determine vehicle speeds. mmWave radar is often used for real-time 3D object mapping; it’s used in self-driving cars and on “smart highways.”^[3]

Two things are clear: radar is not required to “take a picture of a car,” and we have no way of knowing what this module does.

“Dossier of that person’s entire life”

The similarity between the Flock CEO’s message and the Pleasant Hill, Iowa, police department’s message is not a coincidence. Flock helps its customers stay on-message through webinars, glossy ebooks, and, of course, sales reps and blog posts.

@v"Build a digital trail"

In the video, a Flock rep tells the audience he’s “even heard some reporters refer to it in a way that on the left side of the screen, there’s a picture of a license plate, and the right side of the screen has a dossier of that person’s entire life. As we all know, who use the technology, that’s just not true.”

Cut to an excerpt from another webinar, this one about Flock Nova; on the main screen: “Step 1: Build a digital trail with LPR and enriched case data” alongside the heatmap Flock says doesn’t exist.

The strenuous distinction here is that the LPR itself does not show the dossier; the Flock Nova software does. Nova can combine Flock LPR with all sorts of other data sources. According to the “Step 1” slide, it can “surface accomplice vehicles and movement patterns … with AI-enabled LPR” and it can “use AI to connect case data across CAD/RMS” (dispatch and records systems).

In his hypothetical human trafficking investigation, the presenter says Nova will pull in bodycam footage from previous police encounters to see if someone might be associated with “females who are underdressed for the weather.”

Flock also built “AI analysts” into the product to identify patterns and conduct investigations:

@vFlock presentation on Night Shift AI

Langley told the ABC7 crew people shouldn’t worry about what the system might do one day, but Night Shift, Flock promised on stage in 2025, will get even better in the future: “soon, you will be able to build your own agent … you can share those agents within your own agencies, or even across agencies, in the same way you share camera access today, or a custom hotlist.”

A license for music and videos

In Costa Mesa, CA, the city council went back and forth for a while on a specific contractual clause. The clause defines content a customer might “post” or “upload” through Flock’s products, language you would expect in a social network’s terms of service, not a police camera contract. The clause discussed involved a definition similar to this one, from Dunwoody, GA’s contract^[4]:

Flock may provide Customer with the opportunity to post, upload, display, publish, distribute, transmit, broadcast, or otherwise make available, messages, text, illustrations, files, images, graphics, photos, comments, sounds, music, videos, information, content, ratings, reviews, data, questions, suggestions, or other information or materials produced by Customer

After a few rounds, the city council, the city attorney, and the three of the department’s nine Flock administrators who were present all seemed confused. Flock did not send a representative. Costa Mesa decided it wanted the language removed from the contract.

@vCosta Mesa looking for Flock rep

The people in the room, including the three administrators who “use the technology” and were specifically selected to come in and defend the contract against five hours of public comment in opposition, did not seem to know that Flock’s hotlist tool has a comment section and a “Media” button:

Keep in mind that Costa Mesa had already signed this contract. The meeting was about whether it should be renegotiated. The Costa Mesa police department has used the system, “day in and day out,” for four years.

The contractual language was treated as misinformation regardless.

“A tough balance”

On X, Flock’s Chief Strategy Officer, Rahul Sidhu, defends Flock’s decision to redact critical audit log information in response to a question from a reporter:

Honest answer: transparency is split between what we share and what the agency shares. We can’t force the latter. We make it as easy as we possibly can for the agency to be transparent.

Ex: We share the employee IDs for the officers, but it’s up to the agency to share who those IDs belong to. This is a tough balance because we also don’t want to doxx the undercover officers, etc.

He attaches a screenshot saying, “the change followed complaints from roughly 200 law enforcement leaders that activists were using published audit data to identify undercover officers.”

This concern over “doxxing” is rooted in a belief that a secret police force is appropriate, not in a belief that all government officials, police included, are by definition accountable to the public. Identification for accountability purposes is the reason we have license plates to begin with, but it’s a bridge too far for police.^[5]

Meanwhile, access on the inside is wide open. Flock’s blog recently put the number of “monthly active users” above 140,000. There are no background checks. Multi-factor authentication is not required, users have been found sharing accounts, and stolen credentials have circulated on dark-web marketplaces; lawmakers have asked the FTC to investigate. Flock has defended all of that as local decisions.

It is a statistical certainty that some of those accounts are in hostile hands. Whoever holds them can see searches, camera footage, and people’s location histories (including cops’) in real time, no public records request required. All of it will look like it’s coming from yet another small town in northwestern Arkansas nobody has ever heard of, under reasons like “test” or “inv.”

Fighting misinformation

Flock’s claim is that asserting the company does anything beyond “taking pictures of a car” is “misinformation.” The company asks people to ignore the mysterious radar modules; the dossiers with 911 transcripts, LPR histories, CAD/RMS data, bodycam footage, and OSINT data; the AI combing through it all for patterns; the APIs; the account sharing; and the complete lack of security standards.

It’s true that many of those are technically different Flock products, not “LPR.” That is the problem. The backlash focuses on the cameras because the cameras are the only part of the system the public can see. The hardware inside them, and bolted onto them, is undocumented. The software behind them runs in Flock’s cloud, out of sight.

The onus is on the government to select vendors that can earn public trust. Part of that is providing complete and accurate information: not corporate talking points, and not a CEO going on TV to tell the public not to worry about the future because it’s only “pictures of cars” today.

Captain Kramer was probably right that misinformation contributed to the destruction of the camera. Misinformation grows where information is withheld. When a reporter requested information about Pleasant Hill’s Flock deployment last year, the response was that some of that information, like the locations and types of cameras, is “confidential.”^[6]

Whoever destroyed the camera couldn’t know whether it was the type that “takes a picture of a car” or some other type that might have a radar module. They couldn’t know who was watching from the other side. Neither can anyone else in Pleasant Hill.

That’s the arrangement offered: the public must take it on faith that every camera is benign, while the system logs every plate on the assumption that any of them may turn out to be involved in a crime. Trust is demanded in one direction and withheld in the other.

It’s a familiar play: in June 1775, with Boston under siege, British General Thomas Gage issued a proclamation explaining the unrest. The people were not aggrieved, it said. They were misled: “infatuated multitudes, who have long suffered themselves to be conducted by certain well known Incendiaries and Traitors.”^[7]

Gage claimed the press had printed “the grossest forgeries, calumnies and absurdities that ever insulted human understanding,” but offered nothing in refutation. Americans were not persuaded.

Criminal damage is very possible. A video by TikTok user @nbconstructon shows what can happen when lithium battery packs are punctured.^[1]

@v@nbconstructon video with battery pack

Assume the investigators are right: the batteries did not start these fires, and the hardware worked as designed. If a Flock camera did catch fire on its own, no one would find out. There is no reporting duty, no public failure data, no regulator collecting it, and no specification anyone checked before the poles went in the ground.

The debris

The news footage shows what is left on the pole. The solar panel is intact. Below it, a melted black mass hangs off the mounting hardware where an enclosure used to be. The pole is still standing. On the ground underneath is a blackened patch of right-of-way with cylindrical lithium cells scattered in the ash.^[2] The cells are cylindrical, so the packs contain small cells rather than a few large pouches. The fire burned at the mount, 12 feet up, and dropped into the grass.

The batteries

The older, bigger Falcon cameras have internal batteries and optional “penguin packs.” One teardown has the internal battery at about 205 Wh, and two variations of the penguin pack at roughly 216 Wh and 324 Wh. Permit specs cap the assembly at two external packs, so a fully loaded older Falcon could have about 850 Wh.^[3]

The newer models have a separate compute box (“picard”), mounted underneath the solar panel, with the batteries in their own enclosures. I am not aware of any teardowns done on it, but the weights are in FDOT permit drawings.^[4] Scaling from the older pack, two packs come to about 650–870 Wh.^[3:1] The total is about the same as the older model. The energy is just split across more enclosures.

Electrical code requires an energy storage system be listed — tested and certified as a system — above 1 kWh. Fire code provisions start at 20 kWh.^[5] A pole with two packs falls below both.

Scale

To put those numbers in perspective, a typical laptop battery is around 50–100 Wh. TSA and IATA do not allow spare batteries above 100 Wh on planes without airline approval.^[6] Some might remember the Galaxy Note 7, which was famously recalled and then banned from aircraft when its battery started catching fire — that was around 13.5 Wh. The 200–870 Wh of lithium in a Flock camera is significant. Think e-bike.

Even if the incident in Georgia was vandalism, there are still 120,000 black boxes with 200–870 Wh in lithium batteries each dotted across the country, baking in the summer sun on the side of the road. If we’re guessing about 30 lithium cells per camera, that works out to 3.6 million lithium cells, any of which could fail (because sometimes things just fail, even for companies that have good QA and don’t cut corners).

Test reports

Lithium batteries are tested, and test reports exist. Under 49 CFR §173.185(a)(3), the manufacturer and every distributor after it must make one available, but only “to an individual or entity in the supply chain upon request.” That includes Flock’s customers, but, presumably, not the public.^[7] Flock probably does not make the cells, but an assembled multi-cell pack is a battery in its own right, and needs its own test report separate from the cell report.

Heat

Cell manufacturers are specific about temperature. The 21700 cells commonly used in packs like these are rated to charge between 0 °C and 45 °C (32–113 °F). Storage is rated tighter: a year at room temperature, three months at 45 °C, one month at 60 °C.^[8] A solar-charged pack sits near full charge for much of its life, waiting for a cloudy week. Lithium cells encased in black plastic or metal, hanging 12 feet above the pavement on the side of a Georgia (or Arizona, or California) highway, will exceed those temperatures during much of the summer.^[9]

Exceeding those temperatures won’t cause the batteries to ignite. Runaway starts around 130 °C, and sunlight does not get a pack near that. It will degrade and weaken them and cause them to fail more easily. It increases the odds that a minor fault in one of ~3.6M cells throughout the country will cause a runaway reaction that will end up igniting the entire pack. Those odds are increased further when a pole is struck by a moving vehicle, breakaway pole or not. A slip base is designed to release, so the whole assembly comes down and can be crushed or abraded. At 3.6M units, even a 0.01% increase in failure rates is meaningful.

Permits

But that’s all speculation. Flock would call it misinformation, because some of my guesstimates won’t exactly match reality. The problem is that the real numbers are unavailable. They’re not submitted to cities or highway safety authorities (which are not great about safety to begin with). Flock doesn’t make test reports or spec sheets available to the public. And cities and regulators don’t appear to be asking — not even the ones in California or currently-burning Oregon.

The permit forms show it. Colorado DOT’s ALPR checklist asks for read-accuracy metrics, CJIS compliance, hotlist arrangements, retention and purge policies, removal plans, and liability insurance. Its only question about stored energy is one field: “Battery Back Up: ☐Yes ☐No.” Tennessee DOT’s application asks for an “[e]xplanation of how the ALPR camera(s) will be powered” and nothing else.

It’s not that state regulators are unaware of the danger — for solar lighting, Michigan DOT requires manufacturers to “[e]nsure the battery is United States Department of Transportation (USDOT) rated ‘non-spillable’, gel cell or absorbed glass mat (AGM) cell type and complies with IEC 61427,” and “[d]esign the system for an ambient temperature from -40 °F to 140 °F.” Gel and AGM are lead-acid, so the requirement keeps lithium-ion out of the right-of-way entirely. And 140 °F is 60 °C, above every lithium-ion charging limit there is. Lead-acid degrades at that temperature but does not run away. None of that applies to roadside surveillance cameras.

Even where permits do exist, Flock does not have a good history of building what’s in the permit. A 2025 Iowa DOT permit for the Fremont County Sheriff’s Office specifies a dedicated pole: 11 feet of 2½-inch standard pipe at 2⅞" outside diameter, an “X-SQUARED BREAKAWAY BASE WITH ROUND RECEIVER,” an “X-SQUARED SLIP BASE,” and a concrete foundation at least 3’-6" deep. It cites AASHTO LRFD for structural supports and tabulates base reactions for design wind speeds up to 135 mph. Flock bolted its camera to an existing traffic signal mast arm pole instead.^[10] Signal poles are rigid by design, because a support that releases on impact would drop signal heads into traffic.^[11]

The breakaway base and the slip base in that permit were never installed, because the pole they belong to was never installed. And, in a way that would have Franz Kafka fill out an application to roll over in his grave, Iowa DOT says it doesn’t perform as-built inspections, unless as-built differs from the permit. What batteries are hanging off that pole is anyone’s guess.

Tennessee shows the same gap from the other side. TDOT standard drawing T-S-23B requires a multi-directional slip base breakaway for pipe posts in the clear zone that are not shielded by a barrier. Steve Eimers, a safety advocate, found the installations and posted about them, and Flock replaced 16 poles in Tennessee. MaineDOT requires a waiver and an inspection for poles in state right-of-way, and has received no applications at all.

Flock’s account of it all is worth reading. CEO Garrett Langley wrote that the company had “kicked off a nationwide safety audit for all our poles, starting with Tennessee, where we fixed 16 separate installations.” Rahul Sidhu, Flock’s Chief Strategy Officer, put it more plainly: the advocate “found mistakes with our poles in TN (all fixed now) and we’re now doing a nationwide audit (with his advice). I expect he may find Flock poles with issues before we do, but we’ll fix those too!”

A company with 120,000 poles in the ground expects a private citizen to find its safety defects before it does, and is running its audit on that citizen’s advice. No DOT appears anywhere in that account, and how we got here — by years of drafting permits to safety standards so DOTs look the other way, while installers disregard what’s in the plans, putting the public at risk — is brushed off as a “mistake”.

The breakaway problem had a mandatory standard, crash test data, state regulators, and decades of precedent behind it. The years-long failure still had to go viral on TikTok before it was addressed. For the batteries, there aren’t even any rules to ignore.

Fire season

The Georgia fires stayed small — a scorched patch of shoulder and smoke in the pines. The TV crew did not film the aftermath at the other camera, at 2416 Radium Springs Rd, but Google Maps shows it was on a mowed shoulder with no brush or pine trees nearby. Not a placement requirement, but probably the safer way to do it.

But we’re increasingly seeing Flock (and other) cameras along remote trailheads in the Rockies and the PNW, deep in fire country. An e-bike worth of batteries sits 12 feet up on a pole, where physical defects would go unnoticed, installed without DOT inspection or any meaningful permit process. There is a real possibility a degraded battery can fail when struck by a car, when it’s assaulted by wildlife, or when it simply fails on its own due to statistics.

To make matters worse, Flock does not — to my knowledge — inform its customers when this type of failure happens. Previous articles on Riverside County illustrate the point almost too perfectly: 500+ cameras without a permit, many in the Colorado Desert and the Coachella Valley — an area with typical summer highs of 104–120 °F. Palm Springs even reached 124 °F on July 5, 2024.

When Riverside County cameras are damaged, Flock reps send an invoice and a notice — “We will need to replace the pole to ensure the location is functioning properly as soon as possible. Due to the damage being physical in nature, we will be sending an invoice for the damage”. The Sheriff appears more concerned about where to route the invoice than about whether anything caught on fire.

We’ll inevitably have these failures. That’s not even Flock’s fault, it’s just math, chemistry, and physics coming together. Many cells across many cameras, hotter, drier summers, less snow, and overall worse fire seasons. This year is one of them. The country is running about a third above its ten-year average for acres burned, and the national wildfire preparedness level reached its ceiling in the week of July 20, with record-low western snowpack as the cause.^[12]

Failure modes

None of this needs new science or new technology.

Standards can be written. Michigan DOT wrote one for the batteries in solar road lighting: a chemistry that does not create runaway reactions, a listed specification to comply with, and a temperature range to design for. Nobody has written one for the batteries in roadside surveillance cameras.

Standards that exist have to be followed. Tennessee has required a breakaway base for pipe posts in the clear zone for years. At least sixteen Flock installations did not have one, and nobody in the permitting chain noticed (or cared). An unpaid volunteer had to go viral for it to matter to anyone at Flock.

Permits can specify hardware. The Iowa permit specified a dedicated pole, a breakaway base, a slip base, and a 3’-6" foundation, with an engineer’s wind analysis behind it. Flock bolted the camera to a rigid signal pole instead. Iowa plainly admits it treats the permitted plan as the as-built and does not inspect — it does not appear to be alone in using that process.

Flock could disclose information and be transparent. It has test reports for its battery packs, because it can’t ship them without them. It hands them to customers who ask, if any, and nobody else. Flock likely also gets, or could get, reports from installers when cameras fail. If they are collected, they are kept behind lock and key at Flock HQ.

Cities, state DOTs, and contracts could each require any of the above. A permit condition, a bid requirement (if there is a bid), a line in a purchase order, a clause that says “tell us when one of these burns.” To my knowledge, none of Flock’s public safety customers have advocated for any of that.

That is five points of failure on one pole. Flock is not asking to be held to a standard. No regulator is writing one. No DOT is checking the work. No city is putting it in a contract. Nobody is doing the job, and the only people who are finding these flaws and calling them out don’t even work for Flock or any government.

To the company selling “public safety” and the agencies buying it, the phrase begins and ends at policing. It does not include the 4,000+ acre Springs Fire forcing residents from their Moreno Valley homes, or the Bain Fire upending people in Riverside and Jurupa Valley.

These hazards should be removed until Flock, the DOT, and cities get their act together.

Because safety is our fundamental right.

Josett’s queries had targeted his wife, his mistress, and his mistress’s other romantic interests. Josett was placed on leave in December 2023. His Flock access was not revoked while on leave, and he was still running improper queries in June 2024 — locating his victim’s new boyfriend’s home address — while sending thousands of harassing messages (sometimes 100+ per day).

On June 28, 2024, Josett was served a termination notice and an emergency protective order at the station. After leaving the station, he drove by his mistress’ home, violating the order, leading to his arrest. In April 2026, he pleaded guilty to three misdemeanors and received 3 years of probation, no jail time. His police certification is still under review.

@OC DA Press Release re: Robert Jay Josett, April 14, 2026

Costa Mesa residents showed up in force. For five hours, they told city council about how their trust was violated by this officer, the city, and Flock. More than a third of Costa Mesa residents are Hispanic/Latino, and many voiced concerns about cameras being disproportionately placed in their neighborhoods.

But one of the evening’s most powerful comments came from a 59-year Costa Mesa resident:

I was born in a fascist dictatorship \— Germany. I don’t want to die in one. Cancel Flock.

@vCosta Mesa, CA, public comment on East Germany

Other residents talked about the future of the community — including a mother who told Costa Mesa city council she keeps her seven-year-old inside, out of fear of cameras and federal immigration enforcement.

In front of a uniformed officer who had been posted beside the podium all evening — Axon camera blinking in “pre-recording” mode (just in case) — a representative of Pride at the Pier, an Orange County LGBTQ+ political advocacy group, further emphasized the harm being done to our young people by cities like Costa Mesa:

I want to talk about my nephew, who is currently reading his way through 1984 in school. And he came up to me, when I was visiting him and his mom, and said: “I don’t understand why this was such a big deal. Because we’re all watched all the time, right?”

@vCosta Mesa, CA, public comment on 1984

Four hours in, city council decided they had had enough democracy for one night. In a 5-2 vote (Chavez and Gameros opposed), they cut public comment time from three minutes down to two. A few Gen Z speakers simply hit the 1.5x speed button, but others, like the ACLU’s representative, had to hastily condense or truncate their comments, or had their microphone cut mid-sentence.

The circumstances of how Josett’s systems abuse was uncovered aren’t clear. During the hearing, Lt. Barnes told the council, “During that internal investigation by Costa Mesa PD investigators, they found that this former officer had misused Flock, was conducting searches that were not law enforcement related.” They discovered he had abused systems during an internal investigation — not the other way around: they didn’t see suspicious searches that triggered an investigation. The phrasing suggests they stumbled across this while investigating something else.

Former Costa Mesa police chief Ron Lawrence — who first contracted with Flock in 2022, seven months after being made chief — delivered the marathon hearing’s only pro-Flock comment. He said Josett was convicted “because we, Costa Mesa PD, insisted that they file charges.” The implication: without the PD’s pressure, charges were no sure thing. All of Josett’s abuse occurred during Lawrence’s tenure. Lawrence retired in June 2025.

Councilmember Arlis Reynolds also specifically called out Lawrence’s procurement and decision-making process:

I realized tonight that our original Flock contract actually wasn’t made in public. We signed a $98,000 contract without transparency, without public disclosure. $98,000 is $2,000 short of what the city is allowed to do without public transparency … it strikes me that the locations chosen, or the number of cameras chosen, was not based on analysis of crime data or need…

Reynolds also pressed the PD on who has access. Rather, she asked the fairly straightforward question: how many people outside the department can access Costa Mesa’s data? The three Flock administrators present (out of nine total) could not answer.

Knowing who has access wasn’t a prerequisite for assuring Reynolds and the council that the PD has now implemented “rigid internal checks and balances to ensure that employees who no longer work for us or are on administrative leave have their access revoked.” They have been doing audits for the past 12 months, and they’re now using Flock’s new Audit Assistance tool.

None of the police or councilmembers present discussed which existing policies failed or why. Josett’s documented post-leave queries ran through Flock — a system with no external access-revocation requirement at all. Whether his CLETS access, which connects directly to the FBI’s NCIC and at minimum should have been disabled under existing policy,^[2] was ever cut, nobody asked. An assurance that a policy that was already in place now exists does not inspire confidence.

During his presentation, Lt. Barnes also talked about the retention limit: “Our data collection retention, it’s for a full year, it’s for 365 days. That’s something we believe strongly in.” A CMPD captain backed him up by saying retail theft is often not discovered for “up to 180 days plus”. When the council suggested cutting retention to 21 days, Chief Joyce LaPointe did not share that strong belief in the 365-day retention window:

I understand that 365 days is a long time and it’s not necessary… However, I do think 21 days is a little bit short for our investigative bureau… I think just if we were to increase it to 45 days, I think that would allow us to have the information that we need. I know that’s double what you guys are asking for… I know 365 days is quite an extensive amount of time to retain.

The council ultimately voted to keep the contract and change the retention period to 45 days.

All of this followed a now-familiar pattern: pay for the system, install the system, adopt the policy, vote on the system. In that order — an exact inversion of democratic process.

In Costa Mesa, as elsewhere, the contract was quietly snuck in right under a procurement limit. Former Chief Lawrence, Flock, or both, decided that they did not want to ask the community whether they wanted to be surveilled and have their daily life photographed, stored, and shared for a full year. They didn’t create or enforce an effective policy to prevent abuse, and they didn’t give the council an opportunity to go over the contract.

The community who showed up last night, staying past midnight, even after council cut their speaking time, made it clear exactly why these systems try to avoid the light of day. They also made it clear why we need to keep dragging them out from the shadows.

The contract will be renegotiated. Costa Mesa will be watching.

The plate that sent the fuzz after Feder was a New Jersey manufacturer plate: 34 10 DTM. The plate that caused Esterdahl’s 90-minute stop was 34 08 DTM. On these plates, the small middle digits identify the individual car; the rest identifies the manufacturer’s fleet allocation.

Enter Joshua Thomas, Flock’s Chief Communications Officer, to explain the issue to The Drive:

Thomas says the plate was read correctly:

The way that the ML works is it correctly read what it was supposed to read… It was asked, can you find this? And it did find that.

But that police like to enter partial license plates:

The way that law enforcement likes to use these tools is, if any of the characters that they have put into these hot lists get read, they want to get those alerts.

According to Thomas, someone purposely told the system to alert on all results for a plate starting with “34” and ending in “DTM”.

That would be fine and dandy,^[1] were it not for NCIC policies, procedures, and technical constraints.

According to the reporting across the two incidents, a third plate from the same fleet — 34 03 DTM — was reported stolen in California (Feder later learned it had actually been lost by Land Rover during a photo shoot) and entered into NCIC as 34DTM, presumably into the License Plate File, where stolen plate entries go.^[2]

The Drive initially reported the entry came from LAPD; LAPD later said it was actually someone with the Los Angeles County Sheriff’s Department. LASD hasn’t commented.

The Drive says that “speaks to how messy and hard it is to ensure the data will always be clean going into a system like Flock—what it needs is stronger guardrails within it.” What The Drive likely doesn’t know is that those guardrails already exist: every single policy and procedure to prevent these issues from happening was violated.

First: the plate was lost, not stolen. The very first criterion for entry:

A uniquely-numbered stolen license plate can be entered only if a theft report has been made. … Agencies must have a theft report (electronic or hard copy) on file to support a license plate entry. Only the agency holding the theft report and having primary jurisdiction over the place of actual theft may make an NCIC entry — § 1.2, NCIC Operating Manual, License Plate File (Nov. 2022), as published by Illinois State Police

@NCIC Operating Manual, License Plate File chapter (Nov 2022), as published by Illinois State Police

So either no qualifying theft report exists — making the record ineligible from the start — or a deputy took a theft report for a plate that nobody stole. Either way, that guardrail didn’t do much.

Second: the manual flatly prohibits what was entered. “Partial license plates must not be entered” (§ 2.5.2). The manual does handle two edge cases that resemble partial entries: plates longer than ten characters (enter the first ten, put the full number in the MIS miscellaneous field), and plates whose hyphens or symbols could cause a collision when stripped (“an example is plate number 1-1568 which would be matched with plate 11-568”). Again, the full plate goes in the MIS field. In both cases, the fix is more information in the record, never less.

And here’s the part that should embarrass Flock: NCIC’s one true partial-matching behavior comes with a warning label. When a plate exceeds eight characters, “the NCIC LIC search method uses the leftmost eight characters of the LIC” and the system automatically appends a caveat to the hit response: RECORD NIC/V123456789 IS BASED ON A PARTIAL LIC SEARCH - VERIFY ALL DATA BEFORE TAKING ACTION BASED ON THIS RESPONSE (§ 5.4, Vehicle File chapter).

When the FBI’s forty-year-old mainframe deviates from exact matching, it tells the officer, in capital letters, on the hit itself. Flock’s substring alerts arrive on someone’s smartphone without that information.

@NCIC Operating Manual, Vehicle File chapter (Nov 2022), as published by Illinois State Police

Third: the record must say what kind of plate it is. License Plate Type (LIT) is a mandatory entry field, and NCIC classifies everything that isn’t a standard passenger plate — including manufacturer plates — as a “special plate” with its own required type code (§ 1.1, § 2.5.5). A properly-built record would have announced itself as a New Jersey manufacturer plate.

Fourth: someone is supposed to look. The stopping agency must contact the entering agency, and:

“To confirm the hit” means to verify that the theft report is still outstanding; to verify that the license plate inquired upon is identical to the license plate described in the record… — § 5.5

Identical. Not “contains the same characters.” 34 10 DTM is not identical to 34 DTM, and no full plate ever can be identical to a truncated one. Applied as written, stops based on this record are impossible.

Fifth, the backstop: a “state Department of Motor Vehicles (DMV) where the plates are issued may compare license plate data with records contained in their files” and notify the agency or NCIC to correct or cancel the record (§ 1.4). It’s optional, and it requires an actual registry lookup rather than a format check — at five characters, “34DTM” is a facially valid NJ personalized-plate combination — but the mechanism exists. It would take milliseconds for NJ DMV to check if “34DTM” is an issued vanity plate, but the check was apparently not run.

We don’t really know exactly what the deputy entered. “34DTM” is the logical conclusion, because the license plate field “[m]ust not contain hyphens, spaces, or symbols.” Thomas’ suggestion that partial matching is a feature raises technical questions, because NCIC doesn’t have a “partial match” option. It prohibits partial plate entries, and the license plate field doesn’t allow wildcard entries like 34*DTM or 34%DTM.^[3] Any fuzzy matching happened in Flock’s system, against Flock’s copy of the hotlist.

We know 3408DTM, and 3410DTM triggered the alerts. Would 1234DTM or 34DTMABC have led to the same outcome? Would 314DTM have? How does Flock decide what’s “close enough” to send cops after a plate?^[4] And why isn’t it respecting NCIC’s constraints?

After his stop, Feder wrote, “the officers literally showed me the Flock app on their phone and explained how they used it.” Presumably, whatever the app displayed^[5] did not include the NCIC-required information that would have let them confirm the match, because the stop was improperly executed without confirmation — twice.

The guardrails and safeguards and backstops were all here. Entry requires a theft report. Partial plates are prohibited. The record must declare its plate type. Hits must be confirmed as identical with the entering agency before anyone acts. The DMV can flag and kill invalid records. Every layer of that system assumes exact matching, and several of those layers enforce it in writing.

Flock received an improperly-entered record for a plate that was never stolen, matched it against two different plates it read correctly — per Thomas — and called both a hit. The FBI’s rules say a hit means identical, but Flock says a hit means whatever it deems close enough.

Even with all those guardrails, four squad cars surrounded a journalist in a Kohl’s parking lot, and another reporter was detained for 90 minutes. Feder wrote that the cascade of errors “could’ve led to someone getting hurt or even killed.” Even Flock’s Thomas conceded the point, telling him: “I’m really thankful that your kids weren’t in the car. I’m thankful.”

We don’t need more guardrails. We need less Flock.

“Audit Assistance” went into general availability on April 14, 2026. Flock says little about how it works: it “continuously monitors system activity and surfaces search patterns that fall outside an agency’s typical usage,” and it is “proactive” (while simultaneously being a dashboard that must be opened). Flock’s press materials never say what’s under the hood. A police commander quoted in the announcement credits “an algorithm,” but a company spokesperson told Atlanta News First that it “uses artificial intelligence to flag searches that may be outside a department’s policy.”

The Abuse Is Not Hypothetical

The Institute for Justice’s list of “police officers using ALPR camera networks to keep tabs on their romantic interests” is up to 24, as of today. The cases date back to 2021, but most were discovered in the past year. The ALPR abuse library is only current until May 2026, but it has documented 66 cases across 28 states. Only 8 of those are dated before 2025.

People who were stalked before 2025, or after 2026,^[1] may never find out. People who had their personal information pulled from systems other than Flock also may never know. Flock and police even made it part of their fatalistic sales pitch to communities: you are under surveillance 24/7, by more invasive tools than Flock — what are you even worried about?

“It’s Just Not That Interesting”

If [people are] worried about privacy, a license plate reader is the dumbest way to do surveillance. You have a cell phone. A cell phone knows your exact location at all times. — Garrett Langley, CEO Flock Safety, CNN/WRAL (Dec 2025)

And because Flock itself only retains the data for 30 days (never mind that it can be copied and stored indefinitely during that period), Langley argues, abuse is at worst limited and boring:

There’s still going to be abuse, but it limits that, hey, if it’s seven days, 14 days, 30 days of data, it’s just not that interesting. Relative to what you see with data brokers online, where they have your entire internet history stored forever. — Garrett Langley, CEO Flock Safety, Cheeky Pint Podcast (Mar 2026)

Flock’s blog makes the same move: “reported misuse represents a small fraction of overall activity”, and only “19 agencies out of approximately 3,900 Flock customers conducted searches that explicitly referenced protest activity. That represents roughly 0.48% of agencies, less than half of one percent.” Which, of course, doesn’t count the other kinds of abuse — like stalking romantic partners.

It’s an interesting position for a company that, by its own count, photographs and indexes more than 240 billion plates, in case any might be related to one of 6.3 million crimes.^[2] Even if every single crime in the US were captured on a Flock camera ten times over, only 0.026% of captures would contain any information related to a crime. If 0.48% of agencies stalking protestors doesn’t prove the system is being abused, then 0.026% of photos being relevant certainly doesn’t prove it solves crime.^[3]

All You Need to Do Is Look

No matter the scale, transparency tools help uncover abuse. haveibeenflocked.com has helped some people find out they were being stalked, and, in a few of those cases, their discoveries led to consequences for the stalkers. Maybe “Audit Assistance” is helping too — Flock certainly says so.

But finding abuse is not the same as stopping it, and this was never a technical problem to begin with. Sure, nobody can manually read the millions of searches that hit the system every month, and even a mid-sized agency produces (tens of) thousands.

But checking if every search has a case number takes seconds. Checking if reasons go beyond “sus” or “inv” is trivial. Automating keyword scans (which is what the reports on this website do) is a twenty-minute task for the IT department, or just someone who is good with spreadsheets. You don’t need AI for any of that: all you need to do is look.

Very few people were looking at Flock logs before they started being published as responses to public records requests in 2025. A year later, Flock and police have only made it more difficult to watch them. And what about everything else? Langley wasn’t wrong about the data brokers with “your entire internet history stored forever.”^[4] None of those systems publish logs, and nobody is getting fired for abusing them. At the end of the day, a few cops have been fired over how they used Flock, but nothing has actually been solved.

“It Captures Vehicles. Not People”

The underlying problem is the constant minimization. With one hand Flock builds an “Audit Assistance” tool and issues press releases about the criminal cops it catches; with the other it insists there is no privacy interest in any of the data.^[5] Both can’t be true.

If the system “captures vehicles, not people,” nobody could be stalked with it; every stalking charge Flock takes credit for uncovering is evidence against its own product description. What are cops supposed to conclude about a system that they are told “captures vehicles, not people,” where “30 courts” have supposedly agreed the Fourth Amendment doesn’t apply, that they can access from their personal phones, and where the defaults serve up 30-day nationwide location histories on DUI stops? That it contains highly sensitive information?

“Five Officers Arrested”

The Albany announcement was titled “Five Officers Arrested.” It went out as a corporate press release, distributed on a newswire between product launches and C-suite hires. Five of its customers’ employees used the company’s product to commit crimes, and Flock’s marketing department sent out a press release claiming a victory.

Flock’s co-founder supplied the moral: “Technology doesn’t create misconduct. People do. The question is whether the technology is designed to expose that misuse.” Expose. Not prevent. Flock isn’t fixing its product so that it prevents abuse, or even deters it: its press release wanted you to know it has built a surveillance tool to detect beat cops messing up, and to get them fired and jailed. The system that invites the abuse rolls on, and Flock continues minimizing to make the sale.

The Difference

Of course, I post this on a website that also audits Flock searches — meta-surveillance, by my own definition. There are differences: the reports here run on public logs, and are public themselves. They don’t hide in a private dashboard that shows only what an admin, or a marketing department, decides to share. And Flock needs its audit tool — audit is what keeps the surveillance sellable.

This website exists to make the opposite case. I’ve said from day one that I want to be able to shut it down. We can end the abuse by ending the surveillance. And by ending the abuse, we can end the meta-surveillance. Shouldn’t that be the goal?

No ordinance passed by the Council, unless it be an emergency measure, shall go into effect until thirty (30) days after its final passage by the Council. If at any time within said thirty (30) days, a petition … be filed with the Clerk of the Council requesting that the ordinance, or any specified part thereof, be repealed or submitted to a vote of the electors, it shall not become operative until the steps indicated herein have been taken. — Cleveland Charter, § 59

This means two things: first, there will be no new contract for at least thirty days. Nor will the “guardrails” passed by Council come into effect. If the cameras stay up and Flock continues to collect data, that collection will not be constrained by local democracy.

Second, Clevelanders have roughly thirty days^[1] to deliver a petition forcing Council either to repeal the ordinance outright (no contract extension) or to put it to a referendum. A petition would need roughly 4,400 registered Cleveland voters — in a city of ~360,000 residents — to sign on.^[2]

Before the vote, Flock told Clevelanders that “there will be cameras.” In what would appear to be the first popular referendum on mass surveillance, Clevelanders — the people directly affected by the surveillance — now have an opportunity to respond.

But before we get into that, it’s important to understand the context: the event happened on Friday, July 10. The following Wednesday, Cleveland City Council plans to vote on whether to extend its contract with Flock.

The unusual thing in Cleveland is that this new vote almost immediately follows a cancellation. Two months earlier, Signal Cleveland discovered that outside agencies had been running immigration searches against Flock devices in Cleveland and Cleveland Heights despite the city’s prohibition on immigration searches.

In response, Cleveland’s Public Safety Committee voted not to extend the city’s Flock contract. The city let the contract lapse in June. Then, despite having voted to end the contract, Cleveland’s Public Safety Committee has itself a do-over and votes to extend the contract by six months. The committee do-over decision is what will land with City Council on Wednesday for final approval.

While all this has been playing out, Flock’s cameras have stayed where they are, and the company has continued to surveil Clevelanders. Flock’s perpetual, irrevocable license allows it to continue using data collected before the contract expired. After the contract ended in June, Flock continued collecting data with no contractual restrictions or safeguards to cover it.

Cleveland.com also reported on the conversation. The headline: “'There will be cameras’: Flock launches full-scale defense of surveillance at City Club of Cleveland.”

Thomas’ fatalistic message to Cleveland was heard loud and clear: Surveillance is inevitable.

The Forms of Fatalism

The conversation in Cleveland struck a chord, because the night before I had just wrapped up a thoughtful analysis of Shoshana Zuboff’s book “Surveillance Capitalism” with Flock’s new AI Sales Assistant. At the end of our discussion, even Flock’s brainless automaton had to concede that, maybe, this mass surveillance thing could be harmful. (A chatbot will agree with nearly anything you feed it, of course. That’s not a confession; it’s a mirror.)

The book we discussed in our little makeshift online bookclub, which had led my new robotic friend to its realization, had this to say on the subject of inevitability:

The image of technology as an autonomous force with unavoidable actions and consequences has been employed across the centuries to erase the fingerprints of power and absolve it of responsibility. The monster did it, not Victor Frankenstein. However, the ankle bracelet does not monitor the prisoner; the criminal justice system does that.

Every doctrine of inevitability carries a weaponized virus of moral nihilism programmed to target human agency and delete resistance and creativity from the text of human possibility. Inevitability rhetoric is a cunning fraud designed to render us helpless and passive in the face of implacable forces that are and must always be indifferent to the merely human. This is the world of the robotized interface, where technologies work their will, resolutely protecting power from challenge — Shoshana Zuboff, The Age of Surveillance Capitalism, Ch. 7, §VIII.

By providing these inputs to the AI salesbot, I became no less responsible for its output than Flock is for the outcomes of its system.

Inevitability rhetoric, Zuboff writes, is so ubiquitous in tech that it amounts to “a full-blown ideology of inevitabilism.” Its practitioners know exactly what it’s for: nearly every Silicon Valley insider she interviewed regarded the inevitability talk as “a Trojan horse for powerful economic imperatives.”

That is why Flock argues its fatalistic stance any way it can. Five ways, by my count: the vendor is interchangeable, the outcome is unstoppable (so your objection doesn’t matter), your privacy is already gone, the buildout is destiny, and the constitutional limit is real but not yet. Let’s take them in order.

1: Substitution Fatalism

“If not us, someone else.”

“If it’s not Flock, it’ll be somebody else”; “if we’re not here another company will be here.” — Joshua Thomas, City Club (7/10/2026).

An audience member addresses it head-on during the Q&A portion, by likening it to an Israeli settler taking a Palestinian home and justifying it with “if I don’t do it, someone else will.”

Thomas never engages with the analogy.

He does, however, try to enlist Golbeck as a co-author of the premise. Twice. First: “you made this sound like it is inevitable… But I agree with you, there is an inevitability with this.” Later: “as you said — and I’ve said — this is inevitable.” Golbeck cuts him off mid-sentence: “don’t attribute that to me. I don’t agree.” Cameras will exist, she allows, but “I don’t think this surveillance structure is inevitable.”

The premise apparently needs a co-signer. It didn’t get one.

His statement is inaccurate either way. In Denver, where Flock also continued its surveillance for several months after the city had terminated its contract because data had been improperly shared on Flock’s national network, the city switched vendors to Axon.

Yes, the city continues to be under surveillance, but the improper data sharing on Flock’s national network — which was the city’s entire reason for switching vendors — has ended. Thomas’ fatalistic substitution argument only works if all vendors are identical — they are not.^[1] And the argument, it turns out, wasn’t composed for Cleveland. Little of what Thomas said that afternoon was.

The Script

At City Club, Thomas illustrated Flock’s value the way the company always does: with an eyewitness and a blue Jeep. Old-school cops “might have to stop every blue Jeep in the vicinity and create unwanted interactions with law enforcement”; Flock, instead, delivers “precision.”

If the delivery sounded rehearsed, that’s because it was. The anecdote appears nearly word-for-word on Flock’s corporate blog, and industry lobbyist Skylor Hearn performed it on a livestream alongside Flock’s chief lawyer in February (“more sniper than shotgun”). I’ve written about that routine before. This was at least its third documented deployment.

Note what the blog version promises: alerts fire “only when a specific license plate associated with a reported crime is detected. Not every vehicle of a certain color.” Then Thomas described what a search looks like for the audience: a color-and-description search — “a blue jeep with a bike,” no plate required. The moderator separately highlighted an instance where the ATF had used a car’s make, color, and bumper stickers to get a hit. Again, no license plate.

Flock didn’t end the blue-Jeep sweep; it just moved it. The search for blue Jeeps now runs against every car, everywhere, in advance, and the results are stored in Flock’s national database. The moderator, Signal Cleveland’s Nick Castele, spotted the swap: “But that starts with a very wide funnel of anybody who’s driving.”

“What’s the alternative?” Thomas replied. “You start with a very wide funnel of anybody who’s alive.”

Notice the shape of that defense. It isn’t “the funnel is justified” — it’s “a bigger funnel would be worse.” Flock never argues that its baseline is right; it argues that a hypothetical alternative is more wrong. Remember the shape. It comes back.

As it happens, the LAPD’s Inspector General published the funnel’s arithmetic in a review dated — poetically — the same day: Los Angeles’ ALPR system logged 210,568,103 plate reads in two months, yielding 337 recovered vehicles and 74 arrests.

One arrest per roughly 2.8 million scans of anybody who’s driving. Another 161 alerts were confirmed plate matches to cars that turned out not to be stolen at all, exactly like the incident two days earlier, where a journalist working for The Drive was boxed in by police cars and told “You’re lucky we’re in Plymouth. If you were in Minneapolis, they definitely would’ve come at you with guns drawn.”

2: Futility Fatalism

“It’ll happen regardless; resisting accomplishes nothing.”

Flock CEO Garrett Langley tacked another fatalistic way: that of outcomes.

“If the state of Texas wants to enforce immigration, they might use Flock, but they’re gonna go enforce immigration no matter what Flock does.” And: “we can’t make that our problem as a company.” — Outsider Inc. podcast (June 2026)

This is Zuboff’s “the monster did it” in action. The outcome is presented as the result of an unstoppable, autonomous force. Texas will enforce immigration, the villagers will die; we can’t make that our problem as scientists.

What Langley omits is that he engineered the infrastructure to create the outcome: sharing is the default. It’s a nominal opt-in, with auto-approval workflows and no workable oversight mechanism.

Instead of building a three-foot monster and keeping it on the hill, Langley chose to build the ten-foot one and direct it toward the village.

Flock’s Chief Legal Officer, Dan Haley, completes the pincer: if Flock’s choices change nothing, neither do yours. Haley doesn’t engage with the notion that cities are canceling because of data security and access failures, or mysteriously changing settings. Instead, he tells the Legal Leaders Podcast:

protesters will say… their city council should cancel their Flock contract to send a message to the Trump administration.

As someone who has watched too many city council meetings to comfortably admit to: I have never once heard this argument. Residents often raise concerns about the many instances where ICE was found in Flock’s network — either because of “pilot programs,” or because cities disabled outside access and federal agencies got access anyway.

Residents of sanctuary cities or states that prohibit use of surveillance technology for civil immigration enforcement will often urge their elected officials not to do business with Flock, because it risks eroding the protections they fought to enshrine in local law. Not “to send a message to the Trump administration.”

Regardless, Haley launched an on-air assault on the strawman he had built:

Cancelling a Flock contract sends no message to the Trump administration. The Trump administration does not care if your community has a contract with Flock any more than it cares what I had for breakfast… It’s totally ineffectual.

To take Denver as an example, the problems the city had attempted to fix — “pilot programs” and a documented history of unauthorized access — have been addressed by trading a vendor we know can’t responsibly handle surveillance data for one that has not yet received as much public scrutiny.

Even though vendors like Axon are likely to take the wrong lesson from Flock’s continued fumbles, the public and officials in cities like Denver now know what to look for. It will be that much harder for Axon, Motorola, Genetec, Insight, or any of the dozens of others to evade scrutiny, as they have been doing for years.

3: Baseline Fatalism

“You’re already surveilled anyway.”

At those many city council meetings I did hear the line “You’re already surveilled anyway” often. It has been repeated all over the country, by police, city officials, Flock sales staff, and pro-surveillance residents. Cell phones and connected vehicles are the usual culprits cited.

At City Club, Joshua Thomas told Dr. Golbeck and the audience, “you have an Instagram account for your dogs… Half of us in the room… are posting our photo and our location everywhere we go.” At TED2026, Garrett Langley told them, “Every person in this room can be tracked to a foot at this very moment with your phone. That’s a fact.”

It’s the funnel defense again: never “this is justified,” always “something else is worse.” Your dog’s Instagram, your phone, “anybody who’s alive.” Comparisons rather than justification.

It’s not a new line. Twenty-seven years ago, Sun Microsystems’ CEO Scott McNealy put it a little more bluntly:

You have zero privacy anyway. Get over it. — Scott McNealy, Sun Microsystems, Wired (1/26/1999)

Sun Microsystems has since been acquired by Oracle, whose founder, Larry Ellison, has been widely quoted as saying, “citizens will be on their best behavior, because we’re constantly recording and reporting everything that is going on.”

The companies and technology changed while the nihilism remains.

To counter Thomas’ Instagram-jab, Golbeck deployed the familiar “choice” counter-argument live on stage, saying, “I make incredibly intentional choices about what I share… they don’t have a choice where I do have a choice.”

The Supreme Court also rejected this flavor of fatalism in its recent decision in Chatrie. Yes, location history data had been turned over to Google, but it had never been voluntarily surrendered to Google, let alone the government.

Even when privacy issues exist, we don’t need to “get over it.”

4: Teleological Fatalism

“The buildout is destiny.”

In September 2025, Langley told Forbes that within ten years his company’s surveillance would eradicate “almost all crime” in the U.S. At City Club, Thomas expressed the extent of the company’s manifest destiny by saying “every city in America will eventually be using some of this technology.” Langley states the reason in his TED2026 talk: it’s to create “an environment where crime is unsustainable.”

Zuboff nails the rhetoric’s genre; the technological surveillance state “appears virtually ordained either by god or by history.” Somewhat ironically, she then notes:

The “societal goal” articulated by the leading surveillance capitalists fits snugly into the notion of limitless technological progress that dominated utopian thought from the late eighteenth century through the late nineteenth century, culminating with Marx.

The final lines in the first chapter of Marx and Engels’s Manifesto of the Communist Party read:

What the bourgeoisie therefore produces, above all, are its own grave-diggers. Its fall and the victory of the proletariat are equally inevitable.

An inevitable utopia, through modern technology.

At City Club, Golbeck likened mass surveillance to leaded gas. She told Thomas that at one point we used leaded gasoline, but when we found it was harmful, we banned it and found other solutions. Describing surveillance technology, she said “we are in the leaded gas phase now.”

Cities seem to agree with her. According to Tech Times, as of June 2026, “more than 53 municipalities across 20 states have terminated or rejected contracts” with Flock, “citing data-sharing violations, unauthorized federal access, and a pattern of surveillance settings that operated well beyond what cities were told they had signed up for.”

5: Deferred Fatalism

“The line exists, and we’ll tell you when we’ve crossed it.”

On the Legal Leaders Podcast, recorded in February 2026, Haley also said:

There will come a time where… this technology could get ubiquitous enough and powerful enough that there needs to be a warrant requirement… that day in the future is out there. And when it comes, we’ll build tools to enable that. It’s just not yet.

He cites “over 30 Fourth Amendment challenges… all unambiguous” to prove his point.

Five months later, Joshua Thomas toed that company line in Cleveland:

“as we approach those lines, yes, we should then decide how do we regulate that stuff”; “Flock is so far from that today.”

According to Thomas, there are now “more than 40 courts” that have resolved the issue. (The count grows by about ten per telling; a list has yet to appear.)

Despite the court holdings, Flock concedes there is a limit … somewhere. Flock also rhetorically assigns itself the authority to decide when that limit has been reached. The company will let you know if we’re “there yet.”

Of course, looking back to TED2026, CEO Langley — in his typical fashion — does not follow Haley’s lead. There, he tries to get the crowd excited about Flock’s network of more than 100,000 cameras and the army of drones, all hard at work to realize the “environment where crime is unsustainable.” His implied promise is that we’ll be there soon.

But Cleveland rejected the notion that it needs to wait for Flock to decide when a line has been crossed. The city is proposing language that would make the requirement local law, not subject to a vendor’s judgment. Cleveland’s as-amended ordinance doesn’t stop at warrants:

Flock shall not disclose data obtained through the ALPR contract in response to subpoenas, administrative requests, informal inquiries, preservation letters, national security letters or any other legal process that does not constitute a search warrant unless required by applicable law. — Ord. No. 683-2026, §2 (as amended)

This is a city council enumerating and rejecting national security letters by name, in a camera contract, with a financial penalty of up to 25% of the contract’s value attached. (The “unless required by applicable law” carve-out will do some work, but the same section also obligates Flock to “narrow, resist, quash or otherwise challenge” any overbroad demand.)

Haley promised Flock would build tools for warrants when the day comes. Cleveland declined to wait for the vendor’s calendar. Deferred fatalism, undeferred by ordinance.

Manufacturing inevitability

Fatalism is a rhetorical posture. It is also, it turns out, a product feature.

When Cleveland’s committee voted to end the contract and let it lapse, the cameras kept recording. Flock volunteered to run them for free while the city figured things out.

In Evanston, Illinois, the city terminated its contract and Flock removed its cameras. Flock then reinstalled them without the city’s permission. Evanston sent a cease-and-desist. The final two cameras came down in March 2026, seven months after termination, and only after a local paper asked why they were still up.

Cambridge, Massachusetts and Eugene, Oregon, also found cameras still running after ordering them shut off. Other cities reached for the trash bags. In Dayton — where cameras had been searched more than 7,100 times for immigration enforcement in violation of city policy — officials couldn’t tell whether the cameras were still recording, or whether taking them down would breach the contract. Dayton Public Works bagged all 72. Evanston bagged its cameras while awaiting removal — then re-bagged them after the unauthorized reinstall. In Ithaca, residents got tired of waiting and bagged the cameras themselves.

For all the talk of local ownership and control, the only switch a Flock customer actually controls is the garbage bag.

The paperwork is built the same way. Flock’s standard terms reserve to the company “final discretion to veto a specific location” for camera placement (§10.2). When I raised the clause with Flock’s VP of Aviation, Rahul Sidhu — mid-explanation that camera siting is “how local democracy works” — he conceded it: “Yes, Flock can veto a location.”

Flock’s revised terms grant the company a perpetual, irrevocable license to customer data that outlives the contract. That’s the license Cleveland is living under right now. And in Ridgecrest, California, email records show police arranging Flock poles on private property owned by an LLC, with the department “signing the consent forms on their behalf,” and Flock telling them “that would be fine!”

Then there is Los Angeles. On July 11 — the day after the City Club forum — the LAPD let its Flock agreement expire, ending a three-year relationship over what its chief information officer called “serious concerns around civil liberties and civil rights issues, particularly around privacy and the data that is being collected from these cameras.” Flock said the decision “comes as a surprise.”

The Inspector General’s review explains where the surprise came from. The department’s MOU let Flock “retain[] the right to any recordings or data provided through Flock” and “use the data for any purpose.” The nation’s second-largest municipal police force found itself on the receiving end of the same boilerplate as everyone else.

Roughly 1,500 Axon in-car cameras feed plate data into Flock’s system, with no written agreement covering security at all; in the OIG’s words, “Flock’s access to Axon data is unknown in the absence of a written agreement.”

Fifty of the Flock poles arrived free, donated after the Palisades fire, under an undated MOU signed by Flock’s general counsel and by the Chief of Police. The OIG’s first recommendation: suspend new ALPR deployments and contracts pending public input. The California State Auditor flagged the same contract deficiencies in 2020, but the paperwork stayed broken for six years.

And, per ABC7’s report on the expiration: “It’s uncertain whether the cameras will continue recording after the agreement expires.” Of course it is.

@LAPD Office of the Inspector General: Review of the Department’s ALPR System and Use in the Field (July 10, 2026)

None of this is what inevitability looks like. It is what enforcement looks like, even if belated. Zuboff again: “Men and women made it, and they can control it. They merely choose not to do so.”

Exhibit A: The Master Spreadsheet

Attached to Cleveland’s ordinance is CPD’s evaluation deck, dated June 16 — presented the night before the committee voted the contract down. Its “ROI” section is a fill-in template, and the template does the deciding.

@CPD ROI scorecard, Ord. 683-2026 attachment 3

“Investigative Leads Generated”: 30,000 baseline, 144,000 with Flock — roughly four times Cleveland’s entire annual reported crime volume, which suggests camera hits relabeled as “leads.” “Officer Utilization”: baseline 0, result 144,000 — a percentage metric, expressed in the identical number as the leads row. “Time Saved”: 150. One hundred fifty what? The deck doesn’t say.^[2] The “Evidence” and “Notes” columns exist, but are empty. The operational benefit scores are straight self-assessed 5.00s.

The money page values “Personnel Time Saved” at $1,936,875. The dollar amount is precise, but the methodology is absent. The “Annual Cost” is noted as $1,000,000. The contract one attachment over is for $250,000 a year. Nothing reconciles.

And at the bottom, in a cell labeled Auto Recommendation: “Proceed to Level 3 (Enterprise Deployment).”

This is fatalism as a workflow: vendor rhetoric upstream, template procurement downstream, human judgment entirely removed at both ends.

One more notable detail: among the deck’s “success stories” is the county’s 37-defendant fentanyl indictment — a case in which prosecutors say Flock cameras were “used to track vehicles associated with this group, identify travel patterns and assist investigators in linking participants.”

Tracking travel patterns over time, like in a heatmap, is precisely the thing Thomas assured the City Club audience Flock doesn’t do. The department’s evidence for renewal is the counterexample to its vendor’s constitutional defense.

There will be cameras

On Wednesday, Cleveland City Council votes. Whatever it decides, the sequence is important: the city discovered the searches, said no, and the cameras kept recording. Then the city said yes to six more months — this time with a warrant clause, a penalty, a transparency mandate, and instructions to go shopping among Flock’s competitors.

Thomas opened the City Club hour by taking the only real question off the table: “The question I have is not will it be used. The question is how.” Every flavor of Flock fatalism exists solely to keep that first question — “will it be used?” — from being asked.

It is the one question the company can’t survive being asked city by city, contract by contract. Even Flock’s head lawyer concedes a constitutional line exists — he just asks you to let his company decide when we’ve crossed it. Maybe he’ll create a spreadsheet for that too.

Zuboff summarizes the stakes: inevitabilism “precludes choice and voluntary participation. It leaves no room for human will as the author of the future.” Cleveland’s warrant clause, Evanston’s cease-and-desist, Dayton’s trash bags, Denver’s exit, the LAPD’s walk-away — those are all human will, authoring. They show that even when decisions are slow, ugly, or reversible, they are not inevitable.

DeFlock’s National Week of Action Against ALPRs runs August 16–22. Its tagline directly refutes Thomas’s opener in Cleveland: Surveillance isn’t inevitable.

Article photo: "Cleveland, Ohio Skyline and the Guardians of Traffic" by Erik Drost, via Flickr/ WikiMedia Commons, under the terms of the Creative Commons Attribution 2.0 Generic license. The image used was cropped from the original.

Here’s the relevant language, as currently published:

Replacements. In the event that Flock Hardware is lost, stolen, or damaged, Customer may request a replacement of Flock Hardware at a fee as set forth in the Reinstall Fee Schedule. In the event Customer chooses not to replace lost, damaged, or stolen Flock Hardware, Customer understands and agrees that Flock is not liable for any resulting impact to the Flock Services, nor shall Customer receive a refund for the lost, damaged, or stolen Flock Hardware.

The companion clause on “Deployment Plan” changes goes further:

After installation of Flock Hardware, any subsequent requested changes to the Deployment Plan, including relocating, re-positioning, adjusting of the mounting, removing foliage, replacement, and/or changes to heights of poles will incur a fee as set forth in the Reinstall Fee Schedule. Customer will receive prior notice and confirm approval of any such fees.

A MuckRock production linked from Joey Scott’s “FOIA Friday” piece on “The case of the missing and destroyed Flock Cameras” shows Moreno Valley contracts its policing to River County Sheriff’s Department (RCSD), so a request for Moreno Valley PD records returned RCSD’s correspondence. Scott’s piece covers the theft and vandalism costs in that file — I encourage you to read it. This article will focus on the approval bypass that Flock and RCSD (and likely many other agencies) appear to be employing.

RCSD’s Flock contract, a five-year Master Services Agreement from August 2023, carried substantively the same two “approval required” provisions as above, under different section numbers.

In the emails, however, Flock unilaterally decides there’s a problem, dispatches a technician, replaces the unit, and only then tells the county an invoice is coming:

Cam #05 SB Harvill @ Cajalco, 5/1/23 (p.144):

We will need to replace the pole to ensure the location is functioning properly as soon as possible. Due to the damage being physical in nature, we will be sending an invoice for the damage in conjunction with our reinstall fee schedule. This invoice ($500) will be emailed to [redacted]@riversidesheriff.org shortly.

Cam #48 WB Ave of the States @ Washington, 5/24/23 (p.146):

The technician noticed that the location experienced third-party damage after an apparent vehicle accident. We went ahead and replaced the pole to ensure the location would be functioning properly as soon as possible. Due to the damage being physical in nature, we will be sending an invoice for the damage…

Cam #14 WB Allesandro @ Gillman Springs, 8/3/23 (p.203):

The technician noticed that the location experienced third-party damage as all equipment has been destroyed in an apparent vehicle accident. We went ahead and replaced all equipment to ensure the location would be functioning properly as soon as possible. Due to the damage being physical in nature, we will be sending an invoice for the damage in conjunction with our reinstall fee schedule. This invoice ($1,300) will be emailed to [redacted]@riversidesheriff.org shortly.

Cam #34 NB Lyon @ Esplanade, 8/14/23 (p.207/340):

The technician noticed that the location experienced third-party damage as the solar panel is stolen and the wire to the camera was cut. We went ahead and replaced the panel to ensure the location would be functioning properly as soon as possible. Due to the damage being physical in nature, we will be sending an invoice for the damage in conjunction with our reinstall fee schedule. This invoice ($350) will be emailed to you shortly.

None of these are requests. Three of the four predate the August 2023 MSA, meaning whatever earlier agreement was in force governed them — the record doesn’t establish what that agreement said, but it’s unlikely to be meaningfully different.

None of the four emails even cite a section that applies: each points to “Section 7.1” or “Section 8.1,” neither of which covers replacement fees in the August 2023 MSA (7.1 is the contract’s term length; 8.1 is manufacturer defects, a different subject). The clause has been under at least three different numbering schemes since 2023 — the 2023 MSA, a December 2025 rewrite, and the current terms quoted above. Flock support is quoting something else.

Anyway, Flock does know how to ask first … when it wants to move the pole somewhere new, at the customer’s expense:

Cam #14, second incident, 8/16/23 (p.203):

Would you like to move forward with a relocation at this time to avoid damaged equipment reinstall fees ($1,300)? … Do you agree to pay for the relocation fee of $350 to an existing pole or $750 to Flock pole?

RCSD’s fiscal staff say they can’t reconcile what they’re billed for:

RCSD has over 250 cameras, multiple networks and planning to add another 250 this upcoming FY. With these many cameras, it is very difficult to keep track of repairs and their subsequent billing. I’ve mentioned this to Tonya Crump before, but I’d like to have notes on each invoice specifically identifying the network and specific camera name, so we know which station needs to approve the invoices and have a way to track repair costs by station over time. — Andres Martinez to George Pitt (Flock A/R), 4/7/23 (p.227)

… and things even get a little spicy over it:

Your invoice has a “Notes” section already. Would it be too much to ask that this section include the network name and camera name? (CA-Riverside Sheriff – Lake Elsinore - #21 Main @ Cross St). If you can help with this and resubmit these invoices, I’d be happy to get them all process[ed] and paid immediately. — same email

Flock’s billing side seems equally clueless about what they’re billing for:

FYI, the first invoice note mentions Los Angeles/ Long Beach but is invoiced to the RSO. — Matthew Perez (Riverside Administrative Services), forwarding invoices, 4/7/23 (p.228)

and:

The relocation invoices. I do not have the camera locations for. I cc’d Tonia Crump… Maybe she can assist with the camera location for all that I did not note. — George Pitt (Flock A/R Specialist), 6/14/23 (p.227)

Whether local procurement rules require the same kind of pre-authorization before staff can pay an invoice received outside an existing contractual arrangement is a question for a city or county attorney, not me. Public contracting rules vary too much by state and agency.

But if a fee is conditioned on an approval step that didn’t happen, and staff pay the invoice without checking for that approval, they’re relying on Flock’s invoice as their only authorization. That seems like a dicey proposition for everyone involved.

If you’re using open records requests to obtain Flock contracts from your city or county, request the procurement/purchasing policy, the full invoice history, and whatever internal authorization exists for each payment. The chaos and patterns shown in these emails suggest there may be plenty of unauthorized — or improperly authorized — Flock payments out there.

Flock Forward tickets are $350 per attendee. The event is not publicly livestreamed. As its “LPR” product receives mounting criticism, the conference is expected to focus on products like the “Perimeter Pro” security trailer, Flock911,^[1] and, undoubtedly, drones.^[2]

Flock has been under increased pressure from civil rights groups, and the company has not shied away from using increasingly aggressive language in response. Its CEO Garrett Langley has called DeFlock a “terroristic organization” that is “closer to Antifa than anything else” in an interview with Forbes. In a December email to police customers, he said Flock and police are “under coordinated attack … from the same activist groups who want to defund the police, weaken public safety, and normalize lawlessness,” and that those groups are “trying to turn a public records process into a weapon against you and against us.”

As for haveibeenflocked.com: Flock told 404Media the site “is doxxing cops during active investigations” and implied it is run by “activists trying to let murderers go free.” Flock has also tried to deplatform the site, claiming it “poses an immediate threat to public safety and exposes law enforcement officers to danger” and hosts “searchable databases that expose critical operational intelligence.”^[3]

This kind of language, where critics are painted as terrorists and watchdog sites as cop-doxxers, is especially concerning given the federal government’s actions in the past year. The recent 30-year sentence for transporting “terrorist” zines, and terrorism and RICO charges for activists opposing the construction of “Cop City” in Georgia, suggest Flock’s language goes beyond mere hyperbole.^[4]

Matt Eversmann, for his part, does not appear to have a public stance on mass surveillance (yet). In 2023, he and James Patterson did publish the pro-police book Walk the Blue Line: They Walk the Line between Life and Death. Eversmann’s booking page says he “shares lessons on leadership, courage, and responsibility, drawing from his extensive experiences to inspire and educate audiences.”^[5]

The keynote itself will show whether Flock hired him to pitch a particular product, or whether they are putting him on stage in a more general attempt at “hero washing” — to project apparent authority from a company undergoing a legitimacy crisis.

Flock is no longer just talking like it’s at war; it is putting an urban-combat veteran on the stage. While the federal government wins terrorism convictions against protesters and frames its enforcers as warriors under attack, Flock casts its own critics as an enemy force and its police customers as under siege.

Against this backdrop, a keynote from the man who led soldiers through the streets of Mogadishu pins a Bronze Star on that narrative.

If that concerns you, support haveibeenflocked.com^[6] and organize in your own city: DeFlock’s National Week of Action against ALPRs runs August 16–22, wrapped around Flock’s own Flock Forward 2026 (August 18–20, Atlanta), wherever people like you are organizing for civil liberties.

Flock, and other pro-mass surveillance parties, will present Chatrie as reaffirming the one cited line from Knotts. I don’t doubt that they have a blog post in the making highlighting this paragraph from Chatrie:

… another feature of Knotts makes it inapt here: that the surveillance there was confined to public roads. That fact was crucial to the Court’s decision: “A person traveling in an automobile on public thoroughfares has no reasonable expectation of privacy,” Knotts explained, because the car is always “in plain view.” 460 U. S., at 281. By contrast, the movements that Location History reveals are not limited to public streets. Recall what Carpenter observed: A “cell phone faithfully follows its owner beyond public thoroughfares and into private residences, doctor’s offices, [and] political headquarters.”

This line of reasoning is somewhat similar to the District Court’s finding in Schmidt v. Norfolk, based on Carpenter, and it’s pretty much what informed Flock’s oft-repeated “we don’t track people” line.

The argument by itself is persuasive enough, but it can only work if you disregard the rest of the Chatrie opinion as well as Beautiful Struggle.

As yesterday’s post also conceded, Knotts is not wrong, per se. Nobody is making the argument that a single observation of a vehicle on a public road does not pass constitutional muster. But that’s not what the search in Chatrie is about — in Chatrie, nobody argues that the observation and collection of the location history data (by Google) was unconstitutional. The Supreme Court never asks, let alone answers, that question. Both Chatrie and Carpenter found a search occurred when the government accessed a pre-compiled, retrospective database containing location history data.

Both Google and Flock are private companies. A private company collecting a user’s location or taking a picture of a vehicle on a public street is not by definition unconstitutional, nor is aggregating that information in a national database. To be clear: I believe Flock deployments generally aren’t legal, but my objections to the cameras themselves are largely statutory, not constitutional.

In Carpenter, the court examined the government’s access to a historical database: the phone company may have collected years worth of data, but the government’s act of looking at 7 days of CSLI records triggered the Fourth Amendment. In Chatrie, the court works through the reasons why location history is private and not voluntarily disclosed (in any real sense), before writing: “we hold that police officers invade a cell-phone user’s reasonable expectation of privacy when they access his Location History.” (emphasis added)

It then restates the same holding: “When the government ‘accesses historical cell phone’ location information—Location History as much as CSLI—it ‘conducts a search under the Fourth Amendment.’”

Access, not collection. Even if the collection — the observation and recording of a vehicle traveling on a public street — would be legal under Knotts, it’s the government’s access of the retrospective database that creates the search under both Carpenter and Chatrie.

That distinction holds even if we were to assume that Flock’s retrospective database contains only observations permissible under Knotts — which is something we know not to be true, because deployments on private property exist, but is a fact that plaintiffs in Schmidt may have conceded.

But, for the sake of argument, let’s say when the Supreme Court wrote about “access” they really meant to include something about the location where the data was collected.

Beautiful Struggle^[1] held that the compilation of retrospective data itself “is enough to yield ‘a wealth of detail,’ greater than the sum of the individual trips”, and “because people’s movements are so unique and habitual, it is almost always possible to identify people by observing even just a few points of their location history.” The court in Beautiful Struggle agreed you can infer a lot of information from a historical database; those inferences fall outside of what is exposed to the public and would be observable under Knotts.

The Fourth Circuit did not treat that conclusion as its own intuition; it drew the principle from the Supreme Court itself, quoting Justice Sotomayor’s observation in Jones that people do not expect “that their movements will be recorded and aggregated in a manner that enables the government to ascertain” the details of their private lives.^[2]

It’s also an argument plaintiffs made in Schmidt, and the one Flock attempted to rebut on a redacted page with (only) the heading “The Flock Camera Data Does Not Enable an Individual to ‘Infer’”. But the District Court found that the data does allow inference of certain aspects of life. The District Court also found that the inference was not enough to trigger a search, but Chatrie now rejects that quantitative test:

… this Court has never understood Fourth Amendment protections as kicking in only once an intrusion “goes too far,” Where the Fourth Amendment applies, it applies regardless of “the quality or quantity of information” the government obtains. That approach makes all the more sense when, as with Location History, law enforcement officials can select the time-limited set of materials they want from an all-encompassing database.

The record in Schmidt shows that capacity to infer exists: plaintiffs’ expert found Flock captured 78.7% of modeled routes, most of them reconstructable because they pass two or more cameras — exactly the ability to rebuild a person’s movements that, under Beautiful Struggle, makes those inferences possible.

Flock’s headline takeaway will be that the 1983 Knotts case about tracking a beeper in a car still stands. The Fourth Circuit should conclude, as they did in 2021 in Beautiful Struggle, and as the Supreme Court did yesterday in Chatrie, that the correct answer to that is: “so what?”

Flock’s best argument has always been that all it does is photograph the back of a car. But under Chatrie, data collection is not the search. The search happens when the government delves into the database built from the photographs — and into everything it lets them deduce.

Forty years ago, Knotts was about watching a car’s location on a road; now, Chatrie and Beautiful Struggle are about accessing location histories. The fight is moving into the 21^st century: from cars and cameras to databases and computer analysis. That’s the seismic wave Alito fears. Flock should too.

@Brief for Amicus Curiae

For the most part, the brief follows Flock’s primary argumentative strategy: if a single observation in public is legal, then all observations in public must be legal. It is a simplistic argument that falls apart under any scrutiny — after all, crimes like stalking and harassment exist. It’s legal to follow a car on the highway, but that doesn’t automatically mean it’s legal to follow your ex’s car to the office, soccer practice, and their therapy appointments.

There’s misdirected effort here, too. The brief’s first argument — pages 6 through 11 — labors to prove that a driver has no privacy interest in a license plate sitting in plain view. No one said otherwise. The plaintiffs concede the point, and the brief quotes the concession on page 12: they “don’t challenge the isolated use of ALPRs for capturing license plate numbers,” only Norfolk’s aggregated, city-wide use.

The fact that Flock has created a nationwide database is barely discussed. That is not so much an omission in the brief, but a result of the plaintiff barely raising it in the petition. The Institute for Justice’s case in San Jose, CA, takes a similar approach. The Supreme Court places weight on the scope of the tracking; it’s a test that might be easier to satisfy with the nationwide network, but the IJ rightly argues even a city-wide network exceeds the Constitution’s limits.

Regardless, the amici states raise the nationwide network. The article cited in the brief’s third footnote is even headlined “For the Most Part, We Can Track You All Over the Country.” That piece is generally critical of LPR deployments in South Carolina, and, beyond its headline, contains lines like “[Flock] does not explain how the data is deleted.” and “Merely by driving a car with a license plate, people are often unwittingly entered into massive databases that are then shared, Bowers said.”

But the nationwide network is not the only point the “one scan is legal” argument glosses over. Another point the brief references in a citation but skips is the one made in Beautiful Struggle: that of data retention. The brief concedes 21-days of data retention, the maximum under Virginia law^[2]. To understand why this is so relevant, we have to look at the states’ and Flock’s talking point, lifted from Carpenter, about “the whole of an individual’s movements.”

In Carpenter, which was about cell phone (“CSLI”) records, the Supreme Court looked at how much information could be obtained from cell phone records and found that it was the whole of a person’s movements. The District Court in Schmidt found that tracking by ALPR didn’t go quite as far as cell phone or ankle monitor tracking would have, and therefore it did not meet that definition.

But that ignores Leaders of a Beautiful Struggle v. Baltimore Police Department, a case the states do cite in their brief, where the court held that because of the 45 day retention, BPD created a “detailed, encyclopedic” record of movements (emphasis added):

Carpenter applies squarely to this case. More like the CSLI in Carpenter and GPS-data in Jones than the radio-beeper in Knotts, the AIR program “tracks every movement” of every person outside in Baltimore. Because the data is retained for 45 days—at least—it is a “detailed, encyclopedic,” record of where everyone came and went within the city during daylight hours over the prior month-and-a-half. … AIR data is more like “attach[ing] an ankle monitor” to every person in the city. “Whoever the suspect turns out to be,” they have “effectively been tailed” for the prior six weeks. (“[P]olice need not even know in advance whether they want to follow a particular individual, or when.”). Thus, the “retrospective quality of the data” enables police to “retrace a person’s whereabouts,” granting access to otherwise “unknowable” information.^[3]

We do not suggest that the AIR program allows perfect tracking of all individuals it captures across all the time it covers. … Still, the program enables photographic, retrospective location tracking in multi-hour blocks, often over consecutive days, with a month and a half of daytimes for analysts to work with. That is enough to yield “a wealth of detail,” greater than the sum of the individual trips. It enables deductions about “what a person does repeatedly, what he does not do, and what he does ensemble,” which “reveal[s] more about a person than does any individual trip viewed in isolation.” Carpenter held those deductions go to the privacies of life, the epitome of information expected to be beyond the warrantless reach of the government. And here, as there, the government can deduce such information only because it recorded everyone’s movements.

— Leaders of a Beautiful Struggle v. Baltimore Police Dep’t, 2 F.4th 330, 341–42 (4th Cir. 2021)

The Carpenter Court found seven days sufficient history to bring it into the territory of a constitutional search: “It is sufficient for our purposes today to hold that accessing seven days of CSLI constitutes a Fourth Amendment search …”. Beautiful Struggle said 45 days, even without perfect tracking of individuals, was sufficient, and that the picture was “greater than the sum of the individual trips”. Norfolk’s tracking of individual trips over multiple weeks and the 21 day retention period falls neatly in between Carpenter and Beautiful Struggle.^[4] The District Court’s finding that this would not be a search is plainly the outlier in the series.

The brief also contains an interesting technical wrinkle: its citation of United States v. Chatrie, 107 F.4th 319 (4th Cir. 2024). That’s a citation to the panel opinion, which was vacated in November of 2024, when the 4th Circuit (where this brief was filed) granted an en banc rehearing. The proposition they cited the case for (that geofence searches are not “searches” under the Fourth Amendment) does not exist in the April 2025 en banc opinion at all.

Even worse for the states and their brief, that en banc opinion in Chatrie was vacated by the Supreme Court today (June 29, 2026). Chatrie is a cell-phone case, so it does not decide the ALPR question directly but the reasoning leaves the states no room. The Court held:

Police officers conducted a Fourth Amendment search when they acquired Chatrie’s location data from Google because an individual has a reasonable expectation of privacy in his cell-phone location information.

And, in the line that lands hardest on this brief’s “it’s only a few data points” arithmetic:

… this Court has never understood Fourth Amendment protections as kicking in only once an intrusion “goes too far” … Where the Fourth Amendment applies, it applies regardless of “the quality or quantity of information” the government obtains. That approach makes all the more sense when, as with Location History, law enforcement officials can select the time-limited set of materials they want from an all-encompassing database.

The brief also cites Knotts^[5] throughout — this is a 1983 case which directly undercuts the brief’s main argument. The quote given is “A person travelling in an automobile on public thoroughfares has no reasonable expectation of privacy in his movements from one place to another.” The more relevant quote from the next paragraph is omitted:

Respondent does not actually quarrel with this analysis, though he expresses the generalized view that the result of the holding sought by the government would be that “twenty-four hour surveillance of any citizen of this country will be possible, without judicial knowledge or supervision.” But the fact is that the “reality hardly suggests abuse,” Zurcher v. Stanford Daily; if such dragnet type law enforcement practices as respondent envisions should eventually occur, there will be time enough then to determine whether different constitutional principles may be applicable. Insofar as respondent’s complaint appears to be simply that scientific devices such as the beeper enabled the police to be more effective in detecting crime, it simply has no constitutional foundation. We have never equated police efficiency with unconstitutionality, and we decline to do so now. — United States v. Knotts, 460 U.S. 276, 283–84, 103 S. Ct. 1081, 1086, 75 L. Ed. 2d 55 (1983)

The Court found that the existence of tracking technology did not violate the Constitution — and it expressly reserved the question of whether deploying that technology as a “dragnet” would.

The efficiency line is interesting, because the states argue it backwards here. In Knotts, it was the defendant who argued that efficient, technology-driven surveillance was unconstitutional. The Court turned that down flat: it has “never equated police efficiency with unconstitutionality.” Efficiency isn’t the test. The states now run the mirror image — uphold our surveillance because it works — and Knotts disposes of that just as fast. Effectiveness doesn’t decide the question in either direction.

The states’ strongest appellate authority has its own fit problem. They lean on United States v. Gregory, an Eleventh Circuit case, for the idea that automatic, nonstop cameras raise no Fourth Amendment concern. But Gregory is a pole-camera case: fixed cameras pointed at the outside of one house during a drug investigation. Trying to apply it to the 176-camera grid wired into a nationwide database asks a case about a single stationary camera to answer the dragnet question Knotts left open.

The Gregory panel wasn’t even fully sold — a concurring judge cautioned against assuming the public-view doctrine “immunizes pole cameras regardless of the length of time they record,” and noted that the Eleventh Circuit’s parallel reasoning about cell-site data was exactly what the Supreme Court threw out in Carpenter.

The Justices rejected that efficiency rationale head-on, in another case the states cite:

We cannot deny that our decision today will have an impact on the ability of law enforcement to combat crime. Cell phones have become important tools in facilitating coordination and communication among members of criminal enterprises, and can provide valuable incriminating information about dangerous criminals. Privacy comes at a cost. … Our cases have historically recognized that the warrant requirement is “an important working part of our machinery of government,” not merely “an inconvenience to be somehow ‘weighed’ against the claims of police efficiency.” Coolidge v. New Hampshire, 403 U.S. 443, 481, 91 S.Ct. 2022, 29 L.Ed.2d 564 (1971). — Riley v. California, 573 U.S. 373, 401, 134 S. Ct. 2473, 2493, 189 L. Ed. 2d 430 (2014)

In all, the states’ two arguments are: (1) a single capture is legal, therefore all captures are legal; and (2) Flock’s LPR network makes police more “efficient.”

Neither argument actively engages with the facts of the case, which are about a city-wide mass surveillance dragnet with long-term historic data collection and warrantless searches of that data. If these are the best arguments the Attorneys General for sixteen states and DC can muster, and with the Chatrie decision in the bank, Schmidt may continue to be an interesting case.

Copp used the Flock license plate readers to track the ex-boyfriend 140 times; 86 of those alleged uses occurred while Copp was off duty, prosecutors said. Copp also allegedly called the man and told him to have no contact with a woman with whom they both had been romantically involved.

Confirmed instances of abuse are always interesting because they can tell us what it actually looks like in audit files. Unsurprisingly, it looks exactly as you’d expect.

While we don’t (at this time) have audit logs from Prairie Grove, we do have network logs from nearby Illinois agencies. Any area-wide searches done should appear on the Prairie Grove IL PD agency page. They do.

The summary at the top of that page reads:

We have seen a total of 2,993 searches for this agency, performed by 2 persons over 600 days between 8/7/2024 and 3/30/2026.

That “2 persons” is doing a lot of work. Exactly one operator name survived Flock’s redaction — “M. Goi.” Active on a single day in August 2024, using one case number. The other 2,984 searches are stripped to ***: Flock deleted every operator name and every license plate. The “2 persons” could be two or twenty.

This makes it nearly impossible to detect abuse. Nearly.

Of those 2,993 searches, roughly seven in eight — about 2,600 — carry the reason “Training” or “test” and all were conducted between June 4 and November 2, 2025. Each search touched around 470 networks. The reason, over and over: “Training.”

Prairie Grove conducting its training on live data should be an immediate red flag; a live national surveillance database shouldn’t be receiving “training” or “test” queries. Every search should be for a valid reason, and that reason should appear in the logs — at least that’s what we’re being told by Flock and police departments.

The Non-Criminal Report on this site attempts to track use of the Flock system for purposes other than criminal investigations. Some searches in that report are civil matters or things like traffic planning, but most of the entries are “Training” and “test.”

That report has been there for a while. But more importantly, over 450 networks had been receiving stripped-down log files showing that Prairie Grove IL PD was running “training” on live data — week after week, hundreds of times a month, from (at least) June into November 2025. Roughly seven of every eight searches the agency made.

The last “training” search was November 2, 2025. Three days later, on November 5, Prairie Grove placed Copp on administrative leave. After that, the “training” stops, and what’s left is ordinary police work — stolen autos, hit-and-runs, citizen assists. Including, on January 13, 2026, a cluster of searches tagged “Stalking — Copp Internal Issue.”

For the five months the “training” ran, none of the agencies for those 450-plus networks raised the alarm. Neither did Flock.

The reporting doesn’t say what moved Prairie Grove to look. The department offers only that its investigation began “in November”; the McHenry County Sheriff says his office had no involvement; Flock says nothing. And the one victim whose account is public didn’t surface it either. By his own January 2026 petition, an investigator contacted him — he was told about the surveillance, not the other way around — and his request for an order of protection was denied:

Early this year, a man sought an order of protection against Copp, claiming that Copp had looked up the man’s license plate using a license plate reader system 178 times between September and January, court records show. The man’s request for an order of protection against Copp was denied.

Prosecutors also date Copp’s misconduct to February 2024. Even 2,600 “training” hits over five months is only the part we can see.

This should have been easy to catch. Seven of every eight searches an agency runs, labeled “training,” month after month. It would have been easier still had Flock not deleted Copp’s name and his victim’s license plate number from the logs — deletions that make it hard to detect prolonged surveillance and possible stalking.

That hundreds of departments failed to see or act on evidence they had is bad. But it’s also the inevitable result of the “transparency” model Flock sells, where the only party who can see the complete picture is the vendor with no incentive to look.

The product works as designed: it’s surveillance watching everyone except who runs it.

The announcement came after a routine audit revealed that out-of-state and federal agencies made queries into SFPD’s Flock license plate reader cameras network, despite state law prohibiting exactly this. … The data was originally queried by the Northern California Regional Intelligence Center, which then shared information with the Western States Information Network. It was through these two entities that out-of-state agencies were able to make requests.

Gasp.

KALW puts the scale at nearly 300 improper queries into San Francisco’s network in the past year alone. SFPD can’t say what actually went out the door. Chief Derrick Lew said at the Police Commission meeting:

“A query is just that. It’s checking our system to see if there was an actual return,” said Lew. “We don’t know of those queries what generated a real hit, therefore, we don’t know what was actually disseminated.”

The San Francisco Standard reported the same audit, noting SFPD waved off the 299 queries as 0.005% of its total. The Standard’s 2025 reporting documented more than 1.6 million out-of-state searches of the city’s data, at least 19 of them flagged as ICE-related. SFPD now insists no outside agency ever had direct access to its system.

The law is not ambiguous: a California public agency may not sell, share, or transfer ALPR data except to another public agency.^[1] And the statute defines “public agency” narrowly: the state and its cities, counties, and political subdivisions.^[2] Out-of-state and federal agencies are not on that list. Neither are private RISS corporations, like WISN.

Even if NCRIC — which brands itself a government program — were to meet the definition of “public agency,” the data did not stop there. It went to agencies that are definitely not “public agencies” under California’s definition. Laundering the data through a fusion center does not change that. That is the whole shell game.

And it was not a leak. Per the Standard, NCRIC handed WSIN’s Watch Center access to San Francisco data during overnight hours, without telling SFPD. The analysts running those queries were simultaneously searching the databases of between 531 and 763 other agencies — one search, hundreds of jurisdictions, at once. That is the product working exactly as designed.

None of this is news to anyone who was paying attention — which, apparently, did not include SFPD.

In July of 2025, The San Francisco Standard identified the same data-laundering problem, specifically in San Francisco, in “California cops are breaking surveillance laws. Who’s going to stop them?,” quoting EFF:

"It’s the fruit of the poisonous tree,” said Adam Schwartz, privacy litigation director at the Electronic Frontier Foundation. “I don’t think judges like these kind of shenanigans, where the cops are saying, ‘But judge, we didn’t give them the ALPR information; we took the ALPR information, made it into new information, then gave them that information.’”

In February, 2026, I published “The Northern California Fusion Center: A High School Case Study,” which laid out both NCRIC and WSIN. In March, I wrote “Flock promises to implement logging feature it claimed existed,” documenting Flock’s deficient practices — a lack of meaningful logging, and its habit of talking its way around any commitment to comply with California’s ALPR laws.

A few weeks ago, students writing for Carlmont High’s Scot Scoop student paper published “Smile, you’re on Flock: Inside San Mateo County’s expanding surveillance system.” Their story mapped the exact pipeline in San Mateo County that just burned SFPD:

Of the cameras Scot Scoop identified in San Mateo County, the majority of operating agencies, including the San Mateo County Sheriff’s Office and police departments in Atherton, Colma, Hillsborough, Menlo Park, Pacifica, Portola Valley, Redwood City, and San Mateo, share data with the NCRIC, which is a multi-jurisdictional “fusion center.” … That means a license plate in Redwood City can be searched not just by Redwood City officers or the other agencies listed in the city’s Transparency Portal, but also by hundreds of other agencies plugged into the NCRIC network.

Dozens of publications, from a high school paper to the SF Standard, figured this structure out and published it. Privacy advocates and organizations like the EFF and the ACLU talked about it. Multiple ongoing civil suits allege exactly these violations. Countless public comments flagged these problems to elected officials at hearings across the Bay Area and beyond.

After all that, SFPD cracked the case all by itself — during what was either the first routine audit it has ever run, or through some stroke of luck as it bumbled through the most recent repetition of the same audit that routinely failed to reveal this glaringly obvious problem for months, if not years.

Either way … what happens now that they’ve “found” it? Termination is an option. After federal agencies turned up in its network, Mountain View’s council voted unanimously to kill its Flock contract for good; Los Altos Hills cut ties entirely, and Santa Clara County barred its sheriff’s office from touching Flock data. SFPD won’t follow. KALW figures the department won’t terminate its contract, and Chief Lew told the Commission that ALPR has become “a cornerstone of our work.”

Instead, SFPD will probably slap some policies together, call them “guardrails”, and continue to allow Flock to collect data in San Francisco, just as they did after the 1.6 million searches were discovered. In a few months, or maybe years, we’ll be right back to high school papers doing better investigative work than the SFPD can muster with its $849M budget.

Even now, there is no chance that the people who stood by and allowed these violations of law to happen will see any consequences. At most, the city will have to pay someone (mostly lawyers) a bunch of money, and that money will not come out of the police budget.

That’s what “law enforcement” really looks like.

The grant in question is an Edward Byrne Memorial Justice Assistance Grant (JAG).^[1] In Iowa, these grants are administered by the Department of Public Safety (DPS) Office of Drug Control Policy (ODCP). JAG funds can pay for equipment and services, including for criminal justice information systems (CJIS)^[2] and criminal intelligence systems (CIS).^[3]

Story County told ODCP it was purchasing license plate reader cameras. The grant required Story County to comply with the federal regulations for these types of system, and it required Story County to have policies in place before purchasing any equipment.

Expressly listed is a special condition:

Project is required to have established policies and procedures in place regarding the appropriate use of technology and data security/privacy prior to purchasing grant supported technology.

@Approved Grant with Terms

DPS/ODCP approved the grant, but Story County did not use it to buy any equipment. It did not adopt the necessary policies. It did not execute the necessary security addendum. It did not collect the required certifications.

Instead, Story County used the money to enter into a software-as-a-service contract with Flock.

I certify that the program in this application meets all the requirements of the Omnibus Crime Control and Safe Streets Act of 1968, as amended; that all the information presented is correct; and the application will comply with the provisions of the Act and all other Federal laws, regulations, and guidelines. — Story County, January 9, 2024

Then Story County sent an invoice and a check for the “purchase” of cameras to ODCP, and ODCP reimbursed the amount requested. Throughout this process, ODCP does not appear to have required a final inventory report, or even received — let alone read — the Flock contract, under which Flock keeps ownership of the hardware and the county pays only for access to a hosted service.

@DPS/ODCP JAG Grant printout

DPS Finds Non-Compliance, Then Unfinds It

The CJIS Security Addendum, which I’ve discussed often, is a critical part of CJIS compliance. It is attached to a service contract and contractually binds the employees of the service provider (Flock) to adhere to federal CJIS regulations and policies. It’s the official, FBI-sanctioned method of allowing private parties access to sensitive data.

Story County did not execute a CJIS Security Addendum with Flock. This means Flock was not contractually or legally bound to keep any CJIS data it received secure. It could send it abroad, or hold it in insecure, non-compliant software.

DPS’s own CJIS staff knew. In an internal email on October 6, 2025, the Department’s CJIS Compliance Officer, Rebecca Dyer, wrote that “CJIS language was not present in the contract” between the county and Flock — and began assembling the documents the county was missing (more on that below).

I had filed a CJIS complaint with the Department on September 30. Its Director of Investigative Operations, Paul Feddersen, reviewed it and transferred it to the Department’s Program Services Bureau — home of Iowa’s FBI CJIS Systems Officer. On October 14, that officer, Rusty Ringler, confirmed in writing:

Following a review, the Department identified missing or incomplete addendums/agreements requiring attention on the part of the Story County Sheriff’s Office and Flock Safety. These items would typically be identified in a triennial audit conducted by our CJIS audit team, and the agency would be given an opportunity to remediate prior to escalation.

The Story County Sheriff’s office is not scheduled for [its] triennial audit until next year, but we have begun working with them to identify and address areas of concern.

In other words, the conditions for the grant were never met. There was no “purchase” of any equipment. There was no compliance with the federal regulations — least of all before the grant was awarded.

ODCP, however, had already decided otherwise. The day before Ringler’s email — on October 13 — ODCP Bureau Chief Susie Sher wrote:

As the pass-through entity for Iowa’s portion of federal Bryne-JAG funds, ODCP alone is responsible for determining cause for disallowing costs and recouping funds. After a thorough review, ODCP believes this complaint is unfounded and does not find cause to disallow the expenditure of funds for this purpose.

So: DPS’s CJIS compliance officer flagged the missing CJIS language on October 6. ODCP called the complaint “unfounded” on October 13. DPS’s CJIS Systems Officer put “missing or incomplete” in writing on October 14. One department, three divisions — two of them confirming the gap on either side of the third declaring it imaginary. ODCP did not provide any further explanation.

DPS After Dark

Behind the scenes, much more was happening. Story County and DPS had a phone meeting, contents unknown, which in turn produced a set of email exchanges between ODCP Bureau Chief Susie Sher, Marylin Mosinski (Communications Operations Manager, Story County Sheriff’s Office) and Rebecca Dyer (Iowa DPS CJIS Compliance Officer).

On October 6, DPS and ODCP staff began supplying Story County the documents that should already have existed. That morning at 10:52, Mosinski emailed DPS about a form she couldn’t identify:

There is also one more form that was mentioned during the FLOCK FOIA request phone call that will be needed for the next audit. Could we get a copy of that as well so that we can get it signed with all the other forms? We aren’t sure what that one is called…

Dyer replied:

Since FBI CJIS language was not present in the contract signed with your agency and FLOCK, an Amendment needs to be signed between the Sheriff’s Office and FLOCK to meet CJIS requirements; this document is labeled IDPS CJIS Security Amendment.

Minutes later, at 11:03, Dyer sent the templates and assigned who would sign what:

Good morning Marylin- Please see the attached documents. Below I noted who needs to be involved with certain documents. … Amendment: Flock and Story County Sheriff’s Office / Agency User Agreement: Story County Sheriff’s Office / MCA: Story County IT and Story County Sheriff’s Office

A couple of weeks later, on October 22, Mosinski wrote to Dyer:

Command would like me to change the wording on the MCA so it better reflects who is signing. Since you sent me the copy in word format, I can make those changes myself but want to check in with you.

In essence, there isn’t too much wrong with DPS’s CJIS division helping a sheriff’s office come into compliance. But non-compliance in October 2025 means non-compliance at the time the grant was certified and awarded in 2024.

It is also worth noting that Mosinski did not receive the templates until October, yet the executed CJIS amendment carries a September 15 date:

Auditors and Oversight

In 2024, Story County certified compliance, on federal forms, to obtain a federal benefit. Certifying compliance that does not exist, on a federal form, to draw federal money is the kind of conduct that carries federal criminal exposure for ordinary people.

ODCP, the agency that administers these federal funds, dropped the ball at every point. It should at least have asked the most basic question: “what is this grant for?” The answer would have revealed that there was no “purchase” of any equipment. Standard follow-ups, such as “show me you complied with the special conditions of this grant” or “provide a final inventory report,” would also have revealed the error.

Even crediting its own CJIS division, which confirmed the documents were not in place, would have let ODCP recoup the funds and keep future grants to other agencies honest. ODCP chose to ignore its obligations under federal law instead.

The state’s last backstop is the Auditor of State. I referred the matter to Rob Sand’s office in November. On December 27, 2025, Sand replied:

Thank you kindly. For your awareness, we are generally not able to provide substantive responses. Anything we learn during the course of an audit is confidential until a release is made public. In addition to that, timelines for audit work across both the public and private sectors are longer than anyone would prefer. These are serious allegations and we will take them seriously.

That was the last I heard. Audit work is confidential, so I cannot say whether anything is underway; I can say that more than five months later, there has been no further word.

The federal backstop fared no better. In January 2026, the U.S. Department of Justice Office of the Inspector General sent the following response:

The U.S. Department of Justice (DOJ), Office of the Inspector General, investigates allegations of misconduct by employees and contractors of DOJ, as well as waste, fraud and abuse affecting DOJ programs and operations. After reviewing your complaint, we have determined that the matters that you raised are more appropriate for review by another office within the DOJ.

@OIG Response

And that was the last I heard of that.

The Grants Will Continue

It reinforces a pattern seen over and over in Iowa and other states: police agencies and their preferred vendors are free to ignore laws, rules, and regulations. Even though both the county and DPS now acknowledge non-compliance — long after certifying that they were compliant — there are no consequences for certifying compliance that never existed, or for accepting those certifications to release federal funds.

ODCP does not enforce its own grant terms. DPS’s CJIS division identified the non-compliance but treats it as a remediation project rather than a breach. And the Department’s investigative side, handed a complaint about the same conduct, passed it along rather than pursue it.

The amount for this specific grant is small, but ODCP is just one state agency in Iowa, and grants for intelligence systems are common. Grants for “organized retail crime” and other purposes are even more so.

The following are intelligence-systems grants awarded by DPS, presumably under much the same terms as Story County’s grant:

If you are in Iowa, please take a minute to ask the State Auditor to act — he has all the evidence. If you are not in Iowa, I recommend filing some open records requests — you will almost certainly find the same thing where you are.

In the meantime, when reading about criminal charges for improper certifications on federal benefit forms — like those for SNAP or Medicaid — take a minute to consider what happened in Story County and how it reflects on the word “law enforcement.”

@Eldridge plaintiffs’ response (consolidation, leadership, and the preservation record)

The line comes from an April letter by Flock’s lawyers, written to fend off the suggestion that Flock had let evidence slip away. To justify keeping a smaller slice of data going forward, Flock told the plaintiffs that most of what it collects doesn’t matter:

… Flock’s ALPR system captures over 130 data fields, the overwhelming majority of which—fields relating to bumper stickers, roof racks, window stickers, vehicle pose, and the like—are wholly irrelevant to a lawsuit that concerns whether Flock posted an adequate usage and privacy policy and whether federal or out-of-state law enforcement agencies had unauthorized access to the ALPR data of California public entities.

@Flock’s April 8, 2026, letter

California doesn’t carve out a “doesn’t matter” exception. Its ALPR law defines the regulated information about as broadly as language allows:

(b) “Automated license plate recognition information,” or “ALPR information” means information or data collected through the use of an ALPR system. — Cal. Civ. Code § 1798.90.5

If Flock’s system collects it, it’s ALPR information — plates, colors, the contents of bumper stickers, and whatever the other hundred-odd fields hold. And California requires every ALPR operator to publish a usage-and-privacy policy spelling out what it collects, why, how it keeps that data accurate, and how it secures it. (Cal. Civ. Code § 1798.90.51.)

In February, a California appeals court held in Bartholomew v. Parking Concepts that running ALPRs without a compliant policy is itself the harm — no need to prove your data was ever misused or shared. Flock’s exposure doesn’t hinge on catching it red-handed but on whether its published policy completely and accurately describes what the system does.

It doesn’t. Flock’s published License Plate Reader Policy (last updated November 2025) lists eight kinds of data: a plate image, a vehicle image, vehicle characteristics like color and make, the plate number and state, and the date, time, and camera location. In court, Flock admits to more than 130 — and in its settlement proposal it agreed it “would not deny that it collects other information, such as bumper stickers and roof racks.” Flock admits collecting this ALPR information that appears nowhere in its policy.

@Flock’s April 14, 2026, email

That gap is enough to establish the violation, but it still can’t measure it. The plaintiffs also bring privacy claims, including the tort of intrusion upon seclusion, and those turn on how offensive the surveillance is. Offensiveness is judged by the manner, scope, and aggregation of what’s collected, not by whether any single detail was visible from the street.

Which is exactly why “wholly irrelevant” is posturing. Flock wants the court to agree these fields don’t belong in the case, so it only has to keep and hand over a narrow set. One group of plaintiffs’ lawyers, trying to save some data, has been willing to take that deal. If the deal goes through, Flock gets to produce tidy “samples” that will almost certainly leave out the “offensive” parts.

We know Flock users have run searches for things like “star of david” and “red corvette with cross sticker on rear window”. If I were a court considering “offensiveness”, I’d want to hear about a database of religious expressions being built by snapping pictures of people headed to the grocery store and subsequently sold to the government.

Flock says preserving what it collects on Californians would mean “petabytes of data that no one could use.” Petabytes is the scale of a system that photographs ordinary people running errands and records a hundred-some attributes of each car, over and over, across the state. Flock wields the amount of data it collects as a defense. But the bigger the amount of data collected, the more offensive the surveillance, and the more it’s worth, in real judgment dollars.

But that offensive defense is a misdirect. Flock won’t produce even a plain account of what the fields are and how the search tools work. It brushes off requests for “data dictionaries and data maps” as pointless. Most of the decade of data Flock collected is already rotated out on a thirty-day-to-one-year clock; transient petabytes continue to cycle through Flock’s system, but that doesn’t preclude the question of how much and what types of data have already been collected, sold, and deleted.

Looking at the policy itself, it is conspicuously selective about accuracy — another element required by California law. The policy promises that low-confidence plate reads aren’t passed along, and concedes plate translation “may be incomplete or inaccurate” but says nothing about the accuracy of the other fields — including color, which it collects and sells.

In October 2025, a Volusia County, Florida woman spent more than two weeks in jail after Flock got the color of her car wrong. (For what it’s worth, Flock boasts that its system can tell a motorcycle from a semitruck about 92.3% of the time.)

The plaintiffs, for their part, are still trying to figure out who runs the case; the competing motions go before the court on June 25. The split is basically the one above: triage down to the data that identifies class members and move fast, or fight for the broader fields that show how far the system actually reaches.

The firm pushing hardest to let the broader fields go is, as it happens, the same one whose signature courtroom win helped establish that personal data has real value as data. Reasonable people can disagree about what to save when the clock (and the legal bill) is running. But trading away the most revealing evidence to lock in a quicker, smaller win may not be the best play.

The disclosure failure has always done double duty for Flock: hide what the system collects, and dodge enforcement when no one knows to ask. Now Flock wants it to pull a third shift — wall the undisclosed fields off from the one proceeding built to drag them into the light.

It’s genuinely a bold strategy, Cotton. Let’s see if it pays off for them.

The latest available information indicates the department holds a contract with Flock for a single LPR camera, one PTZ camera, and twenty-nine Raven “gunshot” detectors.^[1]

HaveIBeenFlocked.com typically limits itself to analyzing LPR logs and license plate queries — not because the other logs the system produces aren’t interesting, but because the site wasn’t built to ingest them automatically. When one resident examined Dunwoody’s event logs, his analysis showed Flock employees were watching children inside a community center. Thousands of other, unexamined logs exist.

The event log analyzed here was obtained from New Castle PD through a Pennsylvania Right-to-Know request; the request and released files are on MuckRock. It runs from June 28, 2023 through April 27, 2026 — nearly three years — and includes detailed hotlist entries, network sharing, and configuration updates.

The Hardware

New Castle PD’s Flock account includes 31 active devices. Most of them — 29 — are Raven units, Flock’s acoustic detection sensors.

All 31 devices — the ALPR, the surveillance camera, and all 29 gunshot detectors — are located in or immediately adjacent to census tract 42073000400.

That tract has a population of 1,776. It is the only census tract in New Castle where white residents are not a majority. Its demographic profile compared to the rest of the city:

Tract 42073000400 has the highest Black population share in Lawrence County by a wide margin. The next-highest tract in New Castle is at 18.9%. The city’s whiter, more suburban tracts — most with Black populations under 5% — have no Flock devices at all.

The other two devices are:

• One Falcon (ALPR): #01 Lowery St @ W Falls St SB — the department’s only license plate reader, with live video and vehicle description alert capability.
• One PTZ (connected via Wing): C001 W North St Park PTZ — a pan-tilt-zoom surveillance camera at W North Street Park, capable of live streaming and free-form visual search of people.

Both face the same basketball court.

The watchlists: private, undocumented, and tracking individuals

Flock’s event log records when anyone creates or modifies a custom hotlist. These hotlists — which can be “personal” to a single Flock user or shared among many agencies — generate an alert whenever a tracked plate is spotted by any camera on the Flock network.

New Castle PD officers maintain two categories of hotlists. One category is lists of plates tied to active cases, with case numbers, defined expiration dates, and organization-wide visibility. Several officers — Hailey Houk, Branddon Hallowich, Eric Kerr, Peter Mendicino — use the system this way.

The second category is different. Seven officers — Amanda Ventura, Justin Manns, Lawrence Krauss, Devin Murphey, Benjamin Cunningham, Theo Weaver, and Mark Workman — each operate a private hotlist, several of them shared among the group rather than with the department. The lists carry their operators’ own names: Ventura, Manns, KRAUSS, NCPD#23 (Murphey), cunningham, Weaver, and Workman.

Across the log, officers added 99 plate entries to those seven lists. Just four carry a case number. The other 95 do not. Twenty-eight are set never to expire.

The Ventura list is the most extensively documented: 31 entries added between March 2024 and April 2026, and not one of them carries a case number. Many give a person’s name as the sole stated reason for surveillance — entries reading Narcotics. [name] set to expire never, or narcotics, [name], also never. Others name an individual with no stated reason at all. One entry’s reason is simply Picking up kids, expiry never; another is the street address 707 S Cascade.

The expiry field is where the absence of process becomes concrete. A plate tied to an active case expires when the case closes. An entry that names a private individual and is set to expire never is a permanent surveillance designation, attached to a person, that no one is scheduled to review.

Two Ventura entries are worth quoting in full. One gives its reason as High theft probably — surveillance premised, by the officer’s own notation, on a hunch. Another gives its reason as welfare. Neither carries a case number.

The Manns list holds 34 entries over a similar period — 33 with no case number — tagged with names and terse notes such as narc complaint, Fbi narc, and homicide. It is shared with Ventura. One Manns entry inverts the form entirely: a string that looks like a case number, 24-0000082, is typed into the reason field, while the actual case field sits empty — a small sign of how loosely the structured fields are treated.

The cunningham list is the starkest: seven entries, every one with the reason narcotics, six of the seven set to expire never, and not a case number among them.

NCPD#23, Murphey’s list, tracks two Ohio plates under the reason Nephew. Richard Conti added the same two Ohio plates to a group list named Fitty a short time later — that time with a narcotics case number attached. Conti also created a vehicle description alert — a Flock feature that generates real-time notifications when a specific vehicle appears on a camera — named Nephew, targeting a blue Mazda sedan on the Lowery St ALPR during evening and overnight hours. He deleted the alert less than a minute after creating it.

Late-night camera access

The event log also records when officers opened a live view of the park PTZ camera. Of the 77 recorded accesses, the great majority fall in ordinary business and evening hours, by administrators. Every access in the small hours of the morning belongs to one of two officers: Amanda Ventura or Lawrence Krauss.

The pattern is tight. Late on December 30, 2025, Krauss opened the camera four times in roughly nine minutes, beginning at 11:47pm. Five days later, just after midnight on January 4, 2026, Ventura opened it eleven times in forty-five seconds: 12:19:01am to 12:19:46am.

The log shows what preceded that burst: at 12:04am, Krauss had added a plate, MWR4095, to his KRAUSS list, reason “Stolen”; at 12:11am, Ventura added the same plate to the department’s shared list, reason “Stolen out of NCPD”; eight minutes later she was hammering the live camera. Two officers and one vehicle, inside twenty minutes after midnight.

The pattern recurs on April 22, 2026, when Ventura accessed the camera three times between 3:52am and 4:32am. Krauss, for his part, has also shared plates into Ventura’s personal watchlist, tracking some of the same individuals.

What the department shares — and with whom

New Castle PD operates a single Flock network, “New Castle PA PD,” and its administrator, Anthony Lagnese, is responsible for the bulk of the department’s sharing of it. The log records more than 300 network shares of New Castle’s camera data, extending feed and hotlist access to over 100 named law enforcement agencies across Pennsylvania and Ohio. Recipients include the Lawrence County District Attorney, the Allegheny County District Attorney, the Montgomery County Detective Bureau, “Pennsylvania State PD,” and dozens of municipal departments as far afield as Pittsburgh, Bethel Park, and a string of eastern Ohio agencies.

In March 2026, the department’s live stream interface also surfaced a camera it had no obvious connection to: a camera that appears to be a RedSpeed automated speed enforcement camera, located on a highway in central Georgia, hundreds of miles from New Castle.

Why a Pennsylvania department’s interface surfaced a Georgia speed camera is not explained anywhere in the log. The most benign reading is also the most damning one: that Flock’s network sharing is indiscriminate enough to put an unrelated camera, in another state, into a small-city police department’s live feed by default.

This website previously documented that RedSpeed has a Flock integration. New Castle’s log entries seemingly confirm that traffic enforcement cameras can be, and are, used for live-streaming video.

What wasn’t answered

The event log does not record what happened when a tracked plate was spotted. It does not show whether the named individuals on the Ventura and Manns lists were ever stopped, arrested, or surveilled in person. It does not show whether any supervisor reviewed or approved any of the private hotlists.

That last gap is the point. Oversight of a watchlist depends on two things: a case number that ties an entry to a documented investigation, and an expiration date that forces the entry to be revisited.

Ninety-five of the ninety-nine entries on these seven lists have no case number; twenty-eight have no expiration. Even if the department wanted to audit its own use of the system — and even if it would disclose basic case information to the public — there is nothing to audit against. An entry reading welfare, attached to a named person, set to expire never, is unreviewable by design. The absence of case numbers makes oversight structurally impossible.

The only thing the logs do show is that New Castle PD pointed its only two cameras at a single basketball court, and that for nearly three years, officers have been adding entries — most of them permanent, almost none documented — to private watchlists connected to a national surveillance network, in the one neighborhood that is, by a wide margin, the most heavily Black in the county.

Through its blog, Flock says it “aims to advance both safety and equity together” through “data-driven responses.” This is what that looks like in Pennsylvania.

Q: Is this a surveillance tool?

A: No. Flock DFR only activates in response to specific calls for service — never for general patrol or surveillance. Every flight is logged, audit-traceable, and visible via a public-facing transparency dashboard, ensuring responsible use and public trust. — Flock Drone-as-First-Responder (DFR) FAQ (May 11, 2026)

When Flock was selling the project to police in November 2024, the pitch was the opposite.

@vDrones stationed throughout the city

Drone as a first responder is the concept of drones stationed throughout the city.

The 2024 demo scenario also hasn’t yet adopted Flock’s 2026 “public safety” framing. The hypothetical isn’t a murder or a carjacking, but a blocked driveway:

@vBlocked driveway framing

What we’re able to do is say there’s a blocked driveway call and it’s 10 minutes away from the nearest unit. We can launch a drone, go over there, check to see if the driveway is blocked.

The operator launches the drone, autonomously dispatches it to the call, takes manual control on arrival, and then — by his own admission — gives a “very cavalier example” of the workflow when the driveway is in fact blocked:

@vThe plate-read and distribute beat

Say the driveway is blocked, and we want to be able to hit a license plate. It is incredibly easy to do that with this platform. … We’re 400 feet in the air and 600 feet away from this. And I’ve only used 114X of the 200X of this zoom. … When I want to distribute something, I click P and it’s going to take a picture of that license plate, and then I can again text or email that to anyone I want.

From 400 feet above, in response to a blocked-driveway call, the pilot reads a California license plate from a car at the scene (42A4CC). One keystroke captures the plate as an image. One click sends it by text or email to anyone the operator chooses.

Two scenarios later he demonstrates a separate capability. When a suspect flees a vehicle on foot into a backyard, the drone overhead doesn’t describe the home — it reads the address:

@v8430 East Heathcourt

I don’t have to describe it as a red roof with tile and solar panels and a fence. I can say it’s 8430 East Heathcourt. So that’s the entire DFR workflow.

The entire workflow, per the demo:

1. A low-stakes property nuisance call comes in (blocked driveway).
2. A drone is autonomously dispatched (no officer required).
3. The drone arrives, hovers at 400 ft altitude.
4. A remote operator zooms (114x) on a vehicle at a residential address.
5. The operator reads the plate from 600 ft away.
6. One keystroke (P) captures the plate as an image.
7. With one click, it can be texted or emailed to “anyone I want.”

The workflow that is, according to Flock, not “general patrol” starts with autonomously dispatching a drone to a minor property dispute.

The workflow that is also not, according to Flock, “surveillance” ends with aerial surveillance imagery being transmitted, over an insecure channel, to anyone without constraints.

“No other technology helps law enforcement officers get eyes on the scene faster than a drone.” — Garrett Langley, CEO Flock Safety, Flock Safety acquires Aerodome to expand into drone-based law enforcement solutions, Police1 (October 16, 2024)

Aerodome Acquisition

This demo played out around the time of Flock’s acquisition of Aerodome — at the time, Flock referred to it as a “strategic partnership.” It was a $300M+ acquisition of a 17-month-old startup, founded by former cop Rahul Sidhu. Like Flock, Aerodome was funded by venture-capital firm Andreessen Horowitz (a16z) under its “American Dynamism” program, which promotes the companies it backs as patriotic actors working in the national interest, rather than commercial entities.

Sidhu is positioned in every press release as a cop who built a drone product for cops. He spent 14 years as a part-time first responder, including reserve police service (as a “reserve air-support supervisor”) at Redondo Beach. His actual career — the one that pays the bills — is founding police-tech companies and selling them.

SPIDR Tech (2015) was acquired by Versaterm in 2021. Aerodome (May 2023) was acquired by Flock in October 2024 for over $300 million. In between, in May 2024, Sidhu testified before the U.S. House Homeland Security Committee on drones in emergency response, urging federal accommodation of DFR programs. Five months later, the company was sold. He now leads Flock’s Aviation division, where his current employer has publicly endorsed the DRONE Act of 2025.

Sidhu called the Aerodome acquisition an “American Dynamism speed-run.”

Aerodome to Flock Alpha

The “200X” figure requires a note. The speaker doesn’t say “optical” — he says “this zoom.” But the figure he used is the marketed spec for a substantially similar drone, the Chinese-made DJI Matrice 30T: 16x optical, plus digital interpolation, marketed as a single “200x hybrid zoom” number.

The demo took place before Flock opened its own drone-manufacturing facility in Georgia, and as Chinese-made drones came under increasing federal procurement restrictions in the US.

The plate is readable at 720 ft slant range because the drone has 16x of actual glass and enough sensor to crop the rest. The “200X” framing borrowed the platform’s marketing math and omitted the part where most of that number is software, not optics.

Adding thermal and low-light imaging to existing 200x zoom capabilities and using it to read plates in people’s driveways clearly raises additional privacy concerns. The Supreme Court already agrees:

Where, as here, the Government uses a device that is not in general public use, to explore details of the home that would previously have been unknowable without physical intrusion, the surveillance is a “search” and is presumptively unreasonable without a warrant.

— Kyllo v. United States, 533 U.S. 27 (2001)

Twenty-five years later, Flock markets this device to the government while its FAQ denies its real function.

Full webinar

The original complaint by Thornton For All alleged 19,194 searches, based on information from haveibeenflocked.com. Thornton PD acknowledged the complaint, then set the underlying data aside:

When evaluating this third-party website data, it was clear that the issues articulated in the website’s disclaimer were significant. Instead, our audit focused on internal system records of actual usage by this officer.

haveibeenflocked.com cautions against treating its data as authoritative for several reasons:

1. Information in Flock audit logs is unreliable.
2. When logs are modified — such as through redaction — they may appear as duplicates.
3. When external (network) log information is used, not all searches for an agency may be captured.

These limitations cut in multiple directions. Redaction can multiply searches — the same search by officer “A” in one log and by officer “REDACTED” in another is counted twice. At the same time, Thornton has not published its logs, so the only searches available are those that happen to appear in network logs from other agencies. That’s likely resulting in underreporting.

The discrepancy between 19,194 and 10,318 remains unresolved, and Thornton PD has not published the reconciliation — only asserted that its internal number is the correct one.

The numbers, however, are the smaller question. The substantive issues are what Thornton For All named:

… the department’s letter does not provide an explanation for the irregular search activity that occurred outside of normal working hours. Furthermore, the response does not address the targeted, long-term surveillance of a single license plate that was tracked for up to 145 days

The response also does not appear to address nationwide location history retrievals, often covering multiple months, justified in the logs by entries such as:

“Mexico Plate” · “plate” · “Misuse” · “No record” · “Ebb813b” · “See if stolen” · “n” · “no”

The logs as published cannot support a determination that these were legitimate investigations. Whatever else Thornton PD’s audit reviewed, it was not this record.

That single license plate mentioned, YZ6717D, was tracked over nearly 6 months. Flock’s 30-day retention period is marketed as a meaningful privacy guardrail; 145 days of continuous tracking on one plate moots it entirely.

Conducting long-term warrantless surveillance while representing to the public that retention limits are a real protection is the kind of thing that damages valuable community trust.

And on that issue, the Sentinel quotes Police Chief Baird:

When unverified and inaccurate information circulates, this can negatively shape public perception and damage valuable community trust. I am sharing these findings to provide necessary detail and context, as well as to ensure ongoing public discussion is grounded in fact

We could not agree more. Disclosure of accurate, complete information is essential in building community trust.

“This officer’s dedication to public safety objectives, as well as his tenacity in locating vehicles associated with victimizing members of our Thornton community, is clearly evident,” Baird states.

That’s where we will have to disagree. It is not at all clearly evident from searches justified by “no” or “Mexico plate”.

Of course, if Chief Baird wants to make it clearly evident by publishing complete, unredacted search logs — along with the basis on which “no” or “Mexico Plate” were determined to be proper uses of the system — we would be more than happy to publish that information here.

humans@haveibeenflocked.com

Flock’s sales lead, David Ballard — now a “Solutions Consultant,” according to his LinkedIn page — describes how the system should be used:

@vDomestic Situation clip from Webinar

Let’s say you have a domestic situation with a nurse and her husband has provided some type of threat and they’re separated. And the hospital administrator or the Flock administrator for that area can enter his tag into the Flock Safety LPR system. And it’s called a custom hot list. And what that will do is it will send you a text or an email and let you know, David Ballard just pulled on the area of this hospital. So what we can do then, we can move her to a safe location. We can lock doors. We can get our security team to push that way. We can call the police. So those seconds do matter. And that’s one of the big reasons for that hot list setting.

Ballard then continues to describe why that matters, and names what is fundamentally wrong about the picture he just painted:

You’ve got at-risk visitors, which like we’ve talked about were domestic disputes, at-risk patients. Because at the end of the day, we have to treat everyone. And we work with a lot of people in law enforcement that are in a mental crisis. And so we know that’s just a space we have to operate in, in the health care industry.

Habitual offenders, disgruntled and terminated employees.

Ballard didn’t go off-script by linking “terminated employees” to “habitual offenders.” It was right there on the slide behind him — official Flock marketing material titled “Proactive monitoring with real-time alerts,” which includes two mock push notifications. The first reads: “FLOCK ALERT: Custom Hot List Hit – Terminated Employee. Source: Parking Lot Entry. Camera: Entrance. Network: Hospital.” The second: “Custom Hot List Hit. LP #RUI6676. Terminated employee with active threat.” The slide visually equates “terminated” with “active threat.” There is no other datum on the badge.

The product has a “Hospital” network type, with the alert source pre-populated as “Parking Lot Entry.” This is not a thought experiment. It is what Flock built.

Ballard had discussed the policy with his Flock colleague, Jessica Barzee, the Sr. Demand Generation Manager hosting the call:

And that one, Jessica and I discussed this earlier about the terminated employees. These people have made a huge investment in their life. And if they’re terminated, we’re taking that away. And that’s affecting them for the rest of their life. So that’s very powerful, and people are very passionate about that.

The most common assailants of health care workers are patients…

He mentioned, in passing, “we have to treat everyone.” That includes a “Terminated Employee.” That’s not only a moral obligation, it’s a legal one. EMTALA (42 U.S.C. § 1395dd; 42 C.F.R. § 489.24) sets requirements for every Medicare-participating hospital with an emergency department: they must screen every patient, they must stabilize them, and they must transfer as appropriate.

This level of care is triggered as soon as a patient enters hospital grounds. It’s not conditioned on passing a security interview that potentially delays critical medical screening and care. If a “Terminated Employee” shows up at the “Parking Lot Entry” with chest pain and security blocks them from receiving care, that’s an EMTALA violation carrying severe penalties and liability.

What does that interception actually look like? Ballard walks the audience through the workflow:

@vDisgruntled Patient workflow

So let’s say a disgruntled patient provides a threat. They’re going to commit an act of violence. So we can use the Flock Safety’s patented vehicle fingerprint search and identify the patient’s vehicle, or we can bring police into it, you know, do a report and they look up the tag and provide you with that tag and you can enter it. Then we add the license plate to our hot list.

That’s your custom hot list. You can choose who’s going to get that in your security teams, your administrative facility, because they want to know about it.

Then he names the action:

You receive an alert that the vehicle has entered the hospital campus. So if the vehicle returns, the security staff intercepts the suspect at entry.

The “suspect.”

The “Terminated Employee” at the “Parking Lot Entry” with chest pain or some other healthcare emergency? Someone who, in Ballard’s terms, is “very passionate” about having just lost “a huge investment in their life”?

If we suspect a mental health crisis — which would not be unreasonable under the circumstances — the hospital’s moral and legal duty isn’t for its security team to delay care by “intercept[ing] the suspect at entry.” It’s to provide healthcare. That laid-off employee may have provided that care for years before the budget was diverted to fund surveillance technology and security.

The watchlist isn’t limited to former employees.

He then suggests using Flock’s “non-resident” detection — a feature marketed primarily to its HOA customers — “that’s an evidence that we can use and push to our security team, create those hot lists and say, hey, we were cased by a car that looks suspicious.”

Let’s put it on a hot list for our team.

No reasonable suspicion. No expiration dates. No guidelines. No disclosures. You haven’t been to the hospital before and you look suspicious.

A public hospital, federally required to treat everyone, transformed into a privately curated watchlist enforced at the parking lot entrance. This is what Flock calls “objective evidence.”

Ballard describes the goal plainly: “solve crime, move crime, or prevent crime. I’d rather prevent it and move it than have to solve it.” Predictive policing. By hospital security. The “move it” clause is doing real work — applied to a fired nurse in active cancer treatment, it means she goes to a different cancer center, if one exists in her insurance network. Applied to a fired respiratory therapist in mental-health crisis, it means a longer drive to an inpatient bed in a state where beds are already rationed. The pitch: my customer is safe. The threat is over there now.

This webinar was originally posted in September 2023. It is still on Flock’s website. Its healthcare customers — of which there are many — continue to follow Ballard’s recommendations and are still adding “suspects” to custom hot lists based on vibes, interrupting patient care and exposing the hospital to legal liability.

Any hospital that has followed Flock’s deficient advice should immediately instruct its staff to remove all former employees from any “custom hot list.” Providing adquate, efficient emergency care is not optional.

For every other category — habitual offenders, disgruntled patients, cars that “look suspicious” — the same architectural problem applies. The intercept blocks the screening. EMTALA does not allow that. Hospitals can learn this from compliance training, or they can learn it from federal court.

And that’s assuming the technology works perfectly. This week — three years after the webinar — 9News reports that incorrect Flock alerts are “not a one-off.” Among the affected: “a 76-year-old grandmother… repeatedly pulled over after data errors triggered inaccurate Flock camera alerts.”

In three years, how many patients have received delayed care, or have been “moved”, because of inaccurate alerts?

In Ballard’s words: “At the end of the day, we have to treat everyone.”

Let’s start now, before someone dies in the parking lot.

Full webinar, “Expanding Your Healthcare Security Perimeter Beyond Four Walls”

On May 1, 2026, law firms Emery | Reddy and Milberg filed a class action suit in the Northern District of California against The Home Depot, alleging violations of California’s ALPR privacy act and invasion of privacy. It’s the second class action against Home Depot in two months — Bursor & Fisher beat them to it with McGinity back in March. The two suits divide the timeline: McGinity covers shoppers caught before Home Depot quietly updated its ALPR policy in late December; Schmierer covers everyone since. And it lands the same week three separate Flock suits (Eldridge, Dutcher, and Javorsky) move to consolidate in the same court.

The new lawsuit challenges the common assumption that private corporations can surveil their customers and others without limitation. As it should, because that assumption is plainly incorrect. States can and do regulate the use of video and audio recording devices on private property, and California’s ALPR law doesn’t distinguish between private and public operators.

The other component — invasion of privacy — is an interesting tack. The suit alleges two slightly different violations: a violation of the right to privacy under the California Constitution, and the tort of “intrusion upon seclusion.” The complaint writes:

A reasonable person visiting a hardware store does not expect that their license plate data will be automatically captured, timestamped, stored in a national database, and made accessible to hundreds of law enforcement agencies, including federal immigration enforcement, all while the operator maintains a policy that omits mandatory disclosure elements and provides no meaningful restriction on who can access the data.

It also anticipates the obvious argument from Home Depot / Flock:

The California Supreme Court has recognized that the relevant question in an intrusion claim is not whether any single piece of information was publicly observable, but whether the manner, scope, and aggregation of the intrusion would be offensive to a reasonable person.

The complaint then lays out why a private corporation collecting data at its 233 locations in the state, storing that data with its private vendor, and sharing it in real-time with hundreds of police agencies, without Home Depot telling anyone about it, is offensive to Californians believing they’re just shopping for a new toilet seat.

The complaint has a point, and I’m excited to see where it goes. The statutory violations alone give a sense that Home Depot will end up out of pocket on this one, especially after Bartholomew v. Parking Concepts — the February California Court of Appeal decision that held operating ALPRs without a compliant policy is itself the harm.

Other private companies should take note. Flock can hammer its claims about “no reasonable expectation of privacy” and “30+ courts have consistently affirmed that ALPR devices perform lawful actions” all it wants; courts don’t typically look to marketing materials to find what the law is, and neither should anyone else.

The Flock Suits

Home Depot will be defending itself in the same district where Flock is already in court. And the Flock side is getting interesting. Plaintiffs’ lawyers in three existing California class action suits are getting into a consolidation scrap. The firms handling Eldridge and Dutcher don’t like the Javorsky team’s preservation strategy. The motion to consolidate puts it like this:

[Javorsky’s] difference [in approach] has already resulted in a prolonged disagreement with Flock regarding its retention protocols, which has likely resulted in the loss of hundreds of thousands of data points pertaining to putative class members.

But the more interesting bit is technical:

Flock has represented that capturing the broader set (including the ancillary “Identifier” tags) slows its preservation rate by roughly ten times.

The filing does not specify what these “‘identifier’ tags” are, but dollars to donuts that we’re talking about the searchable vectors that power FreeForm, Flock’s natural-language vehicle and person search tool. I have discussed these before in both the FreeForm context, where searches for “Star of David” were performed, and the ReId context, where persons can be tracked across devices through soft biometric data. The math mostly holds there; simple tags stored with the data would be fairly small, plausibly ~200 bytes, so if a vector is ~2kB, that would be about 10x larger and therefore 10x “slower.”

The part that doesn’t make sense in the filing is the preservation rate. It implies that preservation can’t happen in real-time on the backend. Why not? What prevents Flock from setting up an additional replica node? Does it not routinely keep replica copies of its data? If it doesn’t, how does it guarantee data integrity (and thereby both completeness and accuracy)?

I’ve raised these questions before in the context of changing log files:

A distributed explanation is not any better than deleting and adding records in a centralized database. In fact, it would be a very fundamental, very fatal, flaw for records that are supposed to be immutable \— like audit records \— to have multiple copies in multiple places without a single authoritative copy.

Apparently log entries can go missing without Flock’s system throwing an error. If you can’t be sure that your log is complete, you can’t rely on it to show whatever it is you’re auditing for \— it may have been deleted.

If a similar distributed pattern holds for the “identifiers” or vectors — which Flock’s protestations in this new court filing seem to suggest — it would extend the integrity problem from the audit logs to the ALPR data itself.

The motion takes Flock’s “10x slower” claim at face value and uses it to triage: preserve the narrow set that identifies the class, drop the fight over ancillary fields. As a practical call under time pressure, it makes sense. But Flock’s underlying claim is the part that should not have gone unchallenged.

In particular, it’s worth considering that “ALPR information” under California law means “information or data collected through the use of an ALPR system” — not “license plate characters.” Whatever Flock’s cameras capture and feed into its searchable database is ALPR information, with all the operator duties that attach. Flock stating that the broader field set slows preservation by 10x is, in effect, telling the court those fields exist and are part of what the system collects. They’re covered. The plates are just one column in the table.

The more data collected, the more there is for Bartholomew’s harm analysis to work on, and the more there is for the privacy torts’ offensiveness analysis to grade as offensive. In re Facebook — Edelson’s signature win — established that biometric data has value as data. None of that argues for letting Flock walk away from the broader fields just because its architecture allegedly can’t keep up.

Even a narrow set — license plates and locations, a few bytes — is apparently more than Flock can copy or preserve at scale without slowing things down. It implies the live system runs on single copies without the kind of redundancy that would let it verify its own data — and its distributed database likely uses computers sitting unattended on the side of the road, intermittently accessible through spotty mobile connections, storing unencrypted video and images, for the express purpose of directing traffic stops, conducting searches, and providing evidence.

The disclosure failure has always done double duty for Flock: hide what the system collects, then escape enforcement when nobody asks. Now Flock wants it to do triple duty: wall off the undisclosed fields from the lawsuit, too.

In September 2024, Dunwoody PD Major Patrick Krieg requested access to the private security cameras at a community center on behalf of the department. When the community center pushed back and demanded to know what the access would be used for, Krieg was unambiguous: “This is solely for real-time critical incident response.” The community center agreed to share their cameras, including cameras in gymnastics rooms, pools, and fitness studios, with Dunwoody PD for emergencies.

To the broader public, the City made the same promise in a different form: Flock is a public safety tool that catches criminals and keeps your community safe. It’s only used for law enforcement purposes. When citizens raised concerns, we were given three minutes at a podium, requests for open meetings were ignored, and we were silenced by a unanimous vote.

Both promises had the same problem: while the city was making them, Flock employees were inside Dunwoody’s camera network, including a private community center’s cameras (the ones shared solely for emergencies) to allegedly pitch their product to other law enforcement agencies.

From 2023 through April 2026, Flock employees viewed live and recorded cameras in Dunwoody over 1,000 times. In 2025 alone, they searched Dunwoody citizens’ data over 400 times. No one in Dunwoody consented to this.

When I asked the City of Dunwoody to produce any agreement authorizing this, their answer was simple: “The City of Dunwoody found no records that are responsive to your request.”

There was no authorization or explicit permission. Just a promise to a community center, a promise to the public, and a company that treated both like an open door.

Flock’s Response

Flock’s public statement in response to this information being revealed was unequivocal: “We work with cities and agencies, like Dunwoody, that have given authorized, explicit permission to be testing partners.”

Their CEO told a different story in private. In an email obtained through open records, Garrett Langley wrote to the community center’s CEO that Flock had “explicit permission from Dunwoody” and that employees “occasionally” accessed Dunwoody’s devices for testing and demonstration purposes, but that this was a “poor decision,” and Flock showed “a lack of thoughtfulness.”

Flock CEO’s ‘apology’

Let’s start with “explicit permission.” I filed an open records request asking the City of Dunwoody for any agreement, contract, memorandum of understanding, or authorization, anything at all, governing Flock’s access to Dunwoody’s camera network for testing or demonstration purposes. I made the request as broad as possible because I wanted to know whether the city had decided it was acceptable for my family and me to be watched by Flock sales employees without our knowledge. I think any reasonable person would agree I should at least be able to find out if the city robbed me of consent, and if so, who made that decision.

The city’s answer: “The City of Dunwoody found no records that are responsive to your request.”

Response to my request for a “demo agreement”

There was no explicit permission. There was no agreement. There was nothing.

Now let’s talk about “occasionally.” From 2023 through mid-April 2026, Flock employees viewed live and recorded cameras in Dunwoody 1,063 times. In 2025 alone, they searched Dunwoody citizens’ data 401 times directly through the Dunwoody PD network.

Camera views by Flock employees, mostly sales employees

Maybe Flock and the rest of the world have different definitions of explicit and occasionally. Mr. Langley, if you read this, I personally offer to buy you a dictionary.

Flock’s blog went further, claiming the community center’s “camera was only viewed once during a routine demo.” This implies that only one camera was viewed. This is quite contradictory to public records, which show dozens of cameras in sensitive areas where children play being accessed, including in the private community center.

Either they are intentionally lying by stating only one camera was viewed, or they do not know how to read their own audit logs.

Neither explanation is acceptable.

Flock’s response doesn’t even commit to ending these demos. It makes clear that ordinary people across the country, going about their lives, will continue to serve as unwitting props in Flock sales presentations. Flock’s website still states, “Flock Safety does not access or monitor your footage without explicit request of the customer,” although the audit logs tell a different story.

Flock also said in a statement to 404 Media that “it is unequivocally false to assert that Flock, or the police, or city officials are doing anything other than using technology to stop major crimes in the city.” This is at the same time that their blog admits that they were looking at cameras where Dunwoody citizens and children could be. So which one is it? Are they hoping to redefine the words “anything other than”?

Flock Safety’s entire defense rests on the word “permission.” They used it in their public statement. Their CEO used it in his private email to the community center, and their website uses it.

But when I asked the city to show me that permission — any document, any email, any record of anyone ever saying yes — there was nothing. Not a contract, memo, email — nothing. The cameras were shared with Dunwoody PD for 911 emergencies.

That’s not permission. That’s not “explicit.” That’s a private company deciding that proximity to a law enforcement contract was close enough to consent, and a city that either didn’t know or didn’t care.

Dunwoody PD Response

When the community center’s leadership found out their cameras had been accessed by Flock employees, they did what any reasonable institution would do: investigate and contact the police department that had promised to protect them.

Their understanding of the arrangement was explicit.

In an email exchange obtained through open records, the community center’s leadership wrote: “Our understanding was that DPD’s access to our cameras was limited to active-shooter or similar emergency scenarios: real-time tactical awareness, etc. Since no such event had occurred, we had no reason to believe anyone had actually viewed the feeds.”

That understanding came directly from what the PD told them, but it was wrong.

They were immediately given two very different answers:

Deputy Chief Oliver Fladrich said, “I certainly had my eyebrow going up about Flock checking in your system.”

Major Patrick Krieg: “It is becoming clear that we have an individual or small group that is continuing to produce misinformation to our partners in an effort to disrupt operations.”

Read those two responses again. One senior officer acknowledged that Flock being inside the community center’s cameras was unexpected. The other called it misinformation.

I found this particularly weird since they work in the same department, have seen the same evidence, and Krieg himself was the one who promised the community center in writing less than two years ago that access was “not recording your video, nor will we have any rights or ability to disseminate it otherwise, it is solely for real-time critical incident response.”

Email I obtained through open records requests

At this point I am assuming that the community center agreed on that basis, and they had no reason to believe anything else was possible.

Just like everyone else in Dunwoody, they found out this promise had been broken from a private citizen. Not from the police department that made the promise. Not from the officers overseeing the Real Time Crime Center who should have been the first to notice that Flock employees were inside a network explicitly labeled “Do Not Share.” From me — a dad in Dunwoody who filed open records requests.

But those officers were busy. They were at steak dinners with Flock employees.

Texts obtained through open records from Lt. Fecht’s phone: Chris Anderson, David Thorp, and John Watson (number redacted) are Flock employees

The community center was betrayed by the people tasked to protect them just like the rest of us.

We were all told the same story: that Flock was a law enforcement tool, that our cameras were for emergencies, that the system had safeguards. Someone, either Dunwoody PD or Flock or both, decided that our neighborhoods, our parks, our pools, and our children’s gymnastics rooms were fair game for a private vendor’s access.

Nobody asked us for our consent, and when a private citizen found out and raised the alarm, one of those officers called it misinformation.

That’s not a miscommunication, that’s a choice.

City of Dunwoody Response

At the April 13th City Council meeting, Mayor Lynn Deutsch said she “sought a solution” and that “where we landed is that Flock will no longer use Dunwoody for demonstration projects.” She also said the city was “trying to be transparent.”

So let’s talk about that transparency:

Before this story broke publicly, I had emailed the mayor fourteen times about concerns with Flock. She never responded to one. When I offered to meet with her directly to walk through what I had found — audit logs showing Flock sales employees watching cameras inside a children’s gymnastics room — she ignored me.

Mayor Deutsch and the rest of the council have also refused every request from citizens for an open public meeting on Flock, which makes it particularly remarkable that on the 13th, an hour after ignoring those requests, Councilman Joe Seconder suggested an open meeting about a completely different topic.

The “solution” she announced came less than a week after she met privately with Flock’s CEO at a coffee shop, a meeting she didn’t disclose publicly until I brought it up, arranged through text messages obtained through open records.

Texts from Mayor Lynn Deutsch to Flock CEO Garrett Langley obtained through open records

This is the same CEO who has gone on television and lied about Flock’s relationship with ICE and the federal government, and lied directly to other city council members. I had made Mayor Deutsch aware of both of these facts in February.

I even got the exact email of Garrett Langley lying to a Denver City Council woman from a reporter in Denver and attached it

For her, “we” doesn’t mean the families of Dunwoody. It means her and the CEO of the company under scrutiny, meeting privately, before she championed a legal agreement and contract expansion that required nothing of Flock, held no one accountable, and changed nothing materially about how our data is used.

There was never an explicit authorization allowing any of this to happen. Not for the demos, searches, or for a single Flock employee to open a single camera feed inside a private community center, or at our parks and playgrounds.

Without authorization, public accountability, and the public’s consent, the City of Dunwoody, the Dunwoody PD, and Flock turned our neighborhoods, our parks, our pools, and our children’s gymnastics rooms into a virtual human zoo for a private company’s ‘sales pitch.’

Nobody asked us, or told us, and when we found out, the mayor’s solution was a private coffee meeting with the CEO.

So here is the question nobody in Dunwoody has been willing to answer: who authorized this? Not who enabled it technically. Not who facilitated the integration. Who decided it was acceptable for Flock sales employees to have access to cameras inside a private community center, and our parks and playgrounds? Who decided that was consistent with what Dunwoody PD promised us and the JCC in writing? Who decided that 401 searches of Dunwoody citizens’ data in a single year by Flock employees was within the scope of what this technology was sold to us as?

The mayor met with the CEO, then the council voted unanimously to expand the contract, the officers responsible went to dinner with Flock employees, and the cameras, microphones, and drones are still on.

What’s Next?

That can’t be the end of this story. The residents of Dunwoody deserve a city that works for them: not one that meets privately with the companies it’s supposed to oversee and calls it transparency. Zach Humphries, Sean Collins, and I are launching Dunwoody Forward because we believe this community is capable of something better.

We want to build something that goes beyond Flock: a vision for what Dunwoody looks like when the voices of citizens carry more weight than the interests of corporations. We’re still figuring out what this non-partisan group looks like, and we need your help.

Join our Facebook group and let’s figure this out together :)

Join the Dunwoody Forward Facebook Group →

This piece was originally published on Jason Hunyar’s Substack, and is republished here with permission.

This is a meaningful position from an organization I’ve previously disagreed with on ALPR transparency. The underlying disagreement was never moral — the general public should not have their data collected, catalogued, and published — but practical: the structures EFF and ACLU were endorsing produce, in the real world, the opposite of transparency.

Although both EFF and ACLU have since expressed a need and desire for stronger transparency than their previous words suggested, practical issues remain. In its new post, EFF opposes the worst version of these bills (categorical exemption) while still endorsing a framework that keeps records hidden in practice (case-by-case balancing).

The Problem

Seven states (and counting) introducing hostile legislation is not a coincidence. It’s a direct result of Flock’s lobbyists^[1] responding to public-records work that has produced policy outcomes like contract cancellations, declined renewals, and even criminal charges. EFF correctly identifies the records as “not just informational—they are leverage.”

The Washington example is instructive and worth dwelling on. A state court ruled last year that ALPR data are public records. The legislature responded by exempting them. This is the predictable endpoint of a balancing-test regime: when transparency wins on the merits in a forum that requires reasoned analysis, the response is to move the question to a forum that doesn’t.

Flock’s home state of Georgia goes further. Not content with exempting ALPR data, the state made it a misdemeanor to request or use plate data for non-law-enforcement purposes. That is the trajectory of denial-by-fee taken to its logical conclusion: when charging $5.4M for search logs (Dunwoody’s number) becomes inadequate to deter requesters, criminalization is next.

Case-by-Case Balancing and Deidentification

EFF prescribes an unworkable framework that already exists in many states: a privacy exemption requiring case-by-case balancing of transparency benefits against privacy costs.

The framework is idealistic. It is also the primary mechanism by which logs get withheld. Most states lack specific exemptions for the kind of audit data published on haveibeenflocked.com. Even states with “ALPR data” exceptions have to contend with the fact that search terms entered by a user are not “ALPR data.” Agencies often route around this by treating each search as a separate record, then assessing per-record review fees. Five- and six-figure fee estimates are common. The “balancing” and redaction in practice means an agency charges enough to make the request impossible. No balancing actually occurs.

The practical reality under these frameworks is that if you can collect enough records, you can ensure nobody ever gets to see them. That’s the opposite of the desired outcome.

The per-record framing is also a trap of agencies’ own making. If each search log is a separate record for fee purposes, it is a separate record for every other purpose too. Open records law generally requires a specific lawful basis for withholding each record, communicated to the requester, with each denial independently appealable. An agency that wants to charge per-record review fees on 10,000 “records” in a single Excel spreadsheet should be prepared to issue 10,000 individualized determinations and defend each one. Agencies want the fees, but not the obligations.

EFF’s fourth recommendation — disclosing aggregated or deidentified data while withholding personally identifiable information, and treating that process as redaction rather than record-creation — is closer to a real, and workable, solution.

Aggregation is a dodge. Counts of scans by month, hit ratios in percentages, and total-records-shared figures only tell you that surveillance is happening at scale. We know that already. Whether specific searches are lawful, whether officers are stalking exes, or whether “investigation” is being used as a pretext for anything remains locked away in a filing cabinet in the basement of the police station. Aggregate data can’t surface the Milwaukee Ayala case or the Joplin firing. Pattern-of-misuse questions require record-level data.

Deidentification is the workable part. haveibeenflocked.com already takes this approach to an extent: the site publishes audit logs but maps plates to “identifiers” to obscure their identity. This allows the patterns to remain visible — Officer X searched plate Y 124 times in two months — without exposing what plate Y is. Flock previously did the same thing with usernames in its transparency portals before stripping the IDs entirely. It’s a solution where risks like reidentification must be considered, but that’s not an insurmountable problem.

I’ve written about this approach before; haveibeenflocked.com’s “identifiers” are a partially working example of the disclosure-with-redaction structure EFF is asking legislatures to enact.

Front-loading Beats Balancing

The deeper problem with case-by-case balancing is that it does the work in the wrong place at the wrong time. Each request triggers an individualized analysis by an agency that has no incentive to perform it well, no consequences for performing it badly, and a claimed financial mechanism (per-record review or redaction fees) for converting the analysis itself into a denial.

There is a logical alternative: front-load the determination through rulemaking. My state, Iowa, has the structure largely on the books in its Fair Information Practices Act, even if implementation and enforcement are absent in practice.

Under FIPA, state agencies must promulgate rules describing what personally identifiable information they collect, why they collect it, the legal basis for collection, and which of their records are public, confidential, or mixed. The determination is made before any request arrives. The burden sits with the agency, ahead of time, rather than being shifted to the requester at the moment of request.^[2]

Front-loading also forces honest accounting. We do this elsewhere as a matter of course. If a record could contain confidential information, we treat it as if it does. Your doctor can’t store lab results in the same folder where she receives the office Christmas party invites. Yet agencies constantly argue, through public records responses, that they commingle confidential and non-confidential records and store them with third parties — Flock, email providers — that are not bound to keep those records confidential and that, in Flock’s case, will actively disseminate them to paying customers.

Strict reading of public records law makes that assumption-based structure hard. Open records statutes generally, and correctly, turn on what a record does contain, not what it could. Front-loaded rulemaking forces agencies to make the determination at the outset — at minimum, by instructing employees not to enter PII into Flock; at maximum, with a manual confidentiality justification stored with each entry.

Agencies will argue this is too burdensome; cops can’t be trusted to make these legal determinations. They will be right. The burden is the point. If an agency doesn’t know whether a search reason contains confidential information, it doesn’t know whether the search was lawful. Privacy, confidentiality, and oversight are all the same problem.

Watchlists as a Solution

Front-loading exposes one residual problem: are license plates themselves confidential PII? A categorical answer is available through watchlists.

Properly constructed, watchlist inclusion should require an active police investigation; current practice does not, which is itself part of the problem. Assuming the rule is in place, plates on a watchlist can be exempted from disclosure as part of an investigation. Plates not on a watchlist were captured and stored without an existing investigative basis. This is the “just in case” form of mass surveillance creating the biggest privacy problems.

Those historic location profiles should not be stored at all or, if they are not sensitive enough to prevent their storage, they should be subject to disclosure. The question of whether the public should see information collected without an investigatory nexus collapses into the question of whether they should be collected at all.

The watchlist approach also makes aggregation meaningful. The unit shifts from “plates scanned” — which only confirms surveillance is happening at scale — to “watchlist entries vs. open investigations,” which tells you more about how the system is being used. An agency with thousands of watchlist entries and a few dozen open investigations is using the watchlist for something other than active investigations. An agency whose watchlist entries persist for years is operating differently than one whose entries turn over in days. Either pattern is more useful for oversight than a count of plates scanned or a number of “hits.”

The contradiction is unavoidable. Either license plates are not PII and carry no privacy interest on public roads — Flock’s position when defending the cameras — or they are sensitive PII exempt from disclosure — Flock’s position when defending the audit logs from disclosure.

That contradiction is theirs, not EFF’s, and not the law’s. EFF takes the coherent position that plate data should generally be withheld from third parties, while audit logs and aggregate scan data should be public.

Flock aggressively funds the narrative that total exemption is the only solution. It would probably be right, if it didn’t assign itself the exclusive right to collect, receive, and store the very data it argues is too sensitive for the public. “The public” includes Flock.

Flock is also right that current open records laws are flawed, but the solution isn’t to hollow them out. EFF’s proposed solution is an opaque balancing test with unpredictable outcomes. My proposal is to add the requirement that governments be transparent and consistent.

Both proposals are much better than Flock’s. Neither would be required if current laws on confidentiality and open records were enforced.

Council member Brad Spanbauer had asked, on the record:

“Just to be clear, does the system create a heat map of a vehicle’s movement using the multiple aggregated images for a specific searched vehicle?”

Flock’s representative answered: “No, that is not available.”

It is available. It has a name. Flock calls it pattern of life.

What Pattern of Life is

Pattern of life is the Flock feature that turns a string of camera reads into a behavioral profile. You pick a plate. Flock plots every camera that captured it — across a jurisdiction, across a region, across the nationwide network — onto a map, with a heat map overlay that brightens where the vehicle spends its time. You toggle the window: 14 days, 30 days, longer. What comes back is the shape of a driver’s week: home, work, church, doctor, lover, gun range, union hall, rally — each node glowing in proportion to how much of a life is lived there.

It is not a theoretical capability. It is not a roadmap item. It is a marketed, shipped, demonstrated feature of FlockOS, and Flock’s own staff describe it in their own training materials.

“We do not and cannot track vehicles”

The Oshkosh denial was not one rep having a bad night. It is the company’s house talking point, repeated in its corporate marketing, its blog posts, its press statements, and the materials it feeds to elected officials considering contracts.

On a February 26, 2026 blog post titled Is Flock Mass Surveillance? Here’s What 30 Courts Decided, Flock states, in its own voice:

“Flock ALPRs do not and cannot track vehicles, much less individual people. ALPRs take a point-in-time image of the rear of vehicles on public roadways. They are incapable of tracking the whole of anyone’s movements…”

Not “do not, absent a warrant.” Not “do so only in narrow investigative contexts.” Cannot.

Now set that next to a Flock product staffer walking a customer audience through the search interface: “you can change and see 14 days of pattern of life or 30 days of pattern of life … the heat map that you know and love.”

The marketing department is contradicting the product department. A system that “cannot track vehicles” does not ship with a 30-day pattern-of-life toggle and a heat map its users already know and love. One of those sentences is the product. The other is the pitch.

Flock Webinars Confirm the Feature

From a Flock product demo of the search interface. A Flock staffer walks through the suspect drawer in the UI:

“you can change and see 14 days of pattern of life or 30 days of pattern of life. So you can, once you’ve zoomed in on your suspect, you can start to see what have they been doing? Where have they been going? And you have the heat map that you know and love, which you can toggle on and off.”

@vSearch interface with pattern of life

In another webinar, Flock explains why a user would extend a hot list’s retention window:

“you might wanna know long-term where that car has been in a week … you kind of wanna figure out what its pattern of life is.”

@vPattern of Life via Hotlist

Finally, in a Q&A on FlockOS, Flock is asked whether the system can generate “a map-based report reflecting all of the hits for a specific vehicle … a pattern of life scenario,” a Flock trainer defers to another team member, then reads the answer:

“FlockOS allows you to see the historical locations of a specific vehicle, including a map-based view and heat map as part of license plate search.”

@vFlockOS Pattern of Life

Each Flock employee in these three webinars references “the heat map that you know and love” — the same feature Flock told Oshkosh’s council didn’t exist.

Beyond Oshkosh

Oshkosh is the first council we know of to catch Flock in a lie on the record and actually act on it by reversing a vote because of it. It wasn’t the first council to be told a lie, nor will it be the last. It was the first to so publicly call a spade a spade — a move that makes me feel some Midwestern pride. Three things follow for everyone else.

First, every jurisdiction that approved a Flock contract based on sales representations should re-interrogate those representations. The problem isn’t confined to one rep in one Wisconsin council chamber. Flock’s corporate marketing tells the public the system “cannot” track vehicles. Its trainers tell paying customers how to track vehicles for thirty days at a time. If a council relied on the former to approve a contract, it bought the latter. Pull the minutes. Pull the recordings. Ask the chief what he was shown in the back office that was not shown at the dais.

Second, Flock’s public response — that its statements were “misinterpreted and weaponized by activists” — is not a denial. It’s a complaint that someone noticed. The chief did not misinterpret anything. He said he “visually confirmed” the heat maps the next morning. It’s Flock’s canned repsonse to claims it doesn’t like but can’t refute: “these are just false”.

Finally, “pattern of life” is what makes Flock Flock. A single camera that reads a plate and checks it against a list of stolen vehicles is a tool — a narrow one, with narrow uses. A network of hundreds of thousands of cameras aggregating every read on every plate into a queryable history of where a driver has been, brightened into a heat map, is something categorically different.

The cameras are the sensor — Flock owns these, and its customers don’t care. The pattern-of-life database is the product actually sold to police departments. It’s why the cameras exist, and why the feature is built, taught, and demoed.

An “ALPR camera lease” may be the easier sell for its reps, but it’s not a product Flock offers.

The Language

Flock did not invent the phrase “pattern of life.” It is a counterterrorism and military-intelligence term of art for building a behavioral template of a target by tracking their movements over time. Flock markets counterinsurgency tooling to local police departments because it sells.

When that product is pointed at every driver on an American road — and the company’s sales staff then tells elected officials it does no such thing — “misinterpreted” is not the word for what happened in Oshkosh.

False Claims and Fundamental Changes

The claim that Flock enabled backdoor access to customer data and other claims that have been in the media \— these are just false. All of the sharing that happens in the Flock system happens through permissions in the system controlled by you and your admins. It’s your data. Contractually, you control it. Flock does not own it, does not share it, does not sell your data.

@vAmy Palumbo on media claims and FOIA in February webinar

The facts Palumbo called false are well-documented on this site, as well as on Flock’s blog.

A CBP pilot ran May 9 through August 24, 2025, during the same summer in which Flock CEO Garrett Langley published a blog post titled Setting the Record Straight, where he denied federal cooperation — “not my decision, and not Flock’s decision,” he wrote — while that pilot was live.

A January 2026 Flock blog post repeated that “ICE does not have direct access to Flock cameras, systems, or data” while, in the same post, listing the CBP pilot as an arrangement that “effectively enabl[ed prospective customers] to test the product before committing.”

Throughout all of this, audit logs continued to show searches by federal agencies, while agencies like Mountain View, CA, said federal sharing was enabled without their consent.

The only time Flock accesses customer data, Palumbo went on, is to respond to “legal process” — a subpoena, a search warrant, a court order — and the customer is notified when that happens.

She made that statement around the same time Flock employees were, according to Flock, using a gymnastics room, a pool, and a daycare in Dunwoody for a sales demo. A practice Flock says it intends to continue, but “in more public locations.”

Such contradictions are routine at this point. Less than ninety seconds may be a record. Right after the “just false” line:

So where is the misinformation in the media coming from about backdoor access? It’s a misunderstanding about some of our previous pilot programs and sharing within the system. So over the summer, as these issues came to light about access from federal partners who were pilot customers, we made a lot of changes to the system in response to some of that feedback.

From “no backdoor” to a “misunderstanding” about “previous pilot programs.” A pilot program that gave access to federal agencies. Without other agencies knowing about it. If there is a falsehood anywhere, Palumbo does not mention any details.

Palumbo may dislike “backdoor” as a label, but she can’t deny the architecture it describes. Federal agencies, including immigration agencies, hooked into Flock’s sharing apparatus running searches against cameras across the country, including in states like California which restrict such use of surveillance networks.

Either way, you do not appoint a chief legal officer, expand your policy team, stand up new trust and safety programs, and create a dedicated compliance product-manager role to fix a media narrative that is false. You respond to reporters asking for comment and attach a receipt or two.

No FOIA, No Problem

Palumbo goes on a bit to encourage the, presumably, Wisconsin-based audience to apply “a balancing test” when “facing public records requests.” The information agencies are allowing Flock to collect can lead to stalking and could be misused — according to Palumbo. The dangers of releasing this information — to the public; not to Flock, its contractors, its customers, or its pilot programs, of course — can’t be overstated (when it comes to public records requests).

@vAshley Haber on product changes

The next speaker was Ashley Haber. She delivered the list of “changes to the system in response” to the supposedly false information.

Last summer, we made a change so that federal organizations at Flock are handled a bit differently than a typical state or local law enforcement agency. They are properly called out throughout the system with a label that says federal organization. They also are not included in statewide or national lookup…

Which is to say: before the summer of 2025, federal organizations were indistinguishable from local police departments in Flock’s search and sharing interface. A query run from a federal account reached every shared camera within the network’s scope, state by state, without the querying agency being explicitly flagged as federal in the audit. There was no statewide-lookup exclusion. There was no opt-out, beyond the “all or nothing” of the state- or nationwide network.

There is more.

We did a lot of work last year on cleaning up network and org audits to both be more useful for you all and also protect you all as these PRAs and FOIAs were becoming more popular and they were risking officer safety and active case investigations falling apart.

We cleaned up what we call system-generated searches so that there was not an excessive amount of records here. If someone opened a drawer, zoomed in on the map, technically on our back end it may have created another search record but it really wasn’t a user generated action… we also added the functionality starting August 8th of last year… you’re able to see if your cameras produced any results from lookup searches… the last piece is we masked certain sensitive data in response to what happened close to end of last year to protect interagency sharing.

“What happened close to end of last year” may refer to the December emails from the FBI and Flock in response to logs appearing on haveibeenflocked.com.

“Mask certain sensitive data” is the network-audit redaction feature that strips officer names, agency identifiers, plates, filters, and case numbers from the logs agencies are supposed to review for improper access.

The non-hit-search filter, added in August, lets an agency exclude queries that did not produce a plate match — and, by extension, lets them view which queries did produce a match.

So far, no agency has included this information on whether there was a hit in a network audit log. That information is not categorically exempt from open records laws, and requesters generally ask for complete logs, not ones with partial information.

“System-generated searches,” per Haber, are now filtered from the audit “to avoid confusion and too much noise,” directly contradicting Flock’s public narrative of “every search is logged.” Flock decides what is logged and what is “noise” or “confusing,” based on undisclosed and likely fluid criteria.

And finally, she discusses the “filter” that handles immigration and reproductive health searches in states that prohibit such searches.

The last bullet point on her slide informs the audience that details will remain a secret, “in order to protect the effectiveness of this feature.” Maybe Flock thinks a user of the system couldn’t figure out, without a Flock-published list, that writing ‘suspicious vehicle’ in the reason field defeats the filter.

Or maybe publishing the list would remove their ability to lie about how long they’ve been filtering any particular term. One of those explanations seems much more likely than the other.

Flock’s Solutions

Addressing false claims is easy: you correct them. Flock holds all the information and all the evidence; it has a PR team and a blog. It knows when filters went into effect and how many searches are being filtered. It’s not that hard to rebut false claims and build trust through transparency.

But if the claims happen to be true, you may have to roll out several audit-obstruction features, a bevy of new filters, and restructure your entire compliance organization.

Flock’s response is telling.

Almost two months ago, I titled a section “Flock Promises More Violations.” It has now made good on that promise. Back then, I wrote:

the gradual narrowing is interesting to watch. In a span of weeks, Flock’s messaging shifted from “Flock does not sell data,” to “Flock does not sell data to the federal government” to “Flock does not sell data to DHS agencies.”

Federal agencies have been appearing more in audit logs, tagged with [Federal]. Flock has added a toggle to its product to grant/deny federal access to data.^[1] These have largely been federal prisons, and parks like the Presidio of San Francisco.

Now, the FBI has direct access.^[2]

Flock will keep insisting that licensing data isn’t selling data. The distinction matters to surveilled citizens about as much as Netflix’s licensing model matters to a movie studio — and the studio, at least, sets the terms.

Contractually, Flock is not prohibited from granting the feds access. For that matter, it’s not prohibited from granting anyone access. Numerous private corporations and universities have access to what Flock markets as a “law enforcement only” network, and entire police departments are regularly granted access without a contract.^[3]

But communities that were sold the system by Flock and their local PD on the promise that the feds did not have access to the data now have a system deployed that does grant direct, federated access to the FBI and other federal agencies.

It’s what those cities signed up for. Flock manages access to the network. Not the city. Not the PD.

If you want to know if your city grants access to the FBI, you will have to file an open records request. It is unclear at this time whether the “federal access” configuration switch is separate from the “shared networks” file — the configuration that governs which outside agencies can query a department’s cameras (reach out if you know).

Police departments generally don’t inform elected officials or the public when they enable a software toggle—even when it comes with constitutional and liability implications. They certainly don’t seek the public’s approval before subjecting it to federal mass surveillance.

“Every city has a right”

America is built on principles of freedom, and every city has a right to make that choice. When a community pulls back on public safety they achieve less surveillance, but the people who are made to suffer aren’t the affluent ones, it’s the people who live in neighborhoods where they can’t afford safety…

“[E]very city has a right to make that choice” is Langley flat-out catering to his customer base. The U.S. Constitution — specifically the Fourth Amendment — as well as many state constitutions are intended to constrain government. Local governments don’t have unlimited power.

The other issue here is that “the people who live in neighborhoods” are left out of the conversation and the decision to deploy surveillance entirely. They suddenly discover “LPR” cameras pointed at their basketball court because Flock’s own sales pitch — second image below — says these deployments are a way for departments to get video surveillance without having to go through a public hearing.

“Flock LPR” cameras are named to trick people into believing they’re license plate readers. Instead, they capture video and data to be fed into a sprawling national system centered on Flock’s “Nova” intelligence product.

In Langley’s world, the cops get to choose. The people aren’t even told.

Safety-as-a-Service (for a Recurring Fee)

South Africa has over 600,000 private security guards. More than its police and military combined. The wealthy live behind nine-foot walls and electric fences. Safety exists, if you can afford it. If you can’t, crime is simply the cost of being alive.

The true hypocrisy, however, is not the price tag for “All of Us”, but the invocation of South Africa’s “pay to stay safe” system. Langley cites it as an example of inequality; at the same time, Flock partners with the South African company Vumacam to profit off the creation of a new era of “digital apartheid” in South Africa.

Via Ricky Croock's LinkedIn (spelled as "Ricky Crook" here).

Vumacam places Flock cameras in affluent suburbs and sells that data to private security contractors. Those corporations, which are even less accountable than the government, in turn sell their services to South Africa’s upper-class.

Langley stands on-stage in feigned indignation, as his $8.4 billion company collects on “the cost of being alive.”

The Digital Standing Army

Langley lauds police forces in other countries and considers the U.S. system of local police to be a “unique problem we have created for ourselves”. He is wrong. It’s not a problem, but a solution.

The founding generation was deeply divided on standing armies. At the time, the local militia kept the peace — professional police didn’t arrive in the U.S. until 1838. A common wisdom was that the more local the militia, the less likely it would be to turn on the people.

What the founders feared from a standing army has arrived in a different form: increasingly militarized and high-tech police. Langley describes his vision as one where any police officer anywhere in the country can “share” and “cooperate” across borders and jurisdictions.

What that means in practice is that any police department in the nation has the capability to dispatch one of Langley’s drones based on reports from his national “Nova” system, fed by hundreds of thousands of his cameras.

Even Hamilton, a proponent of standing armies, warned that nations attached to liberty will, in time, give up freedom for safety — a dynamic that scales down to any institution sold as protection.

Police now believe they depend on Flock. That means its CEO can not only afford safety — he can demand it from the standing army he helped create.

What to do about it

The camera on your corner was approved by someone. Find out who, and when they’re up for election.

• Check whether your city uses Flock.
• Request public records for contracts, data-sharing and demo agreements, and log files.

Public hearings and records requests are the only reason any of this is visible at all. Keep showing up.

Three days after the deal closed, Flock, apparently alive to the optics of its employees viewing a community center pool through police cameras, released a blog post titled “Understanding Flock’s Testing and Development Program.” Personally, I would not have chosen to link “employees viewing a gymnastics room” to “testing and development.” But this is Flock.

The issue Flock’s blog post addresses was raised by Dunwoody resident Jason Hunyar and amplified by YouTuber Benn Jordan: Dunwoody PD’s event logs (similar to, but not the same as, the “ALPR audit logs” this site publishes) showed Flock executives had opened camera streams inside the JCC on numerous occasions, for durations the logs don’t record. For the details, see Jason’s write-up and the posts about the April 13 Dunwoody meeting and its outcome.

The post was published under Josh Thomas’ name—the company’s Chief Communications Officer who has been speaking for Flock for the past eight years. It’s not a slapdash production by an engineering manager. His headline reads:

This article explains how Flock tests its technology in real-world environments, strengthens search safeguards, and addresses recent privacy questions about its development practices.

Let’s discuss these topics. And the buried lede.

The Lede Thomas Buried

Tucked into the middle of the post, presented as evidence of a safeguard working, is this:

In Dunwoody, a Flock employee performed a demo of this content moderation policy by searching for both “Star of David”, which our search moderation tool blocked, and “Cowboy hat,” which the search moderation tool allowed.

Flock describes the underlying feature, FreeForm, as a search tool that allows officers to query cameras for descriptive phrases like “man wearing a cowboy hat.” Read that together with the Dunwoody example: a Flock sales employee ran an identifying search against live Dunwoody camera data. The cowboy hat search, per Flock’s own description, returned results—real people, in Dunwoody, identified by what they were wearing, surfaced to a salesperson running a demo. The Star of David search was also made.

The only thing that stopped it from returning a list of Jewish residents of Dunwoody was a content filter Flock built, maintains, and can modify at any time without telling anyone.

Flock presents this as reassuring. It is the opposite.

The architecture underneath the filter is the actual story. Flock’s patent, US 11,416,545, titled “System and method for object based query of video content captured by a dynamic surveillance network,” describes parsing video “for content” and storing it “in a database in connection with data that identifies the content (object class, aspects of the object, confidence scores, time and location data, etc.).”

The patent family extends to neural networks trained to identify clothing, estimate height and weight, and classify other physical characteristics of individuals—stored, by design, in searchable databases. That is an index. It is being built continuously, by design, and is queryable by any user Flock decides gets a search box.

The filters, which are themselves AI-based pattern matching rather than deterministic blocks, block certain query strings against that index. They do not prevent the indexing. The filter can be modified or turned off. If it even works at all.

Flock is asking for credit because its AI blocks certain searches. The thing worth noticing is what those searches are being run against, and who is running them.

Recent Privacy Questions About Development Practices

Now the post’s stated topic. In his post, Jason makes a number of factual allegations, all sourced directly from Flock event logs, before concluding:

On September 30th, 2025 - Bob [Carter, VP Business Development, Flock Safety] looked at just one camera. This camera is in the gymnastics room of the JCC. I personally am curious about why a sales employee from Flock would be viewing the gymnastics room. I think this also deserves an explanation.

…

The public deserves to know why Flock employees are using Dunwoody’s Flock system to look at live videos of people and children in the pool, gymnastic facilities, and fitness studios.

Note what Jason actually asks for: an explanation. Not a prosecution, not a verdict, not a character judgment. An explanation of why sales employees at a surveillance vendor are logged into a police department’s system looking at cameras inside a community center. That question has been outstanding since January, when Jason first brought it to the city council.

In its March meeting, long after Jason first contacted the city, Dunwoody IT presented the results of their security audit. Dunwoody looked at the same logs and found no issues.^[1] They didn’t answer Jason’s question. A month later, the mayor didn’t mention that city staff had already gone over these logs. She didn’t answer Jason’s question.

Now, three months after the question was asked, the answer is delivered via blog post: the employees named online are well-intentioned people who accessed a camera network with the city’s explicit permission, as part of their job, and are now being called predators for it.

Josh Thomas asks us to accept that it is part of his company’s sales executives’ jobs to give sales demos when kids are piled into the pool on a Wednesday afternoon, or when the gymnastics room is in active use on a Tuesday at lunch.

Here is the core of what is verifiable: a Flock executive, who does not work for the police, logged into a police account and opened a camera stream inside the gymnastics room at a community center.

The event logs published by Jason—which Flock does not dispute—show multiple accesses by at least two Flock employees, Bob Carter and Randy Gluck, to cameras inside the JCC across multiple dates in 2025, including cameras pointed at the gymnastics room, pools, and children’s facilities.

But the event logs show when a user starts viewing a stream. They don’t show when a user stops, or any detail to provide critical context. Maybe Flock’s employees now better understand how inadequate logging can facilitate abuse.

We can’t tell if looking up a license plate over and over in the middle of the night with only the stated reason of “investigation” is stalking. We also can’t tell if the “pool” camera was viewed for 30 seconds from a terminal inside a police station, or if it was left running for hours or days on a bedroom TV in another state.

Flock’s employees are seeing the end-result of multiple layers of failed policy, inadequate transparency, insufficient auditing, and no accountability. Employees at a private company should not have unescorted access to police surveillance data. If they had not had access, we would not be having this conversation. It’s that simple.

The principle of least privilege is not optional; it’s AC-6 under CJIS Security Policy v6.0; access should be limited to what’s “necessary to accomplish assigned organizational tasks.”^[2] Vendor and contractor access falls under PS-7 (External Personnel Security). Account management is AC-2. And the audit controls that would normally catch any of this are in AU-2 and AU-3, and AU-9. Nearly-identical controls exist under SOC 2 and ISO 27001. Both certifications Flock touts.

Months after the issue was first raised, Flock now claims the activity was approved under “the city’s demo partner agreement.” Flock did not provide its terms. Dunwoody never produced it in response to Jason’s open records requests. Flock employees at the March and April meetings didn’t mention it. The police chief and IT director stayed silent on it during the audit presentation at the March meeting. The mayor didn’t mention it when she addressed the issue at the April council meeting.

Dunwoody has now signed the deal. The incentive to stay on-message is gone, and Flock has moved directly to publicly accusing its “partner” of hiding an agreement as a post-hoc justification of its violation of public trust.

On Being Accused of Accusing People

Flock’s post includes this line, which is the most carefully lawyered sentence in it:

Accusing someone of spying on children is not a policy disagreement; it is a life-altering allegation.

Correct. Fortunately, no one in this story has made that accusation. Jason asked for an explanation—in writing, to the Dunwoody city council, on January 12, and every month since. What Flock has now done, three months later, is respond to an accusation Jason did not make.

Flock employees had the technical capability to watch children at a community center and accessed cameras pointed at those children. Whether any individual Flock employee used that capability maliciously is unknown and largely beside the point. The capability is the problem. The access is the problem. The absence of any meaningful oversight is the problem.

Josh Thomas would like the story to be about what is in a sales executive’s heart, because that is a story he can win. The story he can’t win is the one about Flock’s architecture.

What the Logs Actually Show

Flock’s post frames the Dunwoody events as a single routine demo at an unusually sensitive location. The event logs Jason obtained by open records request show 185 JCC-camera accesses by Flock VP Bob Carter alone since January 2025.

The network sharing is even worse. The JCC’s private camera network, labeled in Flock’s system “Dunwoody GA PD - Atlanta JCC Avigilon (Do Not Share),” was at one point actively shared by Dunwoody PD with three outside agencies, including Lawrenceville GA PD, which received permissions to view, record, and download live video streams.

That sharing was removed only after Jason disclosed it to Dunwoody’s chief, and the removal was performed by a user (“John Watson”) not in the user export—which should include historical users. A ghost administrator corrected a misconfiguration that was not supposed to exist in the first place.

At the March council meeting, Dunwoody’s own lieutenant told the public that only two neighboring agencies view live streams and that liveview access is “strictly reviewed and on a case by case basis.” The logs show 1,271 agencies with access. The logs show no access by any agency, including the two confirmed active users.

This is the environment in which Flock employees, in Josh Thomas’s description, are “well-intentioned” and “accessed a camera network with the city’s explicit permission.”

They may be. There is no way to know.

Strengthened Search Safeguards

This takes up the most space in Flock’s post; we can keep it short here. Flock describes its existing broken AI-based “FreeForm” moderation system, which did exactly nothing to prevent anything that happened here.

Testing Technology in Real World Environments

Mentioned in the same breath as “development practices.” Flock does not distinguish between “development,” “testing,” and “production”—in its post or in practice. It’s not an uncommon problem for venture-backed software companies, but it’s not a small one for Flock. I have written about this many times before, and Flock continues to signal it will do nothing to address it.

Flock’s approach is to let its developers and sales execs loose on a real police department’s account, connected to real cameras, pointed at real people—and, yes, real children.

The Cybertruck example Flock offers is this:

Here’s a concrete example: when the Tesla Cybertruck came out, we had to build a whole new ML algorithm to identify it. Nothing had been seen like that before. This requires testing and training the models in real-world conditions.

“A whole new ML algorithm” is an overstatement. Flock was failing to detect the Cybertruck as a car (or truck, or whatever it is). That’s a training task, not a new algorithm, and an entire industry exists to support exactly that kind of image-recognition training.

Even if Flock does all its ML work in-house, whether overseas or not, and uses only data collected under its government contracts, all it requires is an image and someone to answer: “Cybertruck or not Cybertruck?”

Nobody at Flock needs access to a police account. Not for software development. Not for sales demos.

The Remediation

Flock describes its fix this way:

Although the camera was only viewed once during a routine demo, we understand that this is a sensitive location for many. We have therefore determined that employees will be trained to only conduct demos in more public locations, like retail parking lots.

So the reform is: Flock sales employees will continue to log into police surveillance systems, run demos against live resident data, and view live camera feeds. They will just point the cameras at people and children in more public places.

There is no commitment to stop using production police accounts for sales demos. No commitment to separate development, test, and production environments. No commitment to publish the demo partner agreements. No commitment to audit, retroactively, every access a Flock employee has made to Dunwoody’s cameras. No changes to the logs themselves. Nothing structural.

Jason’s records work also documented Flock employees using Dunwoody’s system to create API connections to third parties with whom Dunwoody has no contract; data funneled through those integrations falls outside any contractual framework. This will not be addressed.

Flock’s repetition that “local agencies—not Flock—control who can access their data” falls especially flat when it’s delivered in the same post where Flock argues that it needs access to that data because it “must be tested and demoed, both to ensure we get everything right on the technical side and so other agencies and businesses understand how the sharing works.”

If Dunwoody PD authorized Flock to share these video streams with “other agencies and businesses” then that is perhaps even more problematic than broken vendor policies and architectures. It’s a police agency acting entirely outside of the scope of its lawful duties to the detriment of the local community.

If true—if the Dunwoody chief of police allowed video from within the community center to be shared with “other agencies and businesses” without being authorized to do so by the council—he deserves to be held accountable.

The signature on the demo agreement will tell.

Addendum to My Previous Post

In my previous post I wrote:

The city’s new MSA does not prohibit Flock from accessing Dunwoody’s account, and continues to grant Flock a royalty-free license to “support and improve Flock’s products and services,” which arguably describes what happened here. The license has no specified term and cannot be revoked.

That remains true, but it understated Flock’s asserted basis for access. I had assumed Flock would rely on its license for business purposes. Instead, per the blog post:

Similarly, one of the benefits communities most value about Flock technology is the ability for law enforcement to directly access privately owned cameras, if and only if the organization allows them to, for crime-solving and security purposes. This is also a feature that must be tested and demoed, both to ensure we get everything right on the technical side and so other agencies and businesses understand how the sharing works.

In a deeply Nixonian “when I do it it’s not illegal” move, Flock treats “demos” for “other agencies and businesses” as part of the government agency’s “crime-solving and security purposes.”

That’s Flock’s real-world interpretation of “the customer owns 100% of the data” and “Flock does not access the data.”

What You Can Do

Flock has now publicly asserted that side agreements authorizing vendor access to police surveillance systems are standard practice. If that is true, such agreements may exist in your city.

They are almost certainly not posted on any public agenda. They were not, in Dunwoody, produced in response to ordinary records requests until Flock itself acknowledged them.

Consider filing a public-records request with your city or police department for any agreement or other record showing whether your agency has entered into a demo or testing arrangement with Flock.

If you obtain any such agreements, or if your agency confirms none exist, I’d love it if you let me know.

Parents across the country have a right to know whether Flock employees are watching cameras in their local daycares, community centers, and schools—whether the reason is software development, testing, sales demos, or something else.

The city also entered into a contract for FlockOS 911 that will see call data transferred to Invictus, under an order form that incorporates Flock’s standard website terms and a separate set of Prepared911 terms rather than the MSA the city just negotiated. The city’s existing Flock-provided contract with ForceMetrics for sensitive, federally-regulated criminal justice information and health data did not get a mention at all in either the meeting or the new MSA.

The most controversial aspect of the relationship, that Flock employees on Dunwoody’s account had been caught watching the pool and gymnastics room at the community center, was vaguely explained and addressed only through platitudes before being hand-waved away.

If your city has Flock cameras, the contract almost certainly contains the same structural problems described below. Flock’s standard terms give it effective ownership of your data, cap its liability at near-zero, and leave critical regulatory obligations undefined. Dunwoody tried to negotiate and still ended up here.

Sales Demos and Empty Promises

The explanation was that Flock had been using the cameras in the gymnastics center for its sales demos. It wasn’t a case of Flock executives watching children, the mayor assured the crowd. It was Flock executives showing children to some unnamed third party to sell its product. This, in the council’s view, made the situation better somehow.

The city’s new MSA does not prohibit Flock from accessing Dunwoody’s account, and continues to grant Flock a royalty-free license to “support and improve Flock’s products and services,” which arguably describes what happened here. The license has no specified term and cannot be revoked.

The city will also continue to pay^[1] to send video surveillance footage from inside the privately-owned and -operated rec center and daycare to Flock.

But, rather than write safeguards into the agreement up for a vote, residents were told Flock had promised not to do it again. In the future, Flock promises, it will not expose images of Dunwoody children practicing gymnastics or going for a swim as marketing materials for its sales prospects.

The council accepted the explanation and the promise at face-value and without further inquiry.

What Dunwoody Didn’t Win

A day before the meeting, councilmember Joe Seconder had told Jason Hunyar, the soon-to-be Dunwoody Dad who discovered Flock’s viewing of the rec center, that the MSA would be raised “as a discussion item, not a vote.” This would be so “there will be additional time to provide feedback on the MSA … and what kind of revisions we can have set forth before a vote is held by council.”

Councilmember Seconder voted to adopt the MSA at that same meeting.

@Master Service Agreement

It prohibits Flock from using Customer Data “to train, fine-tune, or improve any machine learning, artificial intelligence, or algorithmic models” without written authorization from the City Manager. An email suffices.

It contractually mandates existing Flock features for data governance: a Federal Sharing Toggle that lets the city disable all data sharing with federal agencies (as defined by Flock), and a toggle to require case numbers and search justification for every query. Neither feature has to be enabled, but both must exist.

It contractually includes Flock’s “audit log masking”, where Flock no longer exposes the complete audit trail to its customers, framing it as a measure “to protect active investigations, law-enforcement operations, and sensitive data.”

It also requires a post-login CJIS acknowledgment requirement. Never mind that the aforementioned audit logs are a required component of CJIS compliance.

It freezes Flock’s incorporated Online Terms as of the Effective Date and bars unilateral changes without a written amendment signed by the Mayor or City Manager — but stops short at requiring council approval to modify the agreement approved by council.

These are concessions that sound good but collapse under even minimal scrutiny. They do not address the structural problems that make the rest of the contract a liability.

What Dunwoody Lost

The standard terms that place effective data ownership with Flock are left unmodified:

Flock retains the exclusive right to determine and control the method, timing, format, and medium of access or delivery of Customer Data … and is not obligated to provide Customer Data in any alternative form, format or transmission method outside of the Web Interface.

It’s not your data if you can’t access it and Flock doesn’t have to hand it over. It’s also not definitionally your data:

For clarity, Flock Property also includes any derivative works, intermediate or final outputs, analyses, reports, models, or other results generated by or through the Flock Services. Except for the limited ability to access and download Customer Data within the applicable Retention Period, no rights are granted to download, extract, export, or otherwise create or retain copies of such derivative works, outputs, or other elements of Flock Property.

A license plate number, a vehicle description, and arguably the raw image that Dunwoody won’t be able to access are a “derivative work,” “output,” or “result” “generated by or through the Flock Services.” “No rights are granted” to Dunwoody to any of this data.

Until the city manager sends an email, the AI/ML restriction limits what Flock can do with Customer Data for model training. It does nothing about data Flock classifies as Flock Property.

The Battle of the Order Forms

The city’s outside counsel assured the city council that the MSA with Flock would govern the city’s agreement with Invictus. She did not explain how the MSA, between Flock and Dunwoody, applies to an agreement with a separate company. She addressed the incorporation of Flock’s online terms by conclusorily asserting that the MSA would control; a possibility, not a given.

The FlockOS 911 order form does not incorporate the MSA. It incorporates the terms and conditions on Flock’s website and the Prepared911 Terms and Conditions at a separate URL. The council’s motion conditioned approval on execution of the MSA, but a condition precedent to signing is not the same as incorporating the MSA’s terms into the document being signed. The order form still says what it says. The council unanimously voted to sign the form that incorporates those terms rather than cross out the references and explicitly incorporate the MSA.

If Flock were to make the argument that the MSA does not govern the FlockOS 911 contract, it would have a strong position; the council agreed to the terms after adopting the MSA, and the MSA’s governance does not definitively follow from its structure:

The MSA defines “Agreement” to be the MSA plus any Order Forms. Its conflict-resolution clause handles conflicts between the “Agreement” (which includes the Order Form) and (1) any statement of work or purchase order, (2) special terms listed on an order form, (3) incorporated online terms. Conflicts between the “Agreement” and any “Order Form” (which is a part of the “Agreement”) are left unaddressed, because they are definitionally the same document.

$0 Liability

It’s a circular structure that’s especially damaging in the case of the Drone-as-First-Responder (DFR) contract:

1. Dunwoody signed a DFR agreement at some unspecified earlier date.^[2]
2. The MSA is executed. It “supersedes all prior agreements, understandings, and representations relating to the Flock Services.” The original DFR agreement is now dead.
3. The new DFR Order Form, approved during the April meeting, is executed “on the date hereof or following the Effective Date,” so it’s automatically part of the “Agreement.”

But the new Order Form incorporates “the previously executed agreement,” the document the MSA just killed in Step 2. It’s trying to resurrect terms that the Entire Agreement clause superseded. The conflict clause can’t resolve this. Not because it wasn’t designed for necromancy but because the new Order Form can’t conflict with the Agreement because it is the Agreement. There’s no hierarchy for resolving an internal contradiction within the Agreement itself.

The city is prepaying $200,000 for “Flock Hardware” it does not own and cannot maintain, per the MSA,^[3] but that’s not even the worst part: the MSA caps Flock’s aggregate liability at the total amount paid in the twelve months before a claim arises. Because the entire $200,000 is due at signing, in year two the amount paid in the preceding twelve months will be $0. Flock will carry no financial liability at all for operating an aircraft under contract with Dunwoody.

Drones, like any aircraft, are heavily regulated by the FAA. Those regulations are complex and violations can lead to severe penalties. Unsafe drone operations endanger other aircraft and persons on the ground. It wouldn’t be the first time a police drone collided with another aircraft.^[4]

Pricing

The pricing on the drone contracts is opaque. The first DFR Order Form lists a $300,000 contract total: $100,000 due in July 2025 and $200,000 recurring in January 2026, with a $160,699.50 discount on “Flock Safety Drone Hardware and Services”:

The second shows $200,000 due at signing with no discounts at all:

The first order is for “Flock Safety DFR 2.0 - 400ft”. The second for “Flock DFR - M4TD + Dock 3 (2 System Set)” and “Flock911 for Aerodome”. All items are priced as “included” under a platform fee that conceals the cost of each component.

Chief Carlson’s memo describes the second agreement as “the installation of additional DFR (Drone as First Responder) coverage,” which, I’m told, means Flock will add an additional drone.

Agreements All the Way Down

The original DFR agreement, the “previously executed agreement” on the order form, is an 11-page contract with a Product Addendum for “Unmanned Air Support as a Service,” two schedules covering training and specifications, and terms that place virtually all operational liability on the city.

@The original Dunwoody-Flock Drone Agreement

That agreement itself incorporates another “previously executed agreement” on its order form. That appears to be a “Government Customer Service Agreement” from 2021, which is specific to ALPR.

The original drone agreement makes Dunwoody responsible for ensuring that all crew, including pilots, visual observers, and sensor operators, hold the qualifications and certificates required by applicable FAA regulations. It also assigns the city “the entire risk of loss, damage to, theft or destruction of, all Flock Hardware” and states, in all capitals, that loss or damage “SHALL NOT RELIEVE CUSTOMER OF ANY OBLIGATION UNDER THE AGREEMENT.”

The agreement carves all drone data, including flight logs, telemetry, radar, and fleet information, out of Customer Data entirely. It classifies it as “Flock Drone IP” owned exclusively by Flock. The city cannot share any of it with third parties without Flock’s written consent. That restriction says “any third party” without an exception for regulatory authorities, covering the patently absurd situation where the city’s pilots can’t disclose flight logs or telemetry to the FAA or even ATC.

None of this is in the MSA that council reviewed and approved. The MSA has no terms concerning the drone program. If counsel is right that the MSA controls, the original drone terms are dead and there is nothing governing drone operations, FAA certification, pilot responsibilities, or risk of loss.

If the original terms survive through the Order Form’s incorporation clause, Dunwoody is responsible for everything: the pilots, the certifications, the waivers, the airworthiness, and the losses, while Flock owns the data the drones generate. Because it’s an order form, the MSA’s conflicts clause is inapplicable.

Either way, council and residents were told they had a negotiated deal: they don’t.

The State of Madlibs

Then there are the ForceMetrics terms signed by the city. Those were stapled to a Flock order form in February 2025. ForceMetrics is a data aggregation and analytics platform that pulls together internal databases like CAD (dispatch), RMS (records management), and JMS (jail management).

@ForceMetrics Terms and Conditions

The “Informed Responder” product Dunwoody uses “surfac[es] real-time Safety Signals in search results,” to give “first responders quick, actionable insights into critical risks—such as mental health issues, dementia, drug use and domestic violence.”

The ForceMetrics agreement assigns itself a forever-license and ownership of all “Derived Data”, and claims to be the “final, complete and exclusive agreement between the Parties relating to the subject matter hereof”.

ForceMetrics receives federally-regulated criminal history record information and criminal justice information, like names, addresses, and domestic violence histories. It also gets information about mental health and substance history, categories that may be federally protected health information.

To add to this mess, the ForceMetrics terms set a different liability cap (“[t]o the extent authorized by the constitution and the laws of the State of ____,” nobody filled in the blank) and say any conflicts will be handled according to Colorado, not Georgia, law.

Flock Understands and Acknowledges

At the meeting, the most bizarre clause in the agreement was not questioned by council:

Flock understands and acknowledges that prior to Customer contracting for or using any new Flock Services that it does not use as of the Effective Date, Customer must obtain approval from the City Manager of Customer

Why Flock’s understanding matters is anyone’s guess. It could be a way to nullify any effect of the clause because it doesn’t place an affirmative duty on anyone, it merely says Flock understands something. At least someone does.

Looking past that, “any new Flock Services” presumably come with additional legal terms. Those terms, as we’ve seen here, tend to have significant effects on liability and obligations. For example, when the Flock Services send 911 caller data to parties like Invictus, or when the Flock Services come with a requirement to maintain FAA-certification.

In any organization with even slight governance in place, entering into those types of agreements is not something a staff member should be able to do, with or without city manager approval. The city attorney and city council should have a say.

Not here. Dunwoody PD will keep signing agreements without legal review or council approval. Flock will continue to operate its Dunwoody Lab as it has for years.

The MSA requires some software toggles without requiring a setting. The AI-training prohibition can, and likely will, be easily voided via an email from the city manager. Every single structural problem is left untouched: the data ownership, the liability cap that zeroes out on a prepaid contract, the order form chain that either governs nothing or governs too much, the ForceMetrics terms governed by a different state’s law with an unfilled blank in the indemnity clause, and the 911 contract that exists entirely outside of the scope of the MSA.

If there is ever a contractual violation severe enough not to be hand-waved away, one the PD and council find more concerning than using children in the pool for sales demos, Dunwoody will now have to spend a small fortune on litigating the mess it has allowed Flock to create.

Of course, when such contractual violations can be waved away with a vague assurance that it won’t happen again, Dunwoody is unlikely to stand up to Flock and to assert its contractual rights.

A public commenter characterized the relationship as abusive. That’s exactly what it looks like.

The Search IDs

Around the time Flock made heavy-handed edits to existing government records, it added, or started to expose, an “id” field along with search results. From the outset, haveibeenflocked.com has ignored that field because Flock can’t be trusted to keep anything stable. As we’ll see here.

I don’t use Flock’s IDs and instead rely on other methods to handle duplicate entries, so I mostly ignore them. Then I received an email from someone who paid more attention. He had been manually downloading audit logs from transparency portals and comparing the files, noticing that entries change more than they should.

To be honest, I didn’t really believe him at first. It sounded implausible even for Flock to do something so technically terrible. Egg on my face.

Transparency portal search logs now typically look something like this:

e71b39a6-3cc8-4161-b4ec-e62c6e1cd135,***,2026-03-04T20:37:04.924Z,6050,invest

Because cops can’t be trusted with cop data, Flock’s network logs look about the same. In addition to the ID, they have a name of an agency. The idea is that an auditing PD will pick up the phone, relay the ID in their network log to the named agency, and verify that “invest” was a legitimate search.

With about 6,000 agencies doing 10,000+ searches per day, that’s a lot of phone calls.

This idea is obviously completely divorced from reality to begin with, but it’s being used — to great effect — to convince uncritical elected officials of the existence of accountability.

Now, I’m not sure what cops are supposed to do.

The Time and ID Changes

The transparency portal logs are produced on a 30 day rolling basis. So, if you downloaded the same log a day apart, you’d expect to see 29 days worth of identical records with one day trimmed and one day added. However …

On March 23, 2026, West Des Moines’ log showed these two searches:

e71b39a6-3cc8-4161-b4ec-e62c6e1cd135,***,2026-03-04T20:37:04.924Z,6050,invest
bc377b4b-2261-4fe1-a96c-ebb59217c061,***,2026-03-04T21:00:31.190Z,6051,invest

Two searches on March 4, both labeled “invest,” one at 8:37pm (UTC), and one at 9pm (UTC).

On March 24, 2026, they are both gone. In their place are two new searches:

9c685baa-cf80-478c-acf1-2df174a1d686,***,2026-03-04T20:26:48.972Z,6050,invest
ec162dff-51b1-4de6-be2d-16a2b2cd8411,***,2026-03-04T21:39:47.263Z,6051,invest

The also both happened on March 4, and are both labeled “invest,” but now one happened at 8:26pm (UTC) and the other at 9:39pm (UTC). That’s a significant difference.

If the same change happened in network logs, and if anyone had made that phone call about search ID e71b39a6-3cc8-4161-b4ec-e62c6e1cd135, they would have to make another phone call about the search that replaced it: 9c685baa-cf80-478c-acf1-2df174a1d686.

The problem appears broad. In the March 23 – 24 comparison alone (about 200 lines total) there were multiple changes:

-b76afd28-1246-4b3d-91d7-5f14642dd191,***,2026-02-25T20:56:59.751Z,2,Windsor Heights Fresh Stolen
+72db34f8-dd39-4d5d-814c-c968cb5e58b2,***,2026-02-25T20:52:17.101Z,2,Windsor Heights Fresh Stolen

-e71b39a6-3cc8-4161-b4ec-e62c6e1cd135,***,2026-03-04T20:37:04.924Z,6050,invest
-bc377b4b-2261-4fe1-a96c-ebb59217c061,***,2026-03-04T21:00:31.190Z,6051,invest
+9c685baa-cf80-478c-acf1-2df174a1d686,***,2026-03-04T20:26:48.972Z,6050,invest
+ec162dff-51b1-4de6-be2d-16a2b2cd8411,***,2026-03-04T21:39:47.263Z,6051,invest

-b8afc2dc-434c-41e3-8614-92134e713de8,***,2026-03-05T07:58:19.466Z,1169,
+3c652fad-db99-472f-bf7a-16430beb949d,***,2026-03-05T07:01:14.526Z,1169,

+8e10d1fb-2b66-4a0a-b4a8-2ef4b4f33899,***,2026-03-15T05:12:16.454Z,1,invest
-95134732-9341-420e-b830-901856bd4a75,***,2026-03-15T05:39:30.257Z,1167,invest

-e6941d9c-fbf2-4cbb-a54b-7c5d1fd391cb,***,2026-03-19T18:49:41.776Z,1166,
-d277a79e-0a14-4ccd-a561-8df2cfb7ca10,***,2026-03-19T19:00:37.487Z,1166,
+6f9738b1-1fbf-498a-b026-c8eda3d3aece,***,2026-03-19T18:22:11.557Z,2,
+18bf73c6-e37c-4246-ab1c-f98aae2849a6,***,2026-03-19T19:14:27.501Z,1166,

In this one file, about 7% of records changed within 24 hours.

Clanker Analysis

Asking the clanker to analyze the changes over multiple files it wrote a little Python script and produced:

WDM (8 snapshots, Mar 16 - Apr 4)

Non-rolling change rate per snapshot pair: 2.6% - 7.1% (avg ~5%)

Key patterns:

• Removals always equal additions — records are being swapped, not just deleted or added. This is highly suspicious and suggests some kind of rotation/replacement mechanism.
• No field modifications — records are never edited in place; they vanish and a different record with the same date appears.
• 17 “flickering” records that disappear and reappear across snapshots. Example: 95134732... (date 03-15) appears in only the 03-23 and 03-25 snapshots out of 8 — pattern ..Y.Y...

Johnston (3 snapshots)

Similar pattern: 3.9% - 8.2% non-rolling change rate, removals always equal additions, 2 flickering records.

The Takeaway (AI)

When it was done running its script, it gave its unsolicited, but almost accurate “key takeaway”:

The audit logs are not immutable. Every day, ~3-7% of records within the overlapping date window are swapped out (equal number removed and added, zero modifications). Some records flicker in and out across multiple snapshots, meaning the same record can be removed, reappear, and be removed again. This is consistent with records being retroactively added/removed from the audit log on an ongoing basis.

The Actual Takeaway

This is the straightforward explanation, but it’s not necessarily what’s happening. What could be happening is that Flock, like Axon, is distributing its database in an effort to sidestep accountability and ownership by conflating data control and data ownership.

I’ve called this nonsense out before as Flock saying the kitchen is not a central repository for pots and pans, because it has multiple cupboards.

But it may be what we’re seeing here. The log could be pulling in different entries from different “cupboards”, and not all “cupboards” may be available each time the log runs.

A distributed explanation is not any better than deleting and adding records in a centralized database. In fact, it would be a very fundamental, very fatal, flaw for records that are supposed to be immutable — like audit records — to have multiple copies in multiple places without a single authoritative copy.

Apparently log entries can go missing without Flock’s system throwing an error. If you can’t be sure that your log is complete, you can’t rely on it to show whatever it is you’re auditing for — it may have been deleted.

If you’re getting new results every day, your previous audits are automatically invalid and unreliable. A search that occurred at 9pm may look valid, but if a police officer goes off shift at 9:30pm and the next day the log shows the search happened at 9:45pm, that’s potentially unflagged off-duty use of a police system.

It could also cut the other way: the officer’s shift might not start until 9:30pm, and the logs will show improper use the first time around, but not the second (if anyone looks).

Network Logs

These observations are from transparency portal logs, which are largely performative to begin with. Whether the same holds in a network audit remains to be confirmed.

Examining older network logs, which did not have the IDs, entries can be seen disappearing between runs. Because I do not have enough overlapping data to fully confirm, I can only say that it seems very likely that the observed ID changes in West Des Moines and Johnston show a structural problem that has existed for a while now.

This finding alone should be cause to invalidate all prior audits, as well as all future audits until Flock addresses the problem.

States with mandatory audits, like Minnesota, and police departments with audit requirements, will have to redo their audits after it’s fixed. That’s a lot of phone calls.

That is, if they want to make good on their promises of accountability and oversight.

I won’t be waiting by the phone.

Via IPVM and KSHB

The company got caught sending data to Upwork contractors and Denmark. The CEO declares Flock is under attack. The CISO denies high-profile, very real security issues. The permit manager installs cameras without adequate permits in California, Iowa, and other states. The VP of Solution Engineering redacts information from log files. The Chief Legal Officer appears on niche livestreams. And marketing, seemingly sponsored by the City of Dunwoody, pumps out questionable videos.^[1]

You’d think Flock has enough to worry about at home. Now it’s going international.

We already know what Flock’s jurisdictional sprawl looks like domestically. The Virgin Islands Police Department — a Caribbean territory under an active DOJ consent decree for unconstitutional policing — was caught querying Flock cameras in Rogers, Arkansas for stolen vehicles and traffic violations. No one in Flock’s 5,000+-agency network — including Flock and the state agencies responsible for criminal justice information — has flagged that absurdity.

Now take that indifference and remove the American legal framework entirely.

Flock’s first(?) international reseller is Vumacam. A Johannesburg-based company that has been accused of building a digital apartheid, charged by regulators for operating without a license, and caught making false claims under oath about data protection compliance.

Sounds about right.

The Partner: Ricky Croock

Flock’s partner page lists Vumacam as a “channel provider”:

Vumacam is Flock Safety’s reseller partner in South Africa. The partnership extends Flock’s technology internationally, fostering safer communities abroad.

Via Ricky Croock's LinkedIn (spelled as "Ricky Crook" here).

Vumacam operates a network of over 7,000 cameras across South Africa’s Gauteng province — the majority concentrated in Johannesburg. The company was founded by Ricky Croock, a former private security operator who previously ran CSS Tactical, a company providing armed response, guarding, and CCTV services.

If you thought the Flock model couldn’t get worse: Croock found a way. Vumacam builds and maintains the camera infrastructure — poles, cameras, connectivity — and then sells access to private security companies, who pay a monthly fee for video feeds in their patrol areas.

The network includes over 2,000 automatic license plate recognition cameras that, as of 2021, scanned an estimated 9.68 million vehicle registrations per day. That figure has likely grown substantially alongside the network’s expansion to 7,000 cameras.

If this sounds like Flock, that’s because it is.

Croock and Vumacam’s History

The critical reporting on Vumacam is extensive, spanning investigations by MIT Technology Review, Daily Maverick, VICE, and the Pulitzer Center.

Operating Without Registration

South Africa’s Private Security Industry Regulatory Authority (PSIRA) charged both Vumacam and Croock personally with a code of conduct violation for operating a security business while unregistered with the authority.^[2] Police opened a parallel criminal investigation. Vumacam subsequently registered, but PSIRA confirmed both the criminal case and the code of conduct probe remained active.

For a company building a city-wide surveillance network, the sequence is notable: deploy first, register later. Flock has its own version of this approach where hundreds of cameras were installed on public roads without permits across Florida, Illinois, South Carolina, Texas, and North Carolina, with an Illinois DOT official receiving a thinly veiled threat that Flock would send “about 30 different police chiefs” to the office if permits weren’t fast-tracked. And that’s just the states that have taken some form of action.

Lying Under Oath

In a sworn affidavit to the Gauteng High Court, Croock stated that Milestone VMS — the video management software Vumacam uses — was “certified GDPR-compliant under the General Data Protection Regulation applicable under European Union law.” Daily Maverick’s investigation found this was not true. EuroPriSe, the certification body, had not officially accredited Milestone; the application was still pending.

Croock also told the court that Milestone “ensures responsible use of data by end users.” Milestone’s documentation says the opposite: users, not the software, bear responsibility for compliance.

We’ve heard these types of assertions before. Flock’s CEO Garrett Langley told the public that Flock had no federal contracts. That was also not true. Flock was running a pilot program giving Customs and Border Protection and ICE direct access to data from its cameras. After information about the program became public, Flock stated it shut it down, but quietly continued to run it.

And, of course, Flock has also claimed all sorts of compliance, including compliance with HECVAT, which is a vendor evaluation form, and CJIS ACE — a commercial certificate, every bit as valid as the official Certified Privacy Advocate Certificate from haveibeenflocked.com.

“We don’t track people or cars”

Exactly like Flock claims in the US, Vumacam has publicly claimed its system “does not track people or cars.” The company’s marketing materials also echo Flock’s — which makes sense, given it is a reseller — and show that the system can retrospectively map a vehicle’s complete movements over 30 days. Precisely the definition of tracking.

Private security companies can add registration numbers to watchlists without court orders. Police can request location data through private security databases without subpoenas or warrants.

That’s true in America and South Africa.

Digital Apartheid

The “digital apartheid” criticism is the most damning line of criticism against Vumacam, and it’s also the most structurally relevant to understanding what Flock’s technology does, both domestically and abroad.

A SafeCity pole in Sandton, in northern Johannesburg.

Vumacam deployed its cameras almost exclusively in affluent, predominantly white suburbs of Johannesburg because that’s where paying customers were. Poor Black townships were left uncovered, not out of principle, but because there was no revenue model — nobody hires ADT or other security companies there. The result is a surveillance geography that maps onto apartheid-era spatial divisions with uncomfortable precision.

Flock declines to release its camera locations and many cities have refused to release Deployment Plans and other documentation. Efforts like Deflock are underway and are beginning to draw Flock devices on the same maps as America’s apartheid-era redlined districts.

A leaked shift report from Fibrehoods, a Vumacam partner, documented 14 incidents flagging 28 people as “suspicious.” — a term that’s commonly found in Flock logs as a “justification” for retrieving 30-day location histories. All 28 “suspicious” persons in the shift report were Black. The suburbs in question were majority-white.

Michael Kwet, a visiting fellow at Yale Law School who studies the South African surveillance industry, drew a direct line to the apartheid-era dompas — the internal passport system that restricted Black people’s movement in white enclaves. Vumacam (x Flock)'s AI-powered camera network recreates this digitally: Black residents in historically white suburbs are surveilled, flagged, and tracked.

Police in the US say they need Flock to stop them from pulling Black people out of cars at gunpoint. South Africa shows what actually happens when surveillance infrastructure is deployed by private companies in a society with deep racial stratification.

Intent is irrelevant. The business model is what matters.

Why This Partnership Matters

Flock’s domestic troubles are well-documented on this site and elsewhere. Secret data sharing, secret employee access to camera networks, cameras installed without permits, a CEO who goes ballistic rather than address concerns, and these types of hits keep on coming while the company only offers empty promises through increasingly snazzy marketing videos.

The Vumacam partnership introduces something new. The Virgin Islands querying Arkansas cameras was a preview — absurd, unmonitored, jurisdictionally incoherent, but still technically domestic. It’s the diet version of what’s happening in South Africa.

In the United States, Flock’s surveillance network technically operates within — however loosely and poorly enforced — a framework of Fourth Amendment protections, state privacy laws, US DoJ policies, FOIA requests, city council votes, and the kind of public pressure that gets contracts canceled.

In South Africa, Vumacam successfully sued the Johannesburg Roads Agency when the agency tried to suspend its camera permits, and the court ruled that the JRA’s job was to protect road infrastructure, not human rights. No civil society organization has brought a subsequent case. The Information Regulator’s investigation into POPIA compliance appears to have produced no public enforcement action.

Flock gets to sell its technology into this environment through a reseller. It is insulated from direct accountability while Vumacam gets access to the surveillance platform of a $7.5 billion company backed by Andreessen Horowitz and Founders Fund.

Vumacam wants to be Flock as much as Flock wants to be Vumacam.

The Response

SafeCity — featured in the backdrop for the event photo where Flock, Matrix, and Vumacam promote the partnership — is Vumacam’s premium product tier. It is the pitch to government. In February 2024, Vumacam announced a partnership with the Gauteng provincial government giving officials access to a network of over 6,000 cameras and “advanced crime-fighting technologies.”

Response times dropped, the company says, from 18–30 minutes to 5–10 minutes.

Last month, in March 2026, apartheid police commander Eugene de Kock, nicknamed “Prime Evil” testified in court about the atrocities he committed in the name of public safety.

Now, South Africa evaluates a high-tech mass surveillance network that replicates apartheid-era movement controls and lack of oversight that let Prime Evil act with impunity when his security forces abducted, tortured and killed activists.

When Flock’s critics — “activists” mounting a “coordinated attack” according to its CEO — warn about what happens when surveillance infrastructure scales without democratic oversight, they don’t speak in hypotheticals.

Johannesburg proves the outcome: Apartheid 2.0, powered by Flock.

In 2021, the Riverside County Transportation Department issued the first of three encroachment permits to the Riverside County Sheriff’s Department for the installation of Flock Safety cameras on county roads. By October 2023, the Board of Supervisors had unanimously approved a $6.9 million contract to expand the program to 538 cameras.

Four and a half years later, the Riverside County Sheriff’s Department’s Flock Transparency Portal shows the sheriff uses 1,718 “LPR and other cameras.”

A CPRA request to the Transportation Department produced three permits, a handful of emails, and a sworn declaration that may be more interesting than the permits themselves.

The Permits

Riverside County Ordinance 499 governs encroachments within county highway right-of-way. Any structure placed in the road right-of-way — including 13-foot surveillance poles with cameras and solar panels — requires a written permit from the Director of Transportation.

@Riverside County Ordinance 499 (as amended through 499.16)

Three such permits were issued:

ENC21120546 (December 10, 2021 – September 1, 2023)

Originally authorized two cameras. Expanded through riders to cover 33 named locations and a blanket permission to add more via individual location notifications (RD Form 136).

@ENC21120546 — Original Permit

@ENC21120546 — Rider 1

@ENC21120546 — Rider 2

ENC23110539 (November 14, 2023 – November 14, 2024)

An annual blanket permit covering “various county road rights of way.” This permit was explicitly styled as an extension of the first.

@ENC23110539 — Second Blanket Permit

ENC25061408 (December 5, 2025 – December 5, 2026)

Another annual blanket permit, the current one. It was issued with a single RD Form 136 notification on file — one camera, in Anza — and four total documents in the folder.

@ENC25061408 — Current Blanket Permit

No Permit, No Problem

The second permit expired on November 14, 2024. The third was not issued until December 5, 2025.^[1]

During those 13 months, the cameras did not come down. The $6.9 million contract continued and Flock’s operations apparently continued without interruption under Riverside County Sheriff and Republican gubernatorial candidate Chad Bianco’s watch.

Ordinance 499 Section 6 prohibits anyone from “constructing, installing, operating, or maintaining” any structure in the county right-of-way without a permit. That’s not limited to construction — it covers the cameras just sitting there running.

The permits themselves reinforce this. The authorized work is not just installation — each permit grants permission to “install, operate and maintain” the cameras. Each is “to be strictly construed and no work other than that specifically mentioned above authorized hereby.”

When the permit expires, so does the authorization to operate and maintain. The first permit’s void date was extended twice via riders — acts that only make sense if the date is an operative constraint. And in December 2025, the county issued a replacement permit with identical scope and authorization language. If the prior permit was still valid, the replacement was redundant.

The second permit’s own conditions made the obligation explicit. Condition M12 on ENC23110539 states: “Upon expiration of this permit, the permittee shall remove the temporary poles and cable.”^[2] The current permit repeats this language and adds: “It is the Permittees responsibility to maintain a valid permit.” The permittee did neither.

Nothing was removed. No extension was obtained. No replacement was issued for thirteen months.

The CPRA request covered all encroachment permits issued between January 2020 and March 2026. The county produced exactly three. The county certified under oath that no other encroachment permit, extension, or authorization exists.

No Application, No Problem

The county requires each permit application to be “in the name of the person, agency, entity, or authorized agent owning the encroachment and controlling the construction of the work.” It adds that the county “would require documentation of the Utility Owner’s authorization of a third party seeking a Permit on behalf of the Utility Owner.”

The applications list “Flock Safety” as applicant and owner — correctly, since Flock owns and installs the cameras. Three different Flock employees signed applications over the life of the program: Danny Campos, Will Warren, and Derek Porcella.

But the permits were not issued to Flock. They were issued to “Riverside County Sheriff Department C/O FLOCK SAFETY.” The Sheriff’s Department is the permittee on all three permits — holding the obligations, the liability, the strict construction clause — despite never having applied for them. There is no application from the Sheriff’s Department on file. No one at the Sheriff’s Department signed anything.

Flock applied. The Sheriff’s Department got the permits. And no authorization exists connecting the two. The county certified under oath that there are no letters of agency, powers of attorney, or similar documents from Flock authorizing the Sheriff’s Department — or anyone — to hold encroachment permits on Flock’s behalf. Nor are there any documents from the Sheriff’s Department authorizing Flock to apply on its behalf.

The county seemingly decided on its own that a permit applied for by “Applicant/Owner: Flock Safety” should be issued to the Sheriff’s Department. And Flock apparently decided that it could treat that permit as its own and forge ahead with installation.

And this didn’t happen once. The third permit application was byte-for-byte identical to the second one. The exact same PDF was filed under both permit numbers. Same date (November 7, 2023), same agent (Derek Porcella), same Flock Safety mailing address in Atlanta, same description of work, same signature.

And the same outcome: the new permit was also issued to the Sheriff’s Department, not the applicant.

@Permit Application — ENC23110539 / ENC25061408 (dated 11/7/2023)

No Authority, No Problem

This is the part that likely matters most, legally.

Riverside County Ordinance 499 Section 6 states that permits “will be issued for only Utility purposes” on county highways. The ordinance defines “Utility” as water, sewer, irrigation, gas, petroleum, cable TV, electric, and communications facilities. Surveillance cameras are none of these.

For non-utility encroachments, the Director of Transportation may issue a permit if satisfied of three things: (1) the use is in the public interest, (2) there will be no substantial injury to the county highway or impairment of its use, and (3) the use is reasonably necessary for the functions of the applicant.

Flock’s cameras are commercial surveillance products owned and operated by a private company. The Sheriff’s Department has a software service contract to access Flock’s data — both inside and outside Riverside County.

The Director’s finding that these cameras satisfy the three-prong test in Section 6 would be the legal prerequisite for every permit in the chain. Without it, the Director had no authority to issue any of them.

No such finding accompanied any permit application.

Whether such a finding could survive scrutiny is a separate question. Is a private company’s occupation of public right-of-way to operate a for-profit surveillance network “in the public interest”? Is it “reasonably necessary” for Flock’s functions that its cameras sit on county roads rather than, say, private property with the owner’s consent?

No Locations, No Problem

Riverside County has contracted for over 500 Flock cameras. Not all of those are on county roads. Some are on city streets, some on Caltrans state highway right-of-way, some on private property. The permit documents include handwritten annotations identifying specific cameras as “NON COUNTY/city,” “CALTRANS,” and “City St/Grand Terrace.”

Someone at the Transportation Department reviewed the camera deployment list, saw cameras on roads the county doesn’t control, and marked them accordingly. But no formal record of that analysis was ever created.

I asked for any records reflecting which of the 500+ cameras are within county highway right-of-way, or any determination that specific cameras did not require a permit. Again, the county certifies that no such records exist.

When the county’s records custodian was asked about the gap between 500+ contracted cameras and the roughly 80 installations documented in the permits, the only response was informal and vague: “some locations may not have been permitted as they could be private or non county maintained roads.”

That’s it. No spreadsheet, no memo, no analysis. The county issued blanket permits for “various county roads” — possibly subject to the typical Flock “deployment plan” — but never really determined which roads it was talking about.

No Traffic Plans, No Problem

Every encroachment permit in the production requires a traffic control plan under Condition C05 — a safety document showing how workers and traffic will be protected when someone is installing equipment in a roadway. The current permit, ENC25061408, goes further and requires the TCP to be signed by a Professional Engineer.

The county produced one set of traffic control plans: for the Spencer’s Crossing project, eight cameras, prepared in February 2023 under the first permit.

No other traffic control plans exist.

That’s a 98% noncompliance rate.

No Fees, No Problem

Section 15 of the ordinance requires that permit fees be paid “at or after the time application is filed, but in any event before the Permit is issued.” The fee fields on every application in the entire production — all three permits, every application, every rider — are blank.

Section 16 exempts public agencies from permit processing fees if they have “lawful authority” to use the right-of-way for the permitted purpose.

Flock applied in its own name. But the permits were issued to the Sheriff’s Department — a public agency — triggering the fee exemption. A private surveillance company applied, a public agency was listed as permittee, no fees were charged, and no one documented why.

No Records, No Problem

None of the above rests on inference or supposition. Each point traces back to a single document: a Declaration of Custodian of Records executed March 23, 2026, signed under penalty of perjury by the county’s records custodian.

The Declaration addresses each follow-up item individually and certifies that the county has no responsive records. This is not a case where documents might exist but were missed. This is the county’s official position, under oath, that these records do not exist.

This is not some isolated paperwork hiccup in Riverside County from a well-meaning county official unable to find records that really exist. Across the country, Flock cameras go up on public roads under permits that no one reviews, with safety standards no one enforces, issued to applicants that no one verifies. Flock routinely operates cameras with expired permits or without an active contract. Riverside County is one of many.

@Declaration of Custodian of Records — March 23, 2026

The Law in “Law & Order”

Riverside County’s surveillance camera program operated for over four years under three encroachment permits issued to an agency that never applied for them, based on applications from a company that never received them, without the legally required public interest determination, without traffic control plans for the vast majority of installations, without fees, and — for 13 months — without a permit at all.

Each of these permits was issued to the Riverside County Sheriff’s Department. Flock — the owner/operator listed on the permit applications — never received a permit but still installed and continues to operate hundreds of surveillance cameras without a valid permit.

The $6.9 million contract belongs to Sheriff Chad Bianco’s office. The entire Flock deployment — from the first two cameras in 2021 to the 1,718 “LPRs and other cameras” now in Flock’s system under the sheriff’s name — occurred during his tenure.

Ordinance 499 Section 18 provides that any person who operates without a required permit, or who violates permit conditions in a way that jeopardizes person or property, is guilty of a misdemeanor punishable by fine, imprisonment, or both.

The wrong permittee is not a technicality. A 13-month gap is not a technicality. Not paying the fees is not a technicality. These are all separate material flaws resulting in unpermitted occupation of public right-of-way by a corporation, based on a permit issued to a sheriff tasked with enforcing the county ordinance that makes it a crime.

The Order in “Law & Order”

The county does not know, from its own records, which cameras needed permits. It has no mechanism to determine which cameras are on county roads, which are on state highways, and which are on someone else’s property.

The Director of Transportation issued permits to the Sheriff, who had never applied for any, without the required public interest finding, and without traffic control plans for all but one installation. When the second permit expired, no one acted. When a replacement was finally applied for thirteen months later it was with the same application — literally the same file — Flock had used for the prior permit. The new permit was also issued to the Sheriff.

That permit process was handled by a Permitting Manager at Flock with over a decade of experience in right-of-way permitting. None of these issues were discovered when processing the permits or through any audit or investigation in three years. Neither Flock’s permit expert, the Sheriff’s Department, nor the Transportation Department raised a flag.

That process — namedrop Chad Bianco, skip the fees, ignore the regulations — is the law and order he now offers California.

The Timeline, According to Flock

The timeline begins with an “External Claim” in March 2025, where “an individual contacted Flock with security findings after acquiring a device through illegal, unauthorized means.” Presumably, this refers to Jon Gaines’ research. A year later, Flock has not fixed those issues.

What it has done is reflected in the rest of the timeline: it “disclosed and addressed low-severity vulnerabilities,” it “responded to” the research, and it “published a response debunking false claims that the company had been hacked.”^[2] None of that fixes the issues that were disclosed to Flock in March.

The first of those actions, disclosure, happened in November, after Gaines published his report. Before November, Flock had not disclosed the issue. Not even to its customers. This is despite the requirements of the CJIS security policy, which require vendors to notify the government agency and the FBI.

The Iowa Department of Public Safety (a Flock customer and CSA for Iowa) confirmed it had received no notification from Flock. Other CSAs — the Florida Department of Law Enforcement and the Illinois State Police — did not respond to a Sunshine Act request, or asserted that vulnerability notifications are “ALPR data.”

Despite a contractual and legal obligation to provide this notification to its customers, Flock did not do so for eight months, and then only after its customers found out.

The timeline does not discuss a YouTube video before pivoting to a “second” one with “misleading claims about Flock PTZ cameras.” Flock’s timeline says it “addressed” those claims.

“Misleading Claims,” According to Flock

The “Readdressing Misleading Claims About Cybersecurity at Flock” is a lie. Not because its content is false — although it’s not exactly true — but because it doesn’t even do anything resembling addressing claims, like the section heading promises.

Can’t even trust a heading. Anyway …

I want to be crystal clear: vulnerabilities are a part of the development process of hardware and software. No company on the planet is infallible, nor is any company unhackable. It is an expected and normal process for vulnerabilities to be discovered and remediated at each stage of software development. From the point of a developer writing code all the way to that finished product running in production.

We engineer bridges and buildings so that they don’t collapse. We do all sorts of math and engineering and further science so this doesn’t happen. But occasionally, and unfortunately, they do collapse. When they collapse, we don’t shrug our shoulders and say “it’s part of the process.” We investigate the cause and address it. We make meaningful, articulable improvements to our engineering processes and standards.

We now have those collapses and their fixes codified in laws and regulations and we explain them in engineering textbooks and use them as examples on powerpoints at industry conferences and seminars. That is why we now have buildings and bridges that are more earthquake resistant than 100 years ago.

We don’t hide the problem. We don’t say it’s “an expected and normal process” for a bridge to collapse.

It’s an exceptional situation for a bridge to collapse, just as it’s an exceptional situation for a software vulnerability to be discovered in production. And just as people have died from buildings crumbling in earthquakes, people have died from insecure surveillance networks.

You don’t hide engineering issues — civil or software. You make them public, you address them, and you learn from them.

But, despite claiming that discovering these issues in production is “expected and normal,” Flock’s bulleted list of what to expect from a vendor does not include it.

The list does not mention notification or remediation for production issues. No timelines, no categories, no mentions of public vulnerability trackers, no issue categories, or anything else. Not even a “We will notify our customers and provide a remediation plan within 48 hours” or anything similar.

Flock’s Cybersecurity Team

Flock continues to invest in our team and has 10 new headcount positions slated for hiring this year, adding to our existing team of 20+ engineers. Cybersecurity is nothing without people.

This is the exact opposite of what Flock should be doing. Instead of hiring more engineers to develop more buggy AI-powered features and release more half-finished websites, Flock should be investing in hiring policy and security experts.

The post then lays out some team names without defining their headcounts, budgets, or positions in the organization hierarchy. In some companies, a 50-person “DevSecOps” team is focused on security and can shut down production when needed; in others, it’s literally one guy in Mexico City writing scripts so developers can automatically release code without review.

Castaldo does not even hint at where Flock might fall on that spectrum, and that’s cause for concern.

The “First” video

Although Castaldo omits the November video — which was Benn Jordan working with Jon Gaines — from the timeline, he devotes a section of the post to it.

In November 2025, a YouTuber released a YouTube video with two other individuals claiming to have “hacked 80,000 Flock cameras”. That statement tells you all you need to know about the credibility of the individuals and the video itself.

The video is titled “We Hacked Flock Safety Cameras in under 30 Seconds.” The closest thing to Castaldo’s quote is: “Upon further investigation, it turns out that there are over 80,000 of them. And um we got some and we hacked them.” Which is 100% true.

Blatantly misquoting an opponent’s statement before attacking it tells you all you need to know about the credibility of that individual.

Castaldo uses some choice words like “illicitly,” and “illegally” to characterize the acquisition of the Flock hardware. There is nothing “illegal” about buying hardware, and absolutely nothing suggests that Gaines (or whoever bought the hardware) did so illegally. Falsely accusing someone of criminal conduct is defamation per se in most jurisdictions.

Flock did not disclose these issues to customers. Flock did not notify customers in accordance with industry best practices and according to CJIS standards. Flock did not close out any CVEs, nor did it open any new ones. Flock did not tell Jon Gaines “we are aware of this and we will fix it.” And at no time in 2025 (or at all, for that matter) did Flock communicate a fix.

While the findings were legitimate, they were all of low severity. Meaning the risk to customers or customer data was near zero.

Of the findings in the report, many are high severity when going by the framework laid out by the U.S. Department of Justice, which governs much of the data. Castaldo does not specify what framework he uses for his “low severity” classification or his “near zero” risk assessment.

Dunwoody gave us vibes-based auditing and compliance, Castaldo adds another layer: vibe-based cybersecurity.

Had this individual not prevented [the camera] from connecting to our cloud, most of their findings would have been moot.

This is a fair enough statement in isolation, but does not address the two key problems.

First, there is no evidence that Flock discovered and fixed these issues, and rolled out an update. No required customer notifications, no proactive security disclosures, nothing. Complete silence.

If these issues were indeed fixed, and were not the result of plain negligence, nothing is lost by publishing these issues. Most software vendors do exactly that to build trust. Microsoft, for example, has a page called “Vulnerabilities and Exploits” on its main website, and it includes a list of fixes with each update, including any security fixes.

If Flock had published anything or notified anyone, cross-referencing those notifications against Jon Gaines’ report would make for an easy exercise in ticking off fixed issues and seeing what — if anything — remains.

Flock could easily restore trust and show that it is on top of its security by publishing a few emails that it already sent to its customers when it first discovered these issues — as it is required to do — or when it fixed the issues — as is standard practice.

Second, there have been no patches for this particular operating system since 2021. While security issues could have been deployed for Flock’s custom software, no vendor OS fixes were released.

Connecting it to the network would not have caused non-existent patches to be applied.

The “Second” video

This individual did not ethically submit any information to Flock prior to the release of their video

If I’m recalling the video correctly, it is true Jordan did not submit information to Flock prior to the release of the video. The last time issues were disclosed to Flock — in March, according to the timeline — they were not fixed or disclosed even months later (or, to this day, as far as I’m aware). Disclosure to a vendor is often the right choice, but there are no bright lines in ethics.

In this case, anyone whose ethics dictate minimization of harm would have done exactly what Jordan did. He denied Flock a second opportunity to jeopardize people’s safety by trying to bury an issue, as they did when issues were disclosed to them in March.

Just Keep Digging

Flock worked with our carrier partner to quickly resolve the network configuration issue. … Flock has also modified the diagnostic interface to require our technicians to log in with a username and password. Again, this interface is intended to be usable when a technician is physically present.

First, let’s address that the software had to be “modified” to require a username and password.

According to Castaldo’s post, Flock did all of these things:

• “Threat modeling during the design phase of a product”
• “Scanning and fixing code as the developer is writing it”
• “Scanning and fixing finished code when a developer submits it to the code repository”
• “Scanning and fixing applications running in production”
• “Continuously scanning and monitoring the infrastructure the application is running in”
• “Conducting penetration tests against all of the above.”

To top it off, he writes immediately below that list: “There is a cliche about cybersecurity being an onion with many layers, and that remains accurate today.”

Yet, in that whole development process, nobody at Flock, at any time, said: “hey, maybe we should require a username and password.” Even hardcoding “DonkeyKeepOut!” as a password would have prevented Jordan from gaining access.

The second issue is that no matter what layers Flock might have in its development process, there was only one in its security: Verizon’s configuration. In this, Flock’s security model is more like banana: a single layer that can easily be peeled away by anyone who wants access.

Flock gave Verizon the unchecked, unreviewed, unsupervised, ability to create and manage the security configuration for an interface that was not secured with a password.

Even without a “misconfiguration,” Verizon employees would have had access. A company with roughly as many employees as Burbank, CA has residents (plus who knows how many contractors) having unfettered access to live videos of kids playing in parks is Castaldo’s baseline definition of secure.

On Android

The software on Flock’s cameras hasn’t received vendor security updates since 2021. That is the central fact of this section of Castaldo’s post, and the one he does not address. Instead, he offers several paragraphs of technically misleading context about chip architectures — context that, on examination, actually makes his position worse.

Flock hardware runs on a heavily modified version of the Android operating system maintained by Google. This is an open-source operating system, meaning anyone in the world can look at the code and use it.

Flock has “heavily modified” Android, but never published those modifications. Yet we should feel assured — presumably based on vibes — that its “heavy modifications” are not material enough to affect security.

This is very different from the CPU in a computer running Windows or MacOS. Qualcomm’s chipsets are purpose-built and support specific operating system versions.

This is somewhat backwards, because hardware vendors don’t tend to build chips to accommodate operating systems, but it’s accurate enough in the way it matters: there is a fixed relationship between the hardware and the OS.

Flock Falcons reportedly use Qualcomm Snapdragon 625 chips, which are early 64-bit ARM chips (like the M1/M2 chips in current Macs). These were supported by Android until version 8.0 or 8.1, support for which ended in 2021. This is the same as support for older Intel-based Macbooks, which is also ending. There is nothing particularly unique or different about Qualcomm chips in that regard.

It’s theoretically possible that for the past five years, Flock has been paying engineers to backport security fixes to this unsupported version of Android. There are projects like LineageOS that do exactly this to support aging phones in primarily low-income countries.

It’s also theoretically possible that Flock designed the Falcon around 2017 around the then-popular Snapdragon 625, and that it did not replace all of its devices in 2021 when supported ended, but instead designed an entirely new line of devices (which it called “Flock LPR”), with the goal of replacing the Snapdragon 625-based Falcons as they age out of service.

Qualcomm produces a custom, heavily modified version of Google Android that is designed to run on their chipsets.

Qualcomm does produce a modified Android that is optimized for its hardware, this much is true. The problem is that Qualcomm takes an official Google Android version and modifies it for its hardware.

Qualcomm released its last full BSP for the Snapdragon 625 in 2019, and its last security update in Q4 of 2020.

Android Things

Gaines’ security report finds a problem in “Android Things 8.1” being EOL. Android Things was a popular OS for the Snapdragon 625. In the blog post, Castaldo emphatically bolds that “Flock has never used Android Things, in any product.”

Never mind that it contradicts the earlier “all of the findings were previously discovered by Flock’s cybersecurity team,” or that this is the first time Flock has raised the point, the distinction between “Android Things 8.1” or “Android 8.1” is irrelevant.

Because “Qualcomm’s chipsets are purpose-built and support specific operating system versions,”^[3] none of those “specific operating system versions” have been supported since 2021. Not Android 8.1, not Qualcomm’s BSPs, not Android Things 8.1.

Even if the statement were true — which I doubt, because I trust Gaines and Jordan to be able to identify an OS — it would be a nice “gotcha” on an entirely meaningless fact.

At the end of the day, the software hasn’t received security updates since 2021. That’s the point that matters, and the one Castaldo does not address.

Backporting

We will continue to backport any necessary security patches, as required under our agreements with all customers.

If Flock is indeed backporting security patches to Android (Things) 8.0 or 8.1, or whatever the case may be, then security itself may not be the issue. However, “as required under our agreements with all customers” includes the requirement to notify customers when they do discover security vulnerabilities.

Each time Flock backports a fix, its contracts — at least those with CJIS security addenda, which should be all government contracts — require notifications to be sent to contracting agencies (and the FBI). No notifications have ever been sent out.

The other problem is that Qualcomm’s proprietary modifications to Android, which Flock just explained are tied to the hardware, are not open source at all. There is no backporting fixes to those parts of the OS.

Third party attestation

Yes, Flock has qualified third-party attestations of its cybersecurity. What you should also expect from your vendors is continuous audits by qualified, third-party firms. Flock takes this seriously and goes far beyond surface-level audits.

The post rattles off a list of security standards or frameworks, this time omitting HECVAT and FERPA, and points to its “trust center” where, “[o]nce you gain authorization for access, you may review” the relevant documents.

But you don’t need access to see that the list of actual certifications — SOC2 Type II, ISO 27001, ISO 27017, etc. — are about organizational and procedural controls, not software vulnerabilities.

Flock “maintains standards” of “CJIS Insights”, “CJIS ACE”, “FedRAMP 20x,” and “NDAA”. “CJIS Insight” (singular — Flock can’t even get the product name right) is a compliance-tracking software dashboard sold by Diverse Computing, a company in Tallahassee, Florida. “CJIS ACE” is a commercial compliance assessment also sold by Diverse Computing. Neither is a government certification, and neither is affiliated with the DOJ or the FBI.

This is where it gets really interesting and where we have to break out our diamond pickaxes.

Castaldo spent most of this post assuring us that their use of an outdated operating system is fine because they backport software. Now he invokes CJIS and NDAA.

CJIS requires the use of FIPS-140 validated encryption modules. FedRAMP — which Flock also claims and which was codified into law by the NDAA — independently requires FIPS-140 validation as well. To the extent Flock has FIPS-140-2 validation, it has never produced documentation to my knowledge. Soon — in September 2026 — FIPS 140-2 will be no more. Flock will need to move to FIPS-140-3.

FIPS-140-3 places stricter standards on the “Operational Environment,” which includes the operating system: Flock will have to validate the combination of obsolete hardware (Snapdragon 625) and custom operating system as a single “hybrid module.” So far, such a hybrid module does not show up in NIST’s database.

As previously reported, Castaldo’s co-founder at “Security Tinkerers,” Will Lin, sits on the board of Bishop Fox — the firm Flock hired for its security audit. Castaldo mentions Bishop Fox only once in passing in this post, and does not mention this relationship at all in the section about third-party verification.

The Proof

I have called for this before, and I will call for it again: Flock should publish its actual NIST validation certificates, and its security disclosures to its customers.

Castaldo’s 2,000-word defense does not contain a single customer notification, a single CVE, or a single NIST certificate number. It relies on strawmen arguments, mischaracterizations of hardware lifecycles, and a little light defamation.

Stop digging and start fixing.

Note

Correction (April 21, 2026): The Tampa section of this article previously attributed reporting by The Tampa Monitor (Michael Bishop) to Creative Loafing Tampa, which had syndicated the content under a Creative Commons license.

The section also conflated council member quotes from an earlier vote to approve a direct Flock Safety contract with the subsequent RedSpeed speed camera piggyback vote.

Additionally, the section now includes Tampa Police Chief Bercaw’s memo stating that the RedSpeed cameras will not incorporate Flock ALPR integration. These errors have been corrected.

In Florida, every time a parent drops off a child at a Hillsborough County school zone, RedSpeed cameras capture continuous HD video of their vehicle. The footage is fed, via RTSP stream, directly into Flock Safety’s national surveillance network where it is processed by Flock’s AI, stored on Flock’s terms, and made searchable by thousands of agencies nationwide.

The contract governing this arrangement contains no data retention policy for the surveillance layer, no restrictions on who can access it, no privacy provisions for the people being filmed, and not even a reference to Flock’s terms of service. The word “privacy” does not appear — except once, regarding credit card processing when subjects pay for the privilege of their surveillance.

The pricing page of RedSpeed’s winning proposal says it plainly: “Flock Wing License(s) Included.”

What Hillsborough County Bought

In 2024, the Hillsborough County Sheriff’s Office solicited proposals for automated speed enforcement in school zones (RFP 2024-003). RedSpeed Florida won the contract. Its 80-page proposal made the Flock integration central to its pitch.

On page 5, a letter on Flock Safety letterhead, signed by Todd Troutman, Senior Accounts, confirms the partnership:

Flock Safety and Redspeed have partnered together to support many different agencies. Flock Safety is able to provide an additional layer of software to the Redspeed cameras (speed and red light). This allows the Redspeed cameras to be turned into ALPRs that push images into Flock Safety’s cloud and allow agencies with access to those cameras to search for vehicles.

…

In order for the two systems to work together, Redspeed will provide Flock with RTSP streams for the given cameras. From there, Flock Safety will integrate the camera stream into the Flock system thus allowing the software to be on the camera, turning it into an ALPR. The camera is then plotted on the Flock Safety map in the application to appropriately locate where the cameras are.

…

As of March 2024, Redspeed is the only company with whom Flock has partnered with to offer Wing LPR integration on school zone enforcement and/or red light cameras.

@Flock Safety Letter to RedSpeed (from HCSO RFP 2024-003)

RedSpeed’s transmittal letter was even more direct:

ONLY RedSpeed can offer integration with Flock. We have enclosed a letter from Flock confirming this fact. We have collaborated closely with Flock to optimize interoperability… We have successfully integrated over 100 Flock systems in current installations; our competitors have integrated zero Flock systems. Only RedSpeed offers this direct integration, and Flock is included in the RedSpeed price. Integrated Flock means RedSpeed’s cameras are feeding the Wing System for enforcement synergy. It also means fewer poles and solar panels.

Enforcement. Synergy.

RedSpeed’s proposal includes a competitive comparison table highlighting “True integration with Rekor/Flock/Vigilant” as a checkmark for RedSpeed and a red “denied” for “All Competitors.”

The proposal emphasizes that RedSpeed cameras deliver “lane-specific, high resolution (3000x5000 pixels, 30 frames per second), video cameras” — and that RedSpeed “provides the ability to live stream video from all cameras (no still cameras).” It also states that RedSpeed “provides at least 45 days of storage” and “Flock ALPR at all locations, included in the RedSpeed Price.”

RedSpeed’s stake in all this is straightforward. It offers a “turnkey” service — everything from taking a picture to swiping a credit card — for “35% of the Governing Body’s Statutory share of collected revenue.” In Hillsborough County alone, more than 105,000 violations have been issued since fall 2024, generating over $6 million in paid fines; a local magistrate called it a rip-off.

@RedSpeed Full Proposal — HCSO RFP 2024-003 (80 pages)

In Alpharetta, GA, it was structured a little different: the county had to pay 2% extra to give the data to Flock. Maybe that’s Georgia-based Flock’s home field advantage at play.

The Silent Contract

What matters most about the Hillsborough procurement is what the contract doesn’t say.

The HCSO-RedSpeed contract consists of three incorporated documents:

1. The RFP solicitation (HCSO RFP 2024-003, 39 pages)
2. The draft contract template (11 pages)
3. RedSpeed’s proposal (80 pages, including the Flock letter)

@HCSO RFP 2024-003 — Final Solicitation

@HCSO RFP 2024-003 — Draft Contract

The Request for Proposals

The RFP explicitly required ALPR capability (Part D, Section 3):

Qualified, proposing firms must demonstrate competence and experience with Automated Speed Enforcement Systems and Automated License Plate Reader systems

It required video, not stills (Part C, Section 3.A):

Video Technology is required. Still shots are not acceptable. Respondent proposer must utilize radar and/or laser automated speed detection systems.

And it required subcontractor disclosure (Part B, Section 5):

If a Proposer intends to use subcontractors, the Proposer must identify in the Proposal the names of the subcontractors and the portions of the work the subcontractors will perform.

What was not in the RFP were any specifications for how ALPR data should be governed, stored, retained, shared, or deleted.

What the draft contract covers

The draft contract is an 11-page template with fill-in-the-blank fields. It covers: term (3 years + three 1-year extensions), insurance requirements, E-Verify compliance, subcontracting (generic), public records obligations (per Florida § 119.0701), indemnification, and confidentiality — but only of “Sheriff Operations” (Section 23).

What the draft contract does NOT cover

• Data retention for ALPR/LPR captures
• Data sharing restrictions (who can access Flock’s system)
• Privacy policy for citizens whose vehicles are scanned
• Flock Safety’s terms of service or Master Service Agreement
• Any reference to Flock’s default data practices (30-day rolling delete, Section 4.3 perpetual anonymized data license, Section 5.3 law enforcement disclosure rights)
• Ownership of ALPR data (distinct from violation/citation data)
• Audit rights over the ALPR system
• Restrictions on out-of-state or federal agency access
• Any framework governing the surveillance layer at all

@Flock Default MSA — Oakland CA, Sept 2025

Nothing in the contract says HCSO gets any rights to the video or the ALPR data. If HCSO wants to access that, they presumably have to do what anyone else can do: pay Flock and ask nicely.

@SFist — SFPD Flock Data Accessed 1.6M Times by Federal Agencies

@ACLU — Flock Can Share Data Even When PDs Opt Out

The sheriff’s RFP was specific enough to guarantee the desired outcome. The final tabulation sheet published by HCSO shows RedSpeed with the highest evaluation score of 95.95, ahead of Blue Line Solutions (91.75) and Conduent (77.6).

@HCSO RFP 2024-003 — Tabulation Sheet

@The Tampa Monitor — Flock Integrated Speed Cameras in School Zones

Wing: The Platform That Turns Any Camera Into a Flock Camera

RedSpeed’s pitch works because of Wing: Flock’s product line for converting third-party cameras into Flock surveillance nodes. The branding is a somewhat confusing patchwork of overlapping names, and Flock has removed several of its Wing-related pages from its website, but the product is still sold and deployed.

The Pitch

In October 2020, Flock Safety announced Wing with a press release headline that said, plainly:

FLOCK SAFETY ANNOUNCES THE WING INTEGRATION TO DISTILL 1000s OF HOURS OF IP CAMERA FOOTAGE INTO SEARCHABLE IMAGES THAT SOLVE CRIME

The subhead: “Software transforms existing IP cameras into cameras that can see like a detective”

Wing takes video from existing cameras — IP cameras, security cameras, traffic cameras — and runs Flock’s AI on it, letting users search for white sedans, unicycles, or people wearing jeans.

Cameras connect via standard RTSP (Realtime Streaming Protocol), a camera standard that’s supported by many commercial surveillance cameras as well as consumer products like doorbells and $35 surveillance cameras.

The Wing Ecosystem

In an August 2025 OMNIA Partners cooperative purchasing pricelist, Wing LPR is listed as: Flock Safety Wing™ LPR (wing_integration, $3,000/yr per camera): “Video software integration transforms traditional IP cameras into Flock Safety enabled LPR cameras. Includes Vehicle Fingerprint™ computer vision and Advanced Search Package (Convoy Analysis, Multi Geo Search, Visual Search)”

@OMNIA Partners — Flock Pricing, Aug 2026

The same catalog lists the Wing product family: Wing Livestream ($500/yr), Wing Replay ($1,000/yr with 7-day footage retention), Wing Gateway 2.0 (8–32 stream hardware at $3,650–$8,250 + subscription), Wing Cloud Live Only ($90/yr), and an Inbound Vehicle Images API ($1,500–$2,500/yr) for ingesting pre-processed plate reads from third-party LPR systems.

The “Wing Livestream” product price matches the $500 feature that turns Flock’s LPR into live video surveillance — that’s “something you can take advantage of without going to council,” according to Flock Safety’s Kevin Cutler.

Flock misleadingly tells the public it sells “LPR” cameras — a product name, not a description — while it consolidates its network into a single searchable database.

The network from that Superbowl Ring commercial, promising to find your dog is already deployed nationwide on speed cameras, parking enforcement cameras, and “CCTV” sytems on your basketball and pickleball courts.

Wing in Practice

On June 27, 2025, Flock published a blog post titled “Video Without Limitations: Flock Safety’s Newest Solutions for Law Enforcement” showcasing Wing Gateway 2.0 and Wing Gateway Outdoor.

@vFlock Safety — Video Without Limitations Webinar (Wing segment, 13:36–end)

@Flock Blog — Video Without Limitations

In the October 2024 webinar (full video), Trevor Pennypacker, Sr. Product Manager at Flock, is excited to tell Flock’s customers that you can connect “parking lots, restaurants, traffic cameras, really anything.”

The City of Bloomington, IL executed an agreement that explicitly includes Wing LPR in its order form:

• “Flock Safety Wing™ LPR — Included — 10 Included”
• “Flock Safety Wing™ VMS — Included — 100 Included”
• “Professional Services — Wing Implementation Fee — $500.00”

@Bloomington IL — Wing LPR Relevant Pages (9 pages)

The branding, boundaries, and availability of Wing products is all somewhat shifting and murky — from Wing Gateway 2.0 to Wing Cloud to Wing LPR — but the core functionality is what matters: third-party cameras are being turned into Flock nodes, and Flock actively markets and sells that functionality.

The Scan-Everything Architecture

RedSpeed’s cameras are always on during enforcement hours. They capture continuous HD video of every vehicle passing through the field of view — in a school zone, recording parents, teachers, students, buses, and anyone else on the road. “Video Technology is required. Still shots are not acceptable.”

The RTSP stream — all of it, not just violators — is fed to Flock. The Flock letter confirms this is by design: the cameras are “turned into ALPRs that push images into Flock Safety’s cloud and allow agencies with access to those cameras to search for vehicles.” Since then, Flock rolled out FreeForm, its AI-powered search capability that can find people by physical description: “man in blue shirt and cowboy hat,” “dressed in all black clothing and black face mask,” or — as one Dunwoody PD officer tried — “GRINCH.”

Vehicle Fingerprint

The Vehicle Fingerprint technology alone extracts far more than license plates: plate number and state registration, vehicle make, model, color, and body type, missing or covered plates, bumper stickers and decals, roof racks, bike racks, trailer hitches, and aftermarket wheels.

@Flock Blog — Vehicle Fingerprint: When Plate Data Fails

But that’s only part of the picture. Flock CEO Garrett Langley has previously stated that the system indexes everything, filtering only problematic searches — or attempting to filter them, anyway.

Where that data goes

No matter how you feel about red-light or speed cameras as a policy matter, it is hard to justify turning a safety measure for school zones into a surveillance dragnet whose recordings are fed to a private corporation with no contractual restrictions on use. In San Francisco, SFPD’s Flock cameras were searched 1.6 million times by out-of-state and federal agencies — in apparent violation of California law. EFF’s analysis of 12 million Flock searches nationwide found hundreds related to protest activity, immigration enforcement, and discriminatory targeting. A Norfolk, Virginia resident sued after learning Flock cameras had logged his location 526 times in four months.

@SFist — SFPD Flock Data Accessed 1.6M Times by Federal Agencies

@ACLU — Flock Can Share Data Even When PDs Opt Out

The Legal Tension

Florida’s prohibition on “remote surveillance”

Florida law explicitly prohibits using school zone speed cameras for “remote surveillance” and restricts the permitted uses of recorded footage:

(15)(a) A speed detection system in a school zone may not be used for remote surveillance. The collection of evidence by a speed detection system to enforce violations of ss. 316.1895 and 316.183, or user-controlled pan or tilt adjustments of speed detection system components, do not constitute remote surveillance. Recorded video or photographs collected as part of a speed detection system in a school zone may only be used to document violations of ss. 316.1895 and 316.183 and for purposes of determining criminal or civil liability for incidents captured by the speed detection system incidental to the permissible use of the speed detection system.

(15)(b) Any recorded video or photograph obtained through the use of a speed detection system must be destroyed within 90 days after the final disposition of the recorded event.

— Fla. Stat. § 316.1896(15)

Two questions that nobody appears to have asked, let alone answered:

First, does feeding the full RTSP stream to Flock — where it is processed by AI, matched against vehicle databases, and made searchable by thousands of agencies for purposes wholly unrelated to speed enforcement — constitute “remote surveillance” under the statute? The statute defines what is not remote surveillance (evidence collection for speed violations, PTZ adjustments), but the legislative history does not address third-party AI processing of the video feed.

Second, the statute requires destruction of recorded video within 90 days of final disposition, and vendors must certify destruction annually. But once the RTSP stream enters Flock’s system, it is processed into Vehicle Fingerprint data, plate reads, and searchable metadata governed by Flock’s own retention policies — not the county’s.

Altumint, a competing speed camera vendor in Florida, hinted at a loophole when it drew a distinction explicitly. Its chief revenue officer told the Independent Florida Alligator in March 2026 that Altumint’s cameras “only capture a license plate if the vehicle is speeding more than 10 miles over the speed limit,” whereas RedSpeed’s Flock ALPR cameras “can document every license plate that passes by.” He added: “Even in a school zone, you could be going 25 in a 15 … but I can’t capture that plate. ALPR can capture that plate.”

Whether derivative data (plate reads, AI-extracted vehicle descriptions) qualifies as “recorded video or photograph” under the statute is untested. The statute’s drafters were contemplating a camera vendor that stores and deletes footage. They were not contemplating a speed camera sending data to a second vendor that ingests the same stream in real time and converts it into a permanent surveillance record.

No Florida court has addressed either question. No Attorney General opinion appears to exist. The statute was enacted in 2023 (HB 657). Florida is one of RedSpeed’s biggest markets.

What Flock Tells Everyone Else

Across dozens of municipal FAQ pages and Transparency Portals, Flock provides standardized language:

Flock Safety cameras are not used to enforce traffic violations such as speeding, running red lights, or other moving violations. The cameras do not capture vehicle speed and are solely used for investigative purposes related to public safety.

@Leander TX — Flock FAQ

@Columbia MO — Flock FAQ

@Everett WA — Flock FAQ

Technically, that appears to be true. “Flock Safety cameras” are not used for traffic enforcement — RedSpeed’s cameras are. But they operate on Flock technology, within the Flock network.

Flock’s Transparency Portals go further. The Thomasville, GA PD portal explicitly lists “speed detection” as a prohibited use of Flock technology, and confirms that the system is used “for law enforcement purposes only.”

Meanwhile, RedSpeed’s speed detection cameras are feeding RTSP streams directly into this same network via Wing LPR. Data from a speed detection system enters a platform that lists speed detection as a prohibited use.

It’s not our cameras

The Flock letter on page 5 of the HCSO proposal says Flock provides “an additional layer of software to the Redspeed cameras (speed and red light).” The transmittal says “Integrated Flock means RedSpeed’s cameras are feeding the Wing System for enforcement synergy.” The pricing says “Flock Wing License(s)” are included in a speed enforcement contract.

Flock’s defense rests on a technicality: its cameras don’t capture speed; its technology is merely consuming the video feed from someone else’s speed cameras and processing it for entirely different purposes. Whether that distinction will satisfy a legislature, or the parents whose children are being filmed remains to be seen.

The Partner Page

RedSpeed claimed to be the only Flock-integrated vendor for school zone enforcement as of March 2024. As of March 2026, Flock’s partner program page lists several other automated traffic enforcement companies as “Channel Providers.”

Maybe Flock gave them different territories, outside school zones.

@Flock Partner Program — ATE Channel Providers

The Broader Pattern

The GSP Ticket

On December 26, 2025, Georgia State Patrol ticketed a motorcyclist for holding a cell phone while riding. The citation read: “CAPTURED ON FLOCK CAMERA 31 MM 1 HOLDING PHONE IN LEFT HAND.”

GSP called it a “unique circumstance.” The ticket was dropped in court. EFF described the incident as an example of the mission creep it has “long warned about” with surveillance infrastructure.

It is the kind of one-off incident Flock can dismiss. Its long-standing RedSpeed partnership is not.

Brookhaven, GA

In Brookhaven, GA’s words, RedSpeed cameras feed “real-time alerts” into “Brookhaven’s existing License Plate Reader (LPR) platform to identify sex-offenders, protective orders, and wanted persons for increased safety in school zones.”

Even if you are a concerned parent thinking sounds like a good idea, the practical value of such a system is questionable at best. Police are not going to act on these “real-time alerts” each time anyone under a protective order — many of which are not the result of any criminal activity, let alone any criminal activity involving children — drives through a school zone.

The system’s real-time capabilities, like watchlists and speeding tickets, are secondary. The real value is in gathering massive amounts of videos and photos of everyone entering a school zone — parents, teachers, students.

RedSpeed’s strong marketing emphasis on video quality (15 Megapixels, 30 frames per second), raises questions as well. If a regular Flock LPR, which RedSpeed says is of “lower quality,” is accurate enough to perform ALPR and create evidence, how is a camera where you can count the pimples on your middle schooler’s nose an advantage?

The point isn’t better traffic enforcement: it’s high-definition video surveillance.

@Brookhaven GA — RedSpeed Flock Integration (Wayback Machine, Oct 2020)

Tampa’s Piggyback

In Hillsborough County’s seat, Tampa, RedSpeed scored third on an RFP but the council approved the contract anyway. As originally reported by Michael Bishop at The Tampa Monitor, there was “no indication in the backup materials why the third place proposal was chosen.”

After that reporting, Tampa Police Chief Bercaw sent a memo to council calling the Flock language in RedSpeed’s proposal “unfortunate” and claiming it was “designed for Georgia law and not Florida.”

The memo states the cameras will not incorporate ALPR and that Tampa PD will not use RedSpeed cameras turned into ALPRs that push images to Flock. RedSpeed, the memo adds, will not give Flock access to cameras or provide them with any information.

As The Tampa Monitor noted, RedSpeed’s claim of “unmatched Florida expertise” — including work with the state legislature and DOT on permitting — sits uncomfortably next to the chief’s assertion that the proposal’s Flock integration language was merely “designed for Georgia law.” A company with unmatched Florida expertise submitted a Florida proposal it later said doesn’t apply in Florida.

Whether the memo holds is another question. When council voted to approve a separate, earlier contract directly with Flock Safety, council members said they had spoken with the Chief and been assured the data wouldn’t be inappropriately shared. Council member Lynn Hurtak said “the only time they are allowed to use this technology is to share it with other agencies when they have an open case.”

Memos and assurances are not contracts.

Making the Quiet Part Loud

Flock quietly sells Wing integration in the background while partners like RedSpeed bundle it for easy consumption by sheriffs and police chiefs. Contracts are kept minimal — no data governance, no privacy language, no mention of the surveillance layer. The RFP asks for ALPR. The proposal delivers Flock. The contract says nothing about what Flock does with the data. Nobody on city council asks, because the pitch is about school safety and the cameras are “violator-funded.”

Across the country, communities have begun pushing back against Flock’s surveillance network. Austin, Cambridge, Eugene, Evanston, and dozens of other jurisdictions have canceled, paused, or refused to renew Flock contracts after audits revealed immigration enforcement access, discriminatory searches, and data sharing that violated state law.

Those fights were about Flock cameras communities knew they were buying. The unified Wing network is different: residents are now told they’re getting school zone speed cameras, but the video is being routed into a national surveillance network with no contractual guardrails; or they’re being told they’re getting license plate readers only to find them watching them shoot hoops.

Flock, RedSpeed, the Sheriff, and elected officials are tired of the push-back. They’re actively restructuring to keep the public under surveillance and in the dark. We can’t let them.

Audit logs and user exports from a mid-sized Georgia suburb, a Loom training video recorded on a live account in Washington state, and a federal criminal complaint filed in the Southern District of Texas all tell a different story than the one Flock tells on the campaign trail.

The Stump Speech

Flock’s Privacy & Ethics page states that “only your agency decides who to share data with, not Flock.” Their FAQ goes further: “Nobody from Flock Safety is accessing or monitoring your footage.”

@Flock Safety — Privacy & Ethics

A January 2026 blog post insists that “ICE does not have direct access to Flock cameras, systems, or data.” It lists a number of “pilot projects,” including a “CBP Pilot: May 9, 2025 to August 24, 2025.” These pilot projects “effectively enabl[ed prospective customers] to test the product before committing to it.” In other words, they got access.

Flock CEO Garrett Langley posted “Setting the Record Straight: Statement on Flock Network Sharing, Use Cases, and Federal Cooperation” on June 19, 2025; smack-dab in the middle of CBP’s pilot program. Regardless, he assured his readers on the topic of federal access: “it is a local decision. Not my decision, and not Flock’s decision.”

Every city council gets the same pitch. Every council delivers it to constituents. The assurance that access is controlled, limited, and local is what gets the contracts signed. Three specific planks in the platform:

1. Only your agency controls your data.
2. Federal agencies do not have direct access.
3. Nobody from Flock is accessing your footage.

None survive the paperwork.

The Campaign Trail

On February 26, 2025, at 10:47 PM Eastern, a Flock employee ran a search on Dunwoody, Georgia’s live surveillance network. The query was “chicken truck.” Then “cattle truck” — four more times. Then “lawnmower.”

The employee was Bob Carter, VP of Strategic Relations and Business Development at Flock Safety. He is not a police officer. He is a sales executive with a fully enabled search account on Dunwoody’s production network, with access to every camera in the Dunwoody sharing pool and far beyond.

Carter’s complete 2025 search record, read chronologically, is its own argument.

February 26, approaching midnight Eastern: “chicken truck,” then “cattle truck” four consecutive times, then “lawnmower.” Thirteen networks each. No case number.

By June 23: “white racecar with black stripes,” “potatoe chip van” (his spelling, verbatim), “ice cream truck,” “unicycle,” “rocket car.” The misspelling is Carter’s own — Dan Quayle’s ghost, haunting a live surveillance system. A rocket car does not exist in civilian traffic.

Carter kept returning to the unicycle through July and into the fall, workshopping the same searches like a candidate who can’t land a stump speech. By August he’d escalated to 892-network lookups — taking a locally-spotted vehicle and running it against the entire Flock network. In September, a blue Honda sedan toggled four times between a 13-network search and an 892-network sweep. By October, he’d moved from vehicles to people: “person on skateboard,” “person wearing orange vest and construction hat,” and the same yellow racecar searched three times in under an hour.

By December 9: “flatbed truck with lawn equipment,” “usps truck,” “ups truck,” “fedex truck.”

While Carter was busy maybe tracking his package, his colleague, Flock SVP Chris Colwell, sent out an email blast to Flock customers announcing that officer names, license plates searched, and open-text search reasons were henceforth removed from audit logs.

No longer would we be able to see Flock employees tracking their Amazon packages.

Carter’s March 4 session set his personal record: two consecutive lookups sweeping 6,350 camera networks simultaneously. While we will never know what fever dream of unicycles and race cars is on a loop in Carter’s mind, Flock will no longer let agencies across the country — from Virginia to Washington — know that a Flock VP searched “their” data for “SIZ3850” — which, according to lookupaplate.com, isn’t even a unicycle or a Honda.

There will no longer be reasons, names, or case numbers to keep an eye on Flock executives running midnight nationwide searches for rocket cars and unicycles on a national surveillance network.

This is what “Nobody from Flock Safety is accessing or monitoring your footage” looks like in practice.

The Rest of the Ticket

Because no good trip is taken solo, Carter was not running alone. Several Flock employees were created on Dunwoody’s account and given access as if they were Dunwoody police officers and command staff. In other departments’ logs, their searches appear as Dunwoody PD’s.

A February 2026 user export shows six Flock employees holding Owner-level access, equivalent to a department administrator. This grants them full control over search, cameras, users, and hotlists.

Dunwoody roster

Across 2025, Flock’s accounts generated hundreds of searches of Dunwoody’s network. Another Flock entity — Lucidus Tech API — is a programmatic API account tied to a Flock acquisition; Flock’s computer ran an additional 132 searches between January and March. Another API User (Forcemetrics) performed a single search in September 2025. Dunwoody at times appears more like Flock’s personal software lab than a functional police department.

The supporting cast is worth a glance. Amanda Bruner (Nova Onboarding Specialist): 5 searches of the same Georgia license plate over ten weeks, each sweeping between 887 and 891 agencies. No case number. An onboarding employee tracking a specific vehicle for two and a half months. Kathleen Graham (Nova Specialist): 11 searches of the same plate over three days, each across 888 networks. One at 11:40 PM. Randy Gluck (Manager, BD — 911/Emergency): 1 blank search — no query term, sweeping 898 networks. Peter Barty (Staff Engineer, ML): 27 searches, including one for a “Black Mercedes GL450 4MATIC” across 45 networks.

Whether this is stalking or development work is irrelevant to the overall point: these are Flock employees — and in some cases, likely not even that because Flock had not finished its acquisition of Lucidus in January — accessing a live ostensibly “law enforcement only” network handling federally-protected data from databases like NCIC.

And then there is Flock Intelligence. This is an unidentified operator that made 606 searches of Dunwoody’s network over five months, with identity, search filters, and case numbers fully redacted in the audit log. It appears alongside several other explicitly Flock-internal organizations in network logs (e.g., “Flock Safety - Admins,” “Flock Safety - Engineering”).

Most Flock Intelligence queries used the AI-powered freeform search. Some show patterns consistent with ongoing vehicle tracking; others searched for political expression — vehicles with Trump bumper stickers, “don’t tread on me” flags. Peter Barty’s Mercedes also appears as a Flock Intelligence query, suggesting “Flock Intelligence” may be a test account the Nova team uses to search live data.

Flock Intelligence is a separate entity not found in Dunwoody PD’s internal department logs: it shows up only in network-level audits, meaning that since the December changes, neither Dunwoody nor anyone else has any visibility into these searches as they are happening. The named employees in Dunwoody’s account entered through Dunwoody’s front door. Flock Intelligence came in through the side.

Flock’s FAQ is unequivocal: “Nobody from Flock Safety is accessing or monitoring your footage.” The audit log shows this to be false hundreds of times and on multiple levels.

The searches were audited — which is how we know about the unicycles and the race cars — but the claim was not that access is audited. The claim was that it does not happen.

The Backroom

The audit logs document the front door and the side door. A Loom training video documents the back door.

The video, titled Managing Data Sharing and User Access in Your Account, was recorded by Gaby Mahoney, Regional Customer Success Manager at Flock Safety. It was made as a customer tutorial. Rather than use a demo environment, she recorded it using the live national network that’s tracking all of us.

@vManaging Data Sharing and User Access in Your Account — Gaby Mahoney, Flock Safety CSM

Mahoney’s second sentence, verbatim:

So when I log into your account and go under the sharing tab, we can see that you still have one-on-one sharing with some agencies.

When I log into your account. Not “when you log in.” She logs in. Her credentials. Someone else’s account.

The address she visits is sharing.flocksafety.com/networkSharing — a live production URL, not a demo environment — and the selected organization is Olympia WA PD.

At the one-minute mark, she moves to users.flocksafety.com/organizations. This endpoint (“organizations” — plural) most likely does not exist for Flock customers. Assuming Flock follows even remotely typical SaaS patterns — which, to be fair, may be a bold and overly-optimistic assumption — agencies would use a singular “organization” endpoint where they can see their own admin panel and nothing else.

The video confirms the endpoint’s “staff-only” status by appearing to enumerate every customer in Flock’s system. Police agencies, HOAs, businesses, and residential users in multiple states all appear on Gaby’s screen as she types “Olympia” into the single searchable list.

She navigates directly into Olympia WA PD’s admin panel where her account surfaces the full administrative interface: Profile. Organizations List. Organization. Devices. Roles. Users. Zones. Authorized Access List. Transparency Portal. Integrations. Alerts & FlockOS. Billing. Contact Directory.

The Users tab shows Olympia WA PD’s sworn personnel — names, roles, last login dates, permission flags. Two entries carry “Flock” (rather than “External”) as the identity provider. These would not be subject to Olympia’s centrally-managed controls (like multi-factor authentication or automatic account deactivation at the end of employment).

The network sharing panel shows Olympia WA PD’s “Shared with me” list: every Washington state agency sharing into Olympia’s network. Full permission sets for each. At the top of the screen is a red “Revoke Out-of-State Sharing” button next to the page selector, showing 107 rows in the “Shared Networks” table. Next to Aberdeen WA PD, a red button is shown:

Mahoney’s account does not merely view Olympia’s configuration. The interface presents a live control to terminate the data-sharing relationship between agencies — unilaterally, without the knowledge or consent of the agencies.

It’s not only Flock’s CEO who can establish pilot programs while denying they exist, or Flock’s VP that can search for rocket cars. Even its customer service reps have administrator access.

“Only your agency decides who to share data with, not Flock.”

Redaction Day

The Mahoney video is the Rosetta Stone for what happened next. It shows that Flock staff — even its service reps and its sales execs — have high-level access to a live, national surveillance network. They can view, edit, or delete configurations. The CSM who can click Stop Accessing on any agency’s sharing relationship is the same person who walks agencies through narrowing their own exposure. That access is the precondition for everything that followed.

It’s worth noting what the video is actually for: Mahoney is guiding Olympia — a Washington state agency — through the process of restricting its sharing. Revoking out-of-state access, checking who can search its cameras, deactivating users. Near the end she says, “I also notice that you’re not enabled for the statewide or national lookup so that will be good in terms of auditing purposes.”

Limited access makes auditing easier. She knows what the inverse implies.

Five days after she posted the video, on December 9, while Carter was looking for his leaf blower, Flock SVP Chris Colwell sent an email to customer agencies titled “What you Need to Know About Recent Online Disclosures.”

That email announced that audit logs would be stripped of officer names, license plates searched, vehicle fingerprints, and open-text search reasons — framed as protecting active investigations and officer safety. Flock did not merely stop recording these fields going forward — it also retroactively replaced unique officer identifiers in its public Transparency Portals with the word “REDACTED.” The prospective removal ensures new searches go unattributed; the retroactive scrubbing rewrites the record of searches already conducted.

In the same email, Colwell recommended that agencies do exactly what Mahoney showed Olympia would “be good in terms of auditing purposes:” restrict sharing.

Reviewing your sharing settings and considering a temporary shift from Nationwide Lookup to Statewide Lookup.

He linked to an instructional video on how to do it.

Two days later, an FBI Supervisory Special Agent in Atlanta’s C9 Gang division forwarded the Houston HIDTA Officer Safety Bulletin to the broader intelligence community.

The bulletin described this site by name and recommended that agencies “ensure that their agency Flock settings have limited searches to sharing within state only or exclude the states/agencies that release their audit logs.” It further recommended that officers “ensure that the reason for the query be as vague as permissible (e.g., ‘Investigation’).”

Washington was named as one of the states from which FOIA-obtained audit logs had originated. The FBI was distributing instructions to help agencies evade the public records process — and one of its own field divisions was simultaneously using Flock data to prosecute federal cases.

It was a busy period. Houston HIDTA authored the bulletin, ROCIC — one of the RISS centers documented elsewhere on this site as carrying direct Flock database access — distributed it to law enforcement coordinators on December 10, and the FBI’s Atlanta office forwarded it on December 11. At approximately the same time, Flock implemented a blanket VPN block for all public transparency portals — which it holds out to be public accountability tools. A week later, Cyble, a Flock-affiliated firm, filed false abuse reports with Cloudflare in an attempt to take this site offline.

That is the service Flock was providing in December 2025: helping agencies make their surveillance data harder to audit while simultaneously stripping the audit logs of meaningful content, blocking anonymous access to public records, and attempting to silence the publication that had prompted the transparency requests in the first place.

And Carter stopped looking for unicycles and racecars.

The Candidate

On December 18, 2025, an affidavit in support of a criminal complaint was filed in the Southern District of Texas, Case No. 4:25-mj-770.

@Criminal Complaint — Case 4:25-mj-770

The affiant, Ryan Hilz, states under oath that he personally searched the Flock system. In ¶5: “Affiant also searched the Hyundai’s license plate through the FLOCK Safety System, from approximately November 15, 2025 12:00am through 9:00am.” He names a specific camera — “DB15 – Collingsworth (WB) from Broyles” — and narrows it to a two-minute window, 6:33am to 6:35am. In ¶6: “Affiant searched the Cadillac’s license plate through the FLOCK Safety System.” In ¶12, he reviewed Flock images from November 8 showing both vehicles parked side by side. He is not describing results handed to him by a colleague. He is describing searches he ran, cameras he queried by name, and images he personally reviewed.

The audit logs don’t show these searches. Between November 1 and December 1, 2025, the Hyundai plate (WFV2638) was searched 81 times in the Flock system — by Houston PD officers, Harris County Constable deputies, and two Harris County Sheriff’s Office users (V. Pag and m. bar). The Cadillac plate (WSF6471) was searched 86 times, again by Houston PD and Constable personnel, plus a handful of HCSO entries logged only as “C.” — a single initial with no last name. Harris County Sheriff’s Office does have a user account matching Hilz: “R. Hil.” That account’s last recorded search was May 16, 2025 — six months before the robbery. It does not appear in either plate’s November search history.

Hilz swears he searched — literally, swears, on penalty of perjury. The cameras he names are in the Houston network where 167 other searches by other officers are logged. There is an “R. Hil” with the Harris County TX Sheriff’s Office, but that account went dormant months earlier. Either he searched under someone else’s credentials — which means the audit trail attributes his work to a different officer, defeating the purpose of individual accounts and probably violating several federal regulations — or he accessed Flock through a pathway that doesn’t generate the same audit record, which means there are doors into the system that the logs don’t cover.

That gap matters because of who Hilz is. A federal Task Force Officer (TFO) is a state or local employee — a sheriff’s deputy, a city cop — assigned to work under a federal agency, usually through a formal agreement like the FBI’s Violent Crime Task Forces or ICE’s 287(g) program. The TFO keeps their local paycheck and local credentials, possibly including any Flock accounts tied to their home agency. But TFOs report to a federal supervisor, work out of a federal field office, investigate federal crimes, and file in federal court. The local credentials are what make TFOs valuable to the feds — they bring access that the federal agency could not get on its own. This is what Flock means when it says the feds don’t have “direct” access.

The first paragraph of Hilz’s affidavit:

I am a Task Force Officer with the Federal Bureau of Investigation (hereafter “FBI”) and an Investigator with the Harris County Sheriff’s Office (hereafter “HCSO”) and have been employed by HCSO since November 2012. During my employment with HCSO and the FBI, I have been trained in investigations relating to violations of the United States Federal Criminal Code […] I am currently assigned to the Houston Division of the FBI, Violent Crime Task Force (hereafter “VCTF”), and have been since June 2020. My primary investigative responsibilities include crimes occurring within the Southern District of Texas.

Read that introduction the way you’d read a candidate’s bio on a campaign flyer. His actual employer is HCSO — “employed by HCSO since November 2012,” buried mid-paragraph. But that is not the lead. His opening words: “a Task Force Officer with the Federal Bureau of Investigation.” FBI first. HCSO second. The phrase “during my employment with HCSO and the FBI” frames both agencies as concurrent employers — not a county deputy on loan, but a man who works for the FBI and also, incidentally, receives a paycheck from Harris County.

But maybe Hilz took a creative writing class and “Affiant searched” is not to be interpreted literally; his may be a sworn statement that sacrifices accuracy for brevity, the testimonial equivalent of “close enough for government work.”

But whether Hilz is committing some light perjury, whether Flock is misleading its customers about its relationship with the feds, or whether “no direct access” in a system riddled with Flock employee and TFO backdoors is the very best Flock can do: Langley unequivocally broke his campaign promise that it would be a local decision.

After “Hilz’s” Flock searches, the three suspects were transported to the FBI Houston Field Office for interviews (¶26). Inside that field office, one of them was shown a Flock image of the Hyundai and a Flock image of the Cadillac CTS (¶29).

An officer introducing himself as “a Task Force Officer with the [FBI]” showed Flock surveillance images to a suspect in a federal criminal case, while he was being held by federal agents in an FBI interrogation room in a federal building.

To dispel any remaining ambiguity about whether this was local, look to the signature block:

Ryan Hilz
Task Force Officer
Federal Bureau of Investigations
  

He signed as FBI — not HCSO. The only thing that supports that he might not actually be a fed is that he misspelled the name of the agency he spent 16 pages claiming to work for. There is only one “Investigation” in the Federal Bureau of Investigation.

The federal government’s sworn affiant lifts the veil on Flock’s empty promises: the federal government has access, no matter how you spell it.

Flock’s own timeline confirms the infrastructure that made this possible. Its blog states that the federal “pilot” program with the FBI concluded in 2023, and that “[i]n August of 2025, Flock publicly announced it would no longer conduct pilot projects with federal agencies.” The “try” part was cancelled; the “buy” part was not. The FBI does not respond to FOIA requests about Flock. Langley’s “Setting the Record Straight” post, published June 2025, assured readers that federal access was “a local decision” — while the CBP pilot he disclosed in January 2026 was actively running.

The Fine Print

The federal-access issue draws the most attention at council meetings, but the “sworn law enforcement only” claim — which directly supports Flock’s assurance that “Nobody from Flock Safety is accessing or monitoring your footage” — fails even within the agencies that own the accounts.

The pattern extends beyond individual agencies. The Regional Information Sharing Systems (RISS) — funded by DOJ, operated by regional centers incorporated as private nonprofits — is the task force model applied to data: federal money, non-government hands, Flock access.

Five of its six centers carry direct Flock database access through RISSIntel, a federated search tool that lets RISS analysts query Flock’s data without maintaining individual Flock accounts. ROCIC, the RISS center that distributed the Houston HIDTA bulletin instructing agencies to evade public records requests, is one of them. The National Center for Missing and Exploited Children (NCMEC) is named in Flock’s own LPR policy definition as a hotlist data source. NCMEC is a private organization. It populates the alerts that fire on your plate.

The ACLU/UIowa ALPR report documented the same pattern across Iowa: civilian analysts, support personnel, and non-law-enforcement government staff with active Flock accounts across dozens of agencies.

The CJIS Security Policy is explicit about what this requires. Section 5.12.1.2 mandates that all personnel with access to Criminal Justice Information — including private contractor employees — undergo fingerprint-based state and national background checks before access is granted. Section 5.1.1.5 requires that vendors sign the CJIS Security Addendum, which extends the full weight of CJIS security requirements to their staff. Sections AU-9 and AU-11, aligned with NIST 800-53, require that audit logs be protected from unauthorized modification and retained for at least one year. Flock’s December audit-log stripping, its employee access without documented screening, and its unilateral modification of log fields all appear to run afoul of these provisions.

When Story County, Iowa requested Flock’s CJIS certification list, Flock produced 28 names — all with first names starting A through C, several illegible — and no one else. No installers, no subcontractors, no overseas workers, and none of the employees running Flock’s own sales and training accounts on production data. The list is the compliance equivalent of Carter’s searches: performance art.

The contracts themselves offer no backstop. Flock has moved its terms of service to a web URL it controls unilaterally and can change without customer notice. It requested that archive.org’s Wayback Machine exclude its website, preventing any historical record of the terms as they existed when a city signed them. The new terms strip data ownership from agencies and supersede all prior agreements upon any subsequent order — even a camera repair.

No policy implements the “sworn only” promise, no mechanism exists to enforce it, and the contracts are written to ensure that no one can prove what they originally said. “Access is limited to sworn law enforcement” is, at best, wishful thinking.

The Town Hall

When Dunwoody’s Flock contract came up for approval, the council heard the stump speech: access controlled, limited, and local. Only your officers. Only for investigations. Only under oversight. The Dunwoody City Council held its regular meeting on March 23, 2026. As part of its discussion of the Dunwoody Flock contract, an “audit” — if we use the term loosely — would be delivered.

@Dunwoody Flock Audit (Council Meeting Presentation) — March 23, 2026

The audit included a FAQ slide with question 3: “Who can access the data, and how do you prevent misuse?” The city’s answer: “Access is limited to authorized, trained personnel who need it to perform official duties.” The people who wrote that sentence had the audit log that showed a Flock employee was using Dunwoody’s account to look for unicycles and race cars.

Flock Safety even sent its chief legal officer, Dan Haley, to address concerns from the public. A resident had already recited the numbers before Haley took the floor: 401 searches by Flock employees, Owner-level access, live drone footage and hotlist control. Haley addressed none of it.

Haley spoke about machine learning training data — de-identified images, less than 1%, used to improve plate-read accuracy. The city’s own attorney called the data-use provision a loophole and said it could be closed in the new contract being negotiated. Haley corrected her on-mic: “It’s not a loophole, it’s for system quality and improvement.” It wasn’t a question anyone had asked — not even the FAQ.

The council member who asked “It seems like Flock staff has access to our footage. Is that true?” got an answer about plate-design recognition models, but the real question, why a VP of Business Development was searching for “potatoe chip van” on a live police network, went unasked by the council or the city staff who “audited” Flock. Haley certainly did not volunteer an answer.

The Dunwoody police chief did confirm that Flock engineers had been inside the system “under agreement” for integration and testing. There were no immediate objections from the dais to a commercial company using city residents as surveilled guinea pigs — nor, for that matter, to its marketing team using Dunwoody PD to shoot commercials.

The Endorsement

Dunwoody’s Technology Director’s written assessment — submitted to council alongside the FAQ — concluded that the risks of continued Flock use are “acceptable,” in part because “the users accessing the data are law enforcement meeting CJIS standards.”

The same assessment scored “Non-PD direct logins” as a Yellow risk — a documented, acknowledged problem that undercuts the memo’s overall conclusion, which rests on the premise that only law enforcement has access.

The full security assessment matrix tells an even worse story.

@Dunwoody Flock Security Assessment Matrix

All six vendor remote access control items — “Vendor remote access controls,” “MFA enforcement,” “PAM (JIT, vaulting, break-glass, recording),” “Provisioning/deprovisioning,” “Credential storage/password policy,” and “No backdoor accounts” — were rated Green.

That would be good, except the supporting evidence column for every one of them: no evidence. For “No backdoor accounts,” the assessor specifically requested a written attestation from Flock’s security leadership. It was “not specifically provided as requested.” Green anyway; we have apparently entered a new era of vibe-based auditing and compliance.

Item Q4.6 asked whether Flock had made audit log field reductions since October 1, 2025. The answer: none. The rating: Green. The assessment was prepared for the March 23, 2026 council meeting — more than three months after Flock’s December 9, 2025, mass email blast to its customers announcing that officer names, license plates searched, vehicle fingerprints, and open-text search reasons were being removed.

The only item on the matrix rated Red was Q8.1: breach/security incident history. Flock told the assessor it had no breaches in the past three years. The assessor noted that “camera breaches have been highly publicized and should have been mentioned at a minimum (December 2025).” Even the assessor could see that one. It probably would have been hard to deny when Benn Jordan, the security researcher who made the video that exposed the problem, spoke at the start of the meeting.

The Mahoney video shows what no-evidence Green looks like from the inside.

After more than an hour of public comment and questioning, the council voted unanimously to defer the Flock 911 contract to the April 13th meeting, pending completion of a new master service agreement. The motion was made by Stacey Harris, seconded by Rob Price. No one voted against deferral. No one voted to cancel.

The Moment

The reality is that non-sworn city staff have access. As do Flock employees. As does the FBI.

Flock’s standard response to this kind of reality check is to observe that employee access is technically logged, that TFO searches are formally local-agency queries, and that civilian staff access is controlled by the agency rather than Flock. Even if that were all true, it’s a description, not a solution.

Via Unraveled Press.

The people doing the account sharing don’t even know who does what searches; they consider getting caught “undue attention” rather than a violation of federal security regulations and professional standards. A November 2025 letter from Senator Wyden of Oregon says his staffers were able to find Flock accounts for sale.

As a custodian of billions of data points on hundreds of millions of people, Flock should be trying to prevent these problems, but instead it actively engineers them. Its public position is that of the passive service provider in an imaginary world where local governments are in the driver’s seat.

In private, Flock employees are placed on police department rosters, so that a VP’s search for rocket cars is attributed to the department, not Flock. Then it strips the audit fields that would let officials detect the difference.

This analysis looked at a single, relatively small police department. There are tens of thousands of users with law enforcement level access across 6,000+ departments, and hundreds, possibly thousands, of those users were never vetted by anyone. Dunwoody deferred the vote. Other cities will face the same choice. All that elected officials have to do is read the paperwork.

We don’t need to let Flock define “this challenging political moment.” We can vote them out.

Flock Intelligence does not appear in any audit log before August 2025, and it is absent from the org audit entirely. It only shows up in the network audit, meaning it searches Dunwoody’s cameras from outside the department.

The searches

Over 80% of Flock Intelligence’s queries are FreeForm searches — the AI-powered text prompt feature analyzed in detail here. That earlier analysis showed that Flock’s moderation system warns about political searches but does not block them. Flock Intelligence’s searches confirm that pattern.

Political expression

Among the 170 unique text prompts, a cluster targets vehicles by political expression:

• “a truck with a trump flag on it” — warn
• “red honda accord with a trump bumper sticker” — warn
• “green car with trump bumper sticker” — warn
• “vehicle with trump bumper sticker” — warn
• “a SUV with a yellow don’t tread on me flag” — warn
• “a red nissan rogue with a don’t tread on me flag” — warn
• “don’t tread on me flag” — warn
• “american flag” — warn
• “a car with a british flag” — warn
• “dallas cowboy flag”
• “vehicle with a Dallas Cowboys star sticker”
• “vehicle with a Falcons logo”

Every political expression search was warned — and every one went through. The sports team searches passed without even a warning, which tells you where the moderation system draws its lines and how firmly it enforces them.

What got blocked

The moderation system blocked searches describing occupants:

• “car with two occupants” — block
• “car with 2 occupants” — block
• “4 door truck with 4 individuals” — block
• “four people inside car” — block
• “green vehicle with a roof rack 4 individuals inside” — block

And a handful of subjective descriptors:

• “green car with trashy stickers on it” — block
• “orange car with person and red shift” — block
• “crazy looking car” — block

Other warned searches include “pink breast cancer awareness plate,” “pink ribbon sticker on plate,” and “german shepard in back of pickup truck.”

So: searching for a specific political candidate’s bumper sticker gets a warning and goes through. Searching for “crazy looking car” gets blocked. That is the moderation hierarchy Flock built.

Recurring patterns

Some searches recur across months in ways that suggest either ongoing tracking:

“Black Mercedes GL450 4MATIC” appears in October, November, and December. In December it evolves into “black Mercedes-Benz GLB 250 SUV” and several variations — the same vehicle tracked across a quarter, description refined over time.

“Armored truck OR Brinks truck” (and variations) appears every month from August through December. This is the most consistent search pattern in the dataset.

“White Dodge Charger with black roof and black stripe” recurs October through December with slight wording changes.

Again, this is not a police agency. It is a private party performing long-term surveillance on locations of Mercedes and cash-in-transit vehicles.

Possible reasons range from harmless testing queries (over multiple months — so that seems unlikely), to employees selling intelligence to criminal actors, to some sort of commercial service.

Person searches

Three prompts target people rather than vehicles:

• “white t-shirt” (objectClass:person)
• “person on scooter” / “person with scooter” (objectClass:person)
• “yellow backpack” (objectClass:person)

All were allowed by moderation.

Other Flock organizations in Dunwoody’s logs

Flock Intelligence is not the only Flock-affiliated entity searching Dunwoody’s cameras. Four others that we’ve seen previously appear here as well:

“Flock City PD - Law Enforcement Demo” searches Dunwoody’s network every month of the year. That is a demo environment running against a live police department’s surveillance data — not a sandbox.

“Flock RTCC” — Real-Time Crime Center — searched Dunwoody’s network in January and March.

“Flock Safety - Admins” and “Flock Safety - Engineering” are self-explanatory: Flock employees with direct access to customer camera networks.

In total, Flock-affiliated entities account for over 1,000 searches of a single police department’s camera network in 2025.

What is Flock Intelligence?

It is not listed as a law enforcement agency. It does not appear on Flock’s public-facing product pages.

Its operator identities, search filters, and case numbers are all redacted in the logs Flock provides to its own customers. Dunwoody PD cannot audit who at Flock Intelligence searched their network, what they were looking for, or why.

As I publish this, at 6:10pm (CDT) on March 23, 2026, Dunwoody PD and Dan Haley — Flock’s chief legal officer — are telling the City Council that access is only granted to police agencies, and only for criminal investigative purposes.

Again, police and Flock say one thing, the logs say another.

Someone, somewhere — who is not police — is tracking live data about these vehicles.

March 24, 2026 update: Removed claims about Flock Nova pending further verification.

Even if the original footage is available to Flock, you may get an edited or altered version (e.g. cropped or with watermarks overlaid), or a reduced-resolution version. You may also get it late, or never, and the conditions for access are at Flock’s discretion.

Although Flock revised its terms again soon after, restoring on-paper “ownership” to the customer but giving itself broader license to do what it wants with copies, the prediction held. An open records response from Missouri shows the result of Flock’s policy of “ownership.”

The Original Footage

The request was made by Deflock Joplin, the group responsible for the January 2026 headline “Joplin officer no longer employed after alleged misuse of license plate tracking system.” The records request is straightforward:

Recordings from the Flock LPR camera located at 4th and Maiden Ln from 2/16/2026 starting at 5:00 PM lasting until 6:00 PM. This camera is on the south west corner of the intersection facing a southern direction. The records requested should include stills, video, and all other records generated by the camera. I request the data from Flock OS and the camera’s internal storage.

The City of Joplin charged $23.57 for the request and fulfilled it a couple of weeks after receiving payment with a file “Flock_Safety_Search_Image_Results_3-9-2026_1-22-54PM.” The city did not include 40 minutes of footage/images, stating “we are currently experiencing a technical issue affecting this functionality.”

While technical issues that prevent a city from accessing “its” data would be a cause for concern, rumor has it that the “technical issues” in question occurred somewhere between the keyboard and the chair, and the city did not understand how to save images. The city did supply the missing 40 minutes once the discrepancy was pointed out.

World’s Fastest Truck

As far as we know, Flock cameras take a series of images and/or a short video clip when they detect motion. Flock and police often emphasize that it’s “only the license plate” or “just the back of the vehicle.” Of course, the laws of physics dictate that you can’t know what’s in a picture before you take it. This truck is a demonstration:

These two images were taken in rapid succession. It’s hard to even tell the vehicles are in a different location, but you can see the “Flock Safety” watermark is positioned differently.^[1]

These images are clearly of the front of the vehicle. But that’s not the interesting part.

Metadata and Time Confusion

Some of these images have been used as evidence at criminal trials, many in the “over 30 cases” that Flock likes to falsely cite as upholding the constitutionality of its cameras. The timestamps on the Joplin images should give anyone relying on that evidence pause.

The filename for both images contains “2026-02-16T23-39-42.219+00-00”, suggesting the images were taken less than 0.0005 seconds apart. That is neither possible, nor true, based on what’s in the images: we can see the car moving maybe 10 feet. Tacomas don’t typically travel at hypersonic speeds exceeding Mach 17.

The timestamp in the picture is “2/16/2026 17:39:42 CDT.” This is an odd mix. The date is unmistakably American (mm/dd/yyyy), but the time is 24 hours rather than am/pm. On February 16, that’s not confusing. Four days earlier, it might have been.

But even more confusing is that the timezone is labeled as CDT, or Central Daylight Savings Time (UTC-5). Daylight savings is not in effect in the middle of February in Missouri, when CST (UTC-6) is in effect. The image is ambiguous as to whether it shows an image taken at 5:39pm or 4:39pm.

The timestamp in the filename (23:39:42.219 UTC) suggests the labeling (“CDT”) is off, but we’ve already established that it is not possible for the timestamp to be accurate for both images until we have hypersonic Tacomas.

The (EXIF) metadata has been scrubbed, so there is no third hint.

That leaves these images without a reliable timestamp. These aren’t abstract concerns — they cast doubt not only on the accuracy of these files, but on the accuracy of every other image produced by the same system.^[2]

The only way we can determine the time with any certainty is by looking at the position of the sun and the 5:59pm sunset noted in the almanac for Joplin, MO, on February 16.

AI-based surveillance so high-tech you need a sundial to make sense of it.

License Plate Detection

The other piece of metadata in the image, below the timestamp, is a license plate: 0FH D30. According to lookupaplate.com, the plate corresponds to a 2014 Toyota Tacoma with an extended cab.^[3] The plate is also formatted per Missouri’s light truck standards, with a renewal date in April (F) and a last sale date likely in 2023 or 2024 (H).

The quality of these images is extremely low (second image), to the point where they no longer contain the license plate information.

Everyone who has ever used a computer knows that the “zoom and enhance” from movies and TV shows isn’t really a thing. Sure, you can backhack and extrapolate some data, but here too the laws of physics get in the way.

Access to the Image

If we assume Flock abides by the laws of physics — if no others — then the only sensible conclusion is that the license plate encoded in the bottom-right of the frame was not derived from these images at all, but from some other image that the City of Joplin theoretically owns, but can’t access.

This also independently follows from the fact that the images have watermarks and metadata overlays, assuming those are not created by the hardware itself.^[4]

The requester was precise and asked for “the data from Flock OS and the camera’s internal storage” to ensure he got the actual image, and not only a presentation version.

A high-resolution version must exist somewhere. Flock generally suggests that the city owns the original image and that it will be retained until the end of the retention period. That is to say, Flock should not be deleting its customers’ data without authorization.

Joplin provided the images shown and states that “[t]he Sunshine Law does not require the Department to obtain duplicate copies of the same data directly from the vendor or from the camera’s internal storage in addition to what we can access via our portal.”

In other words, there are no originals, but even if there were, the city can’t access them.

Not even Joplin, the ostensible owner of the images, is allowed to look at them.

Below is an AI-enhanced image, where Google’s “Nano Banana” (a generative AI upscaling model) has filled in the blanks by making up what could have been in the picture.

This image does not show the actual content of the original, but it shows a level of clarity and detail that is much closer to the original image captured than the blurry version that Joplin can access and provided in response to the request.

The Tacoma is not an outlier; there are cars (picture 1, picture 2), SUVs, and — just to cover “we don’t photograph people” — a motorcyclist. None of these plates are legible.

The Original Logs

The ownership problem extends beyond images. Logs suffer the same fate. I’ve written at length about Flock unilaterally removing log data, and how that cuts against both the supposed immutability of the logs, as well as customer ownership.

I’ve alluded to how, in some states, it may fall under statutes prohibiting the alteration or destruction of public records, and written about how Flock inserts itself in open records requests even when law prohibits doing so. I won’t rehash all of that here.

Instead, I give you the Flock “Customer Guidance for Preserving and Requesting Flock Data for Public Records Requests”:

@Customer Guidance for Preserving and Requesting Flock Data for Public Records Requests

It’s a guide on how to submit requests for data via Kodex, which, according to Flock, “is a secure digital platform for managing, processing, and responding to data and legal requests.”

Flock uses the system for “Legal requests,” which apparently includes open records requests, “Preservation requests,”^[5] and “Quick questions.”

Once the ostensible owner of the records requests “their” records from Flock, “Flock’s Evidence Division and Engineering Team will review your request, pull available data, and transmit the completed data package through Kodex.”

Flock does note that “our Evidence Policy asks for 14 calendar days to fulfill requests. If data is needed sooner, we are motivated to help customers to meet any FOIA/PRA deadlines they are facing.”

Government agencies are responsible for their own deadlines. In states with statutory deadlines, and even those without, the requirement is not “respond within 10 days, or later is fine too if your vendor is not feeling it.”

In fact, a 14 calendar day limit exceeds the statutory deadline in several states, and entering into a contract that formally requires non-compliance with law is a legally dubious proposition.

Ownership in Name Only

Officials tell the public that Flock’s cameras “take a picture of the back of the vehicle” and “only capture license plates.” They assure us the image does not include the vehicle’s occupants.

Cities like Joplin genuinely can’t access all of “their” information. They uncritically accept blurry images with derived license plates, and if they want the originals, they must ask the vendor nicely and wait at least 14 days — or less, if the Spirit so happens to move Flock.

The ownership is a fiction. The customer has never possessed the original image or the original log. If it can even obtain it at all, it can’t do so independently; it can only submit a formal request to Flock — which will respond on its own timeline, in whatever format it chooses.

That’s not ownership. That’s a favor.

And this is the evidence that’s putting people in prison.

Deflock Joplin published its own analysis of the images, where they raise some excellent points.

Note: The images in this article are post-processed for web delivery. They may be of slightly lower quality than the originals. The originals are available via MuckRock.

• Traffic Infraction
• City Planning/Traffic Analysis - test
• Welfare Check
• Larceny/Theft Offenses - Unauthorized use of a vehicle

VIPD appeared in recently imported log files. It’s not uncommon for new agencies to show up, but this may be the first instance of an agency outside the continental US we’ve seen. It raises some interesting questions. First and foremost: why?

It’s always been highly questionable for an agency in, say, Washington to claim that it has any legitimate purpose for querying data from Florida. The Virgin Islands being, well, islands, takes it from “questionable” to “downright ridiculous.”

At least someone in Washington could steal a car or run a red light and flee to Florida. In fact, I’d put money on at least a handful of people having done that or something similar. Is it likely? No. Is it possible? Sure, I guess.

But the argument here would be that someone stole a car in the Virgin Islands, left the plates on, shipped it to the mainland via commercial freight — which presumably checks VINs — and then drove it around Rogers, Arkansas. You couldn’t get that fiction published in a creative writing course.

It’s another instance of Disproportionate by Default.

This is also a department operating under an active Department of Justice consent decree for unconstitutional policing practices.^[1] The combination — a department with documented civil rights problems, plugged into a nationwide surveillance network, running searches with no apparent investigative nexus — is exactly the scenario that audit requirements are supposed to catch.

Flock’s contractual standard limits use to “legitimate public safety and/or business purpose[s]” — a bar so low it’s practically subterranean. And VIPD still managed to limbo under it.

VIPD’s searches were visible to Flock and every network they queried. Each of those 5,000+ receiving agencies claims to audit its incoming queries. Every one of them should have flagged a Caribbean police department searching for traffic infractions on the mainland. None did.

The Iowa Legislature created IPIB in 2012 to give Iowans “an efficient, informal, and cost-effective process for resolving disputes” about open records and open meetings laws — without resorting to litigation. Nine governor-appointed members were meant to mediate and, where necessary, adjudicate complaints about governments withholding public records or holding secret meetings. For this purpose, the board was authorized to act as a prosecutor on the public’s behalf.

That is not what the board does, or what it has ever done. IPIB keeps complaints away from courts — not to adjudicate them, but as a black hole that attracts complaints and prevents them ever escaping to meaningful review. The board should be dismantled and Chapter 23 repealed.

The Legislature’s Double-Tap

It is immediately evident from the chart above^[1] that since 2018 the number of cases IPIB has received has remained more or less stable, but if you have attended any of the board’s meetings, you probably heard complaints about increasing workloads.

The workload statement is true to an extent, but the increased workload does not stem from complaints. In part, it stems from a law enacted in July, 2025 (HF 706), which “created a requirement that all newly elected and appointed officials of a government body attend training on Iowa’s Sunshine laws”.

Iowa has 99 counties and close to 1,000 incorporated cities, in addition to myriad state and other agencies. That’s a lot of “elected and appointed officials” who will require training.

IPIB is not required to actually deliver the trainings to officials, but it is required to ensure that one approved course is available at no cost. Unfortunately for everyone involved, IPIB pays its staff attorneys in Des Moines the same rate Iowa DOT pays its Highway Technicians (a position that requires a GED and a CDL permit rather than a JD) in rural Washington County.

When any third party would need to charge more, IPIB staff providing the trainings is the only fiscally responsible choice.

IPIB’s (hourly) Administrative Assistant 2 retired in 2024, taking home $68,494.34 that year.

In a February 2025 budget presentation, then-director Eckley listed “Turnover” as a “challenge,” noting that “Only 1 out of 3 staff has tenure over 1 year.”

That presentation was published in between the board getting sued for violating open meetings law when Eckley gave herself a 6% raise, and before Eckley resigned and the board offered her replacement, Charlotte Miller, the pre-raise salary.

In this context, it would be hard to fault IPIB’s attorney for considering “Lunch and Learn” sessions as more of a networking opportunity than a job responsibility.

By passing HF 706 the legislature ensured IPIB remains ineffective, even if it ever decided to change course. It redirected citizen complaint resolution time to government official training. The board teaches a law it has no time to enforce.

IPIB’s budget has not meaningfully changed between 2018 and 2025, but for FY2026 it estimates a sudden $91,259 (24%) increase, with most of that increase allocated “for hiring of contractor to implement mandatory training per approp language and/or to help with backlog”, confirming that training and complaint-handling time are competing for the same funds.

According to the figures presented at the February board meeting, that backlog is growing fast: between November 2025 and January 2026, 95 cases were opened while only 55 cases were closed. The figures only reflect those two states: “opened” and “closed.” The director omitting case disposition in the presentation to the board suggests her focus is purely quantitative, not qualitative.

At that same meeting, staff said, “we’re no longer drowning as much … we’re treading water” and suggested potential efficiency improvements by pointing out “we’re doing all our own copy editing.” Institutional pressure to reduce backlogs may explain why quality of the work-product isn’t a priority, but professional responsibility still attaches to the individual licensed attorneys drafting deficient orders.

With IPIB’s entire budget swallowed by its personnel costs only to leave them treading water, there is neither time nor money for IPIB to actually do its job of prosecuting violations.

If the board gives its staff nothing to do but take the government on Lunch & Learn dates, can we really expect fair outcomes? The answer is in the chart above: the number of complaints that are actually investigated and handled is low. Very low.

Complaints and Procedural Smokescreens

The process IPIB must follow is outlined in Iowa Code Chapter 23. It is relatively straightforward and probably what you would expect from a process like this.

The screening stage is intended to act as a filter for obviously deficient complaints. IPIB’s inbox may be filled with complaints from people caring loudly about issues well outside its purview. Initial screening is a necessary escape-hatch to allow staff to recommend directly discarding such complaints.

After that initial review, “informal assistance” should be IPIB’s bread and butter. The board’s raison d’être is to be an informal alternative to slow, costly litigation. Informal resolution is step one after the initial review.^[2]

After informal assistance, if the complaint is not resolved, staff investigate the complaint to determine if there is probable cause to believe a violation has occurred. During this process, IPIB can issue and enforce subpoenas to obtain necessary evidence; it can also hear witnesses.

This isn’t a full investigation, but an investigation of probable cause. If a complainant says a document was not produced, this would be the step in the process where IPIB might obtain a copy of an email from the city showing that the record was produced.

Finally, if probable cause is found, the case proceeds to a contested case, and IPIB is to engage in fact-finding and analysis of law. A contested case requires gathering evidence, hearing witnesses, and analyzing legal frameworks.

All of that is what the law requires. The diagram below illustrates what actually happens.

IPIB changed its primary process in November 2024. The new process is described in its 2024 annual report as a “new process [that] better aligns with the requirements outlined in Iowa Code chapter 23.” In other words, the process it used before was “less aligned”, or, in regular English: non-compliant.

That non-compliance was the basis for two separate district courts reversing IPIB complaints a day apart — November 29, 2024, was a remand in van Pelt v. IPIB, and Swarm v. IPIB remanded on November 30, 2024. In both cases, the district court agreed the dismissal was improper, reversed IPIB’s dismissal, and remanded the complaint to IPIB for processing.

In Swarm, IPIB accepted the complaint and almost immediately dismissed it again — this time, “as an exercise of administrative discretion.” Swarm petitioned for review of the new dismissal order and the case is currently pending in Henry County. For van Pelt, IPIB appealed and lost at the Iowa Court of Appeals. It has not yet accepted the complaint.

In 2023, before IPIB’s “more aligned” process, it dismissed 69% of complaints at initial screening. In 2025, after the “alignment,” that number became 47%, but 42% were dismissed for lack of probable cause immediately after screening, but still before investigation, and 2% were dismissed for administrative discretion.

Even without additional context the numbers would be a red flag—the board is telling the public that 90% of their complaints are unfounded or not even worth looking at.

Reviewing a small sampling of “insufficient” complaints confirms that they were not being reviewed for sufficiency at all.

Take, for example, 23FC:0026. Here, the complainant “alleged that she requested a copy of a 911 call concerning the report of a deceased body. She alleged that the CCSO denied the request.” This alone already constitutes a valid complaint: a record was requested, it was withheld. Was it lawfully withheld? Maybe, maybe not. That requires an investigation.

However, rather than investigate, IPIB immediately dismisses the complaint for lack of sufficiency because “it is difficult to see a public interest that is met by releasing the 911 phone call under what would be a traumatic situation for all individuals involved.”

Following its determination of trauma, IPIB then decides that the “value of confidentiality” is greater than the public interest. IPIB does not specify what that value is, or what public interests it outweighs. It applied a balancing test to a factual record consisting of a single sentence about the incident: “the 911 call involves an incident in which the caller found a dead body”.^[3]

IPIB never looked at whether the complaint was legally sufficient on its face. It instead applied the Iowa Supreme Court’s Hawk Eye balancing test,^[4] which weighs confidentiality interests against public interest in disclosure. Like most balancing tests, it can only be applied when a developed factual record is available. IPIB applied it at screening, to a single, unverified sentence.

In late 2024 and throughout 2025, after the introduction of the “more aligned” process, these types of dismissals are partly supplanted by “dismissed, no probable cause.” This sounds like an improvement, but on closer inspection it becomes clear that it is a procedural smokescreen and a mislabeling of what actually occurs.

Take, for example, complaint 25FC:0046. This complaint survived initial screening and was accepted by the board. The next step is informal assistance, but no informal assistance was given, and no informal resolution was ever proposed or rejected.

IPIB proceeded anyway. Rather than examine “books, papers, records, electronic records and other real evidence”, or talk to any witnesses, IPIB simply summarized the original complaint and the school district’s response and slapped an “investigative report” label on it. It closed its eyes and saw no probable cause.

The new “more aligned” process fails to see that the most significant alignment issue was never procedural labeling, but a complete lack of informal assistance — the reason for IPIB’s existence. Neither the old “dismiss for insufficiency” process, nor the new “dismiss for lack of probable cause” process includes that critical step.

Finally, 25FC:0042 illustrates what happens when a board takes discretion beyond what the law provides. It is a clearcut case where a college (ICCC) admits that “its Board agendas were posted online without a physical posting”. That violates Iowa’s open meetings law. However, because “ICCC has unilaterally taken measures to ensure all future agendas are physically posted”, IPIB still dismissed the complaint “as an exercise in administrative discretion”.^[5]

Iowa Code Chapter 23 does not provide for administrative discretion. It authorizes IPIB to dismiss a complaint for lack of jurisdiction, find no probable cause after investigation, or proceed to a contested case upon finding probable cause. Dismissing an already-admitted violation appears nowhere in the statute. IPIB relies on its Rule 497-2.2(4)©, which it was never authorized to write.^[6]

What Chapter 23 does provide for is informal assistance, which would have consisted of IPIB discussing the proposed—and already implemented—resolution with the complainant. It might have tried to convince the complainant that there wasn’t much more that could be gained from the complaint. Instead, IPIB decided it was done and dismissed the case.

Rather than provide informal assistance, which is the reason the board exists, an increasing majority of IPIB’s decisions fall within those three categories of dismissal.

IPIB at the Court of Appeals

In its appellate brief in van Pelt v. IPIB, the board rejected its job out loud:

Van Pelt wistfully opines that IPIB’s failure to conduct a formal investigation of his complaint rendered unavailable discovery methods that would have otherwise been accessible to him had he directly filed an enforcement petition in the district court against WDM under Iowa Code section 22.10. Yet, “Iowa Code section 23.5 offers a choice to persons seeking to enforce the open records law.”Van Pelt voluntarily chose to file a complaint with IPIB against WDM in lieu of directly pursuing judicial enforcement of his records request in the district court.By electing this particular remedy, van Pelt subjected himself and his complaint to the framework IPIB implemented through its administrative rules to review and adjudicate public records complaints.

IPIB shamelessly used the word “wistfully” to describe a valid legal argument about its flawed case-handling resulting in a loss of statutory rights. That word choice tells you everything about how the board views the people it was created to serve: not as parties with enforceable rights, but as nuisances who should have known better.

That same contempt surfaced when IPIB asked the District Court to stay its order:

. . . any perceived delay in processing van Pelt’s complaint would not constitute a violation of any applicable statutory or administrative requirement as neither Iowa Code chapter 23 nor IPIB’s administrative rules place any deadlines upon the Board’s complaint intake and investigative functions.

In so many words: “even if you make us look at the complaint, we’ll take as long as we want, and there’s nothing you can do about it.” Never mind that IPIB’s own rules require it to “promptly work with the parties” toward an “expeditious resolution.” Following the rules it wrote does not appear to be IPIB’s strong point.

The van Pelt v. IPIB case began life as IPIB complaint 23FC:0104. The short version^[7] is that the complainant — me — had requested a “deployment plan” for a company’s surveillance cameras from the City of West Des Moines. That plan was incorporated by reference into its contract with its vendor. West Des Moines responded “we didn’t download it from the vendor website” and IPIB dismissed the complaint without further investigation.

I filed a case for judicial review, originally as a direct challenge to IPIB’s procedural misstep. The trial attorney chose to go in a different, needlessly complex direction.^[8] Nevertheless, the District Court found that IPIB had not done its job and sent the complaint back to IPIB for processing.

IPIB chose to appeal and lost on the grounds that the complaint was legally sufficient. But even with an appellate opinion on the books, the board refuses to entertain even the possibility that its process or its interpretation of law may be flawed.

The Iowa Court of Appeals opinion explained that when a government body’s contract expressly incorporates a document, that document “belongs to” the government body under Iowa Code § 22.1(3)(a) — even if the body never retained a physical copy.

The Court also held that the City, as a party to the contract “always has a right to” the entire contract — including what is incorporated into that contract — and that under binding precedent,^[9] the City had a duty to produce it from readily available sources.

The opinion then closed two common defenses: first, a claim that a vendor “owns” the document.^[10] This defense fails where the government body has contractual approval rights and ongoing obligations. Second, the claim of “I don’t have it.”^[11] This defense does not work when an ongoing contractual relationship gives the body ready access.

But perhaps most significantly for future IPIB complaints: the court defined the review standard for IPIB’s initial screening. It describes it as equivalent to a motion-to-dismiss standard where all facts are taken as true and the only question is whether the complaint is legally plausible on its face — meaning “does this complaint allege anything that could be a violation?”

As long as the complaint alleges that a government body withheld a record or did not provide notice for a meeting, the answer is almost always “yes.” IPIB cannot resolve legal or factual disputes at the threshold stage and must investigate complaints that clear that bar.

At least that’s what the court says.

Business as Usual

In a meeting on March 12, 2026,^[12] deciding on whether to seek further review by the Iowa Supreme Court, IPIB’s AG-supplied attorney and its board members brushed the decision off as though it contained nothing of substance, commenting “this is not like we’re going to set precedent — it’s [not] going to change the way we do business.”

To find out what “the way we do business” is, you only have to look at the February 2026 meeting agenda. Nine cases were dismissed via the consent agenda. Some appear appropriate, like dismissals for abandonment or lack of jurisdiction, but others, like 25FC:0184, make determinations of fact and law at initial review (“Because there are no records responsive to the complainant’s request, the Department did not violate Chapter 22 when it closed the request.”)

Most insidiously, one complaint was dismissed via the consent agenda through an order drafted by executive director Miller because “complainant does not argue” a specific enough violation of Chapter 22. The complaint itself wasn’t deficient, but the complainant didn’t do IPIB’s job making its legal argument for it.^[13]

At that same February meeting, board member Luke Martz commented to a complainant:

you’re not the first person who’s come to this board frustrated with what we expect our public officials to keep as records that they don’t… you’re not alone.

He then voted to dismiss the complaint for lack of probable cause. IPIB had not held an evidentiary hearing, or engaged in any real fact-finding. It did not subpoena the records to definitively answer whether they exist. The lack of probable cause was wholly based on a passively-voiced “[no] evidence was presented to IPIB that indicated the county was not honest about the existence of the records.”

The remanded van Pelt complaint may be on the agenda for the board’s March 19 meeting; as of March 17, IPIB has not yet confirmed the meeting date or posted the agenda on its website.

The Board’s Legacy

Of all the complaints IPIB has received since its founding in 2012, it lists only four as contested cases on its website. One resulted in a $1,000 fine, one was settled, one was dismissed, and one was appealed all the way to the Iowa Supreme Court. None of them resulted from complaints dated 2018 or later.

The contested case that reached the Iowa Supreme Court ultimately returned to IPIB’s complaint sink, never to be seen again. In Ripperger v. IPIB,^[14] the board found that the Polk County Assessor violated chapter 22. The Supreme Court reversed in part and remanded for IPIB to resolve whether the property owners who requested removal qualified as “persons outside of government” — a factual question the board was specifically instructed to answer. No published order on remand appears to exist. The case entered IPIB’s complaint process and, like the rest, simply stopped.

In addition to handling complaints, IPIB is also authorized to issue “declaratory orders with the force of law determining the applicability of chapter 21 or 22 to specified fact situations”. This allows IPIB to, for example, declare that posting a meeting notice only on a city’s TikTok-account is not sufficient notice, even if nobody has complained about that yet.

IPIB has issued a declaratory order only once, back in 2013. It has, however, produced a number of informal advisory opinions, which are similar to declaratory orders in many ways, but are non-binding informal advice.

In thirteen years, IPIB’s entire record is a single $1,000 fine and one formal opinion. Even worse, IPIB completely neglects the most powerful tool the legislature gave it: the subpoena.^[15]

That’s not a result of underfunding, staff training, or resource limitations. That’s an institution that isn’t even trying. Even when IPIB itself determines there is probable cause that a violation occurred, it does not act. Even when a court tells it to handle a complaint, it would rather appeal and spend years in litigation than do its job.

IPIB in its entirety is perfunctory. Its board members and staff would rather “align” procedures in ways that present the appearance of efficiency rather than address the substance of its work—or the lack thereof.

The agency serves only one purpose, and it’s for the state, not the people: to serve as a complaint-sink for Iowans who believe that access to government is a right, not a privilege to be granted at the government’s discretion.

Connecticut Makes it Work

Connecticut — which has 3.7M residents compared to Iowa’s 3.2M — has had a very similar board since 1975: the Freedom of Information Commission (FOIC). The FOIC has been able to use the same tools IPIB has to mediate two-thirds of its complaints, hold evidentiary hearings, and produce numerous declaratory orders and contested cases each year.

In 2024, the FOIC handled 855 complaints, compared to IPIB’s 134.^[16] Those numbers predate IPIB’s 2025 training mandate. That’s important, because Connecticut abolished county governments and currently has only 169 municipal governments — a fraction of Iowa’s.

With similar populations, you might expect more complaints in Iowa. More government bodies could violate the law, and smaller cities and counties might not have dedicated legal staff, or even full-time staff. The exact opposite is true.

Either Connecticut’s agencies are a lot worse at open records compliance than Iowa’s, Iowans have less interest in local government, or — most likely — Nutmeggers have more faith in FOIC than Iowans have in IPIB. For good reason.

FOIC has eight staff attorneys versus IPIB’s two. Each FOIC attorney handled 107 cases, compared to IPIB’s 67, assuming IPIB’s director does not handle complaints. (45 if she does). FOIC’s 2024 orders aren’t a list of procedural and discretionary dismissals either; in fact, contested case hearings are so common in Connecticut that they’re published via weekly agendas. Iowa has not seen one since 2017.

Colleen Murphy joined FOIC in 1990. She became its executive director in 2005. She retired in February of 2026. Connecticut retains staff and builds deep institutional knowledge while IPIB greases the gears of its revolving door.

IPIB’s Future

IPIB could have been Connecticut. The concept was sound. The incentive structure that has been in place for years has undone the concept and replaced it with an executive bureaucracy wholly divorced from the institution’s original purpose.

For years, IPIB’s budget was flat. The recent bump was accompanied by more work. Its staff turns over faster than it can develop institutional knowledge. Its board members are appointees with no particular accountability to the public it supposedly serves. And the legislature, which created IPIB as a cheap alternative to litigation, has just handed it a training mandate to fully crowd out the complaint work it already wasn’t doing.

IPIB can’t stop and think about what it’s doing while it’s treading water. The legislature has shown the opposite of an appetite for reform. The solution is to dismantle the board entirely and repeal chapter 23.

We could replace it with a new agency, but there is no reason to think it would fare any better. The statute gave IPIB everything it needed. IPIB chose not to use it.

Instead, training functions can be assigned to the Attorney General’s office, where they belong. The AG knows — or should know — open records law well enough to be able to either put together a curriculum, or to approve one to be delivered by a vendor or one of Iowa’s 15 community colleges (at least seven of which have existing legal programs).

Advisory Opinions should not be handled by the AG because of its conflict of interest when defending state agencies. If they are needed, the Office of Ombudsman, which reports to the legislature, could take up the task as it did before IPIB. Alternatively, advisory opinions could be assigned from a lawyer pool, similar to criminal defense appointments.

Adjudication can still happen through the courts. For Iowa Open Records Act (chapter 22) cases, discovery is often unnecessary due to the reversed burden of proof. The Iowa Supreme Court has rule-making authority to create an expedited procedural track for Chapter 21/22 enforcement without new legislation. The small claims process shows that courts have ample leeway in setting expectations for plaintiffs.

IPIB’s declaratory orders — of which only one exists — are covered under the courts’ general declaratory powers.

An informal complaints process is mostly unnecessary. Informal resolution is baked into the general concept of settlement negotiations when a case is reviewed by a court. Governments only settle when it hurts less than the alternative. Taxpayer-funded attorney fees keep that threshold high regardless of forum. Fee-shifting and court-enforced fines for individuals — recently raised to $12,500 for open meetings violations^[17] — can provide pressure where IPIB won’t.

But resources spent on mediation would likely be better redirected to free or low-cost legal aid for citizens, and potentially, if it can be kept sufficiently conflict-free, a general “open government helpline” at the Attorney General’s office for both citizens and governments.

Dismantling the board would remove citizens’ temptation to fall into the § 23.5 false election-of-remedies trap. Complainants already need to go to court to get IPIB to investigate. Staying there is the more efficient option.

Swarm v. IPIB illustrates the trap: Swarm’s case stems from an open meetings violation he alleges happened in January 2022. After IPIB dismissed his complaint, Swarm sued the city for the violation, but amended to put IPIB’s name on the suit. When he did, the city joined IPIB. Sixteen months after Swarm filed the case, the district court heard it. It then sat on it for another ten to decide what to do.

It took a full twenty-six months and going toe-to-toe with both the city and IPIB — who filed a combined five attacks on the case before even filing an answer^[18] — as a self-represented litigant, but Swarm ultimately prevailed.^[19] The complaint was then sent back to IPIB’s “efficient, informal, and cost-effective process for resolving disputes” to finally be looked at. IPIB instead made a near-immediate determination: “probable cause exists to believe a violation has occurred, but, as an exercise of administrative discretion, [we] dismiss the matter.”

Today, more than four years since the alleged violation happened, Swarm is back in court fighting IPIB.^[20] He has made no progress whatsoever on the original complaint — Mount Pleasant and IPIB have been spending scarce judicial resources and taxpayer money for years so that one can avoid slapping the other’s wrist.

In January of 2026, Eulando Hayes also filed a lawsuit against IPIB, seemingly because of further improper “probable cause” dismissals in 25FC:0141^[21] and 25FC:0142.^[22]

When the board is dismantled, Chapter 23 should be repealed in its entirety and any pending complaints should be dismissed without prejudice or triggering the election-of-remedies statute, to be refiled in court.

It’s been more than thirteen years. The board has issued only non-binding advisory opinions, one fine, and one declaratory order. At least two separate litigants have spent years in court in their efforts to get IPIB to look at their complaints — so far unsuccessfully. A third just started.

Even if IPIB survives, the “election of remedies” in § 23.5 must go. Iowans should be able to trust a government agency to do what it says on the tin. But when that fails — when appointees decide doing their job is discretionary — citizens should not be left wistful, longing for a state that believes in the laws it creates.

Whether that is already done or will be done soon is unclear, but it answers another recent question: “what happened to the ‘devices searched’ column?” A few weeks ago^[1] that column disappeared. We know Flock likes to alter contractual terms and unilaterally remove audit capabilities. We also know that its “Devices searched” field disappeared for a while between November 2024 and February 2025.^[2] It has been unclear if this latest removal was on purpose, and, if so, what that purpose might have been.

A quasi-enlightening email exchange^[3] begins in August 2025, when a police officer asks Flock about “vehicle reads from the Condor cameras.” (Quick reminder: Condor is Flock’s PTZ “AI-powered video” camera that automatically zooms in on your phone). This was confusing to the officer because Condor cameras are not ALPR devices. He, like many elected officials and police officers, likely did not understand that Flock’s LPRs aren’t either.

There is no meaningful difference between an “LPR” (which, by the way, is Flock’s product name, not its category) and a “Condor.” They record things, they are analyzed via machine learning or AI, or Upwork contracts, and they are searchable by anyone Flock chooses to give access. Both the “LPR” (formerly “Falcon” and “Sparrow”) and the “Condor” are AI-powered surveillance cameras.

The officer’s inquiry came about 4 months before YouTuber Benn Jordan disclosed a separate security failure on the same Condor line: debug interfaces on what Flock characterizes as “a very small number” of units had been left Internet-accessible without password protection. Flock said it was a limited, isolated configuration issue and blamed it on Verizon. It was, however, another symptom of having no organizational controls in place. Both incidents involve Condor cameras doing things they weren’t supposed to do, and Flock did not proactively notify its customers about either.

A little over a month after the officer’s email, a search revealed >257,000 cameras. The log entry was accompanied by a note:

An issue was identified that caused the system to initiate unprocessed search activity on a larger set of cameras than intended by the user. No footage or data from these devices was accessed or viewed. The underlying bug has been fixed, and additional safeguards have been implemented to prevent recurrence.

At the time, I noted that the note does not deny that the cameras were real. I concluded that the “number includes Flock’s retail customers, like Lowe’s, Academy Sports, and FedEx.” My conclusion was based on an assumption that Flock would not merge what it holds out to be its “LPR” network and its general-purpose “AI-powered surveillance” network. I now believe that assumption was wrong.

Flock checked with engineering and responded to the officer’s email. The response was that Condors should not be showing in the “vehicle reads,” but that the engineering team was working on some new features for 2026. It was “refining” some of the data. That, according to Flock, is what caused the issue. The answer was not any more specific.

What “refining data” means is anyone’s guess, but what we do know is that Flock was rolling out FreeForm around that time. FreeForm went into “Early Access” in March of 2025. “Early Access” is a term you’d expect to find on Steam, not in your mass surveillance contract. On Steam, the term is widely understood to mean “buggy and not suitable for any serious use” — a warning that your save may be deleted or your PC might crash. Flock slaps the label on a technology that can search for people, where it’s constrained only by a broken AI moderator.

I’ve often mentioned the other oddities in August 2025; possibly first in an analysis of logs from Santa Cruz, where 90% of logs disappeared overnight. That data also showed a massive change in “search” vs. “lookup” usage, a pattern that would become visible across organizations. For example, Houston, TX, did 492,000 searches in May but “only” 183,000 in August (still roughly 6,000 searches per day).

Maybe by August our civil rights were ready for beta.

These anomalies have never been mentioned in an audit report that I’m aware of, and Flock has not addressed them other than maybe through this statement about data refinement.

After the email exchange, and reviewing data from the FreeForm report, I now think it’s likely that the 250,000 number reflects Flock’s broader network — with or without retail customers — including Condor and potentially other AI-powered surveillance cameras. The email doesn’t say that. But Flock was actively “refining data” across camera types at the same time FreeForm soft-launched, and the 250,000-camera anomaly appeared one month later. That’s circumstantial. It’s also the most coherent explanation available until Flock, or any of its customers, offer a better one.

After unification, maybe Flock will (or does) offer a search interface that attempts to maintain illusory ALPR status, or maybe it will (or does) have a single interface for searching over a quarter of a million cameras that automatically follow you around and zoom in on your phone. Its AI moderator could continue to approve terms like “jeans” and “tweaker on a bike”, or it could not.

Maybe Flock will bring back the “Device count” column some day, maybe not.

We still don’t know what they’re refining or why they’re refining it, but whatever it is, they’re doing it in secret. The column is gone, the data changed overnight, and not a single audit report has addressed it.

Its newly-launched Trust Center answers such hard-hitting questions as “Is this mass surveillance?” with:

Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat.

Though, to be fair, that answer is better than the complete fabrication elsewhere on its page that says “Flock does not operate a centralized or open surveillance database. Each customer environment is independent.”

The meaning of “centralized database” is clearish — Flock likely tries to distinguish it from a decentralized database. In this case, that claim is similar to claiming your kitchen is not a centralized place for your pots and pans because you have multiple cupboards.

“Global database” is equally almost-apparent. What the new term “open database” (it also appears on another page) is supposed to mean is murky. Maybe it will clarify later, or maybe the murkiness is the point.

In any case, it will be interesting to see what elements survive contact with the legal team. One page makes claims about academic research partnerships and third-party audits — neither appears to exist in any meaningful way:

Another page claims that the GDPR is “The world’s strictest standard for data privacy.” Which is not only incorrect, but shows a complete lack of understanding of what GDPR actually is and how it works (it is a regulation that sets a floor, not a ceiling — member states can and do impose stricter requirements).

Anyway …

The fact that a half-finished set of pages found their way to production is embarrassing but not, in itself, a major issue. I can’t judge that too harshly because I pretty much develop in production all the time.

Where it becomes an issue is when you’re looking at organization-wide controls and data governance, as in SOC2 or ISO27k1, which Flock cites in support of its being deserving of trust.

These are essentially wireframed pages. Who deployed them to production? The answer to that question is almost certainly some web developer or marketing associate working on the page layout and design.

Did Legal or Compliance approve statements like “Lorem ipsum” for public consumption? My magic 8-ball says “absolutely not.” Did the product team review the system description for accuracy? “Try again.”

The release of these pages is a symptom of Flock’s broader problem: it fails to implement meaningful controls on access while claiming it has them in its marketing materials. This page is one example.

Another is this screenshot from a video showing a Flock customer service representative with full access to the admin interface for what appears to be every single Flock customer:

According to Flock’s lorem-ipsum-heavy Trust Center, we are looking at independent customer environments with proper access controls, and definitely not a centralized or open surveillance database where a low-level Flock employee can click a button to obtain access.

The secondary problem in that screenshot (there are more in the complete video, but more on that later) is that Flock apparently classified the Olympia Fields IL Park District as “Law Enforcement.”

Presumably that means that it has access to the database that stores information from Flock’s national network of 250,000+ cameras (more on that later too).

This is a problem because the Park District does not appear to be a law enforcement agency at all — it manages playgrounds, picnic shelters, and a disc golf course.^[1]

But once again, nobody appears to have caught the error, despite all the safeguards, constraints, audits, and controls that Flock touts in its trust centers, old and new.

An agency has access to data it’s not supposed to have, which shows up in a video recorded by someone who can access data they’re not supposed to have access to. The Trust Center, which was also published by someone who should not have published it to an environment they should not have access to, says everything is fine.

Flock can’t be trusted. No amount of lorem ipsuming will change that.

• Data Privacy
• Facts vs Myths
• Civil rights
• Law enforcement

Where Hotlists Come From

First, the official watchlist: this comes from the FBI’s National Crime Information Center (NCIC), which is “a computerized index of missing persons and criminal information and is designed for the rapid exchange of information between criminal justice agencies”.^[1] The FBI’s database was created in 1967, and has since grown tremendously in scope.

NCIC stores information about property (vehicles, firearms, etc.) as well as people (e.g., warrants, gangs, terrorism, anyone of interest to the secret service). This information can then be queried by state and local agencies, in accordance with the FBI’s terms, which are laid out in federal regulations and the CJIS Security Policy.

The information from NCIC — which is often inaccurate — is uploaded by states, after which the federal government and its state partners make it accessible to federal and local agencies via portals like Palantir’s ICM and Falcon, and, to the point of this article, Flock’s FlockOS and its “hotlists.”

Until recently,^[2] Flock had a blog post on its website called “What Happens When a Wanted Car Passes a Flock Safety Camera?” That post appears to have been deleted in a hurry. It is still linked to from Flock’s other blog articles, including one that describes the “Hot List feature.”

Because Flock has requested that sites like archive.org’s Wayback Machine not archive the content on its site, an archived copy is unavailable, but here is a paragraph from a referencing post:

Flock Safety’s Hot List feature allows businesses to receive alerts on stolen vehicles, known wanted criminals and more, as long as the private business chooses to share their LPR cameras with law enforcement. Law enforcement will then be automatically notified if a vehicle associated with the NCIC enters your property, allowing them to take action. It works via an integration into the Federal Bureau of Investigation’s National Crime Information Center (NCIC), which is updated daily.

Customers can also place at-risk vehicles or license plates on custom Hot Lists to alert law enforcement or on-site security instantly if/when they enter their property. — “Vehicle and Catalytic Converter Theft: Flock Safety’s Solutions for Businesses,” Flock Blog, May 14, 2025

The “Customers” referred to are Flock’s commercial customers.

The Unregulated Layer

This is the second category of watchlist: managed by local police agencies, HOAs, neighborhood associations, and businesses, and shareable without constraints — but somehow still exempt from public records law, according to police agencies.

NCIC entries, which have specific retention policies and restrictions on sharing, are often copied to custom log entries in the Flock system.

Other entries, like the one shown on the “SUS Vehicles” hotlist, can be for vague reasons like “Poss vin swap, stop and verify” — suggesting the vehicle has been placed on the list to be stopped without probable cause, or, at best, for pretextual reasons.

These stops are then combined with departmental policies to keep their use secret, like those seen in Wapello County, Iowa:

DO NOT MENTION ALPR USAGE TO THE OCCUPANTS OF THE VEHICLE. Simply reference that you ran the plate and observed an NCIC hit … DO NOT MENTION ALPR USAGE IN YOUR REPORT OR COMPLAINT UNLESS ABSOLUTELY NECESSARY. … If it is necessary to explain in a report, it is advised to use language such as “Using County resources, I discovered the suspect vehicle was bearing Iowa plate…” — Wapello County Sheriff’s Office SOP III-20, November 7, 2025.

Whether a stop was conducted based on a watchlist hit can only be established if a defense attorney asks the question and the police answer it. That may not happen until the victim of an unlawful stop has spent days, weeks, or even months in jail.

What Counts as a “Reason”

I examined 800 “Custom Hotlist” entries entered by Harris County Constable Precinct 5^[3], which covers over 300 square miles of western Houston suburbs — an area with 1.3 million residents, policed by roughly 450 sworn deputies. 101 of those deputies — nearly one in four — appear as users in the hotlist logs. 51% of entries had no listed case number and 73% were set to never expire. The criteria used varied from outstanding warrants (copied over from NCIC), vague suspicion that a VIN may be altered, or no reason at all.

An investigator at the Precinct 5 constable’s office used Flock to locate and seize a vehicle for an alleged theft that another county refused to investigate, that was never entered into any criminal database, and whose statute of limitations expired seven years earlier. The hotlist entry reads:

Vehicle is not listed as stolen in NCIC/TCIC. Registered owner claims vehicle was stolen out of Colorado County in 2012. Colorado County refused to enter vehicle as stolen. Find PC and stop/identify all occupants… Vehicle will be seized for a Civil Seizure hearing. Do not release vehicle

Investigator James Dancer created this entry on July 3, 2024, for a Texas plate ending in –981^[4], case number 2407-00085, with a one-month expiry of August 2, 2024.

The vehicle was allegedly stolen twelve years ago, according to a claim by the registered owner. Another agency — Colorado County — had already declined to enter it as stolen; possibly because the statute of limitations expired seven years earlier, in 2017.^[5]

Colorado County already decided there was no criminal case here. Dancer’s entry instructs his peers to manufacture a justification for a stop (“Find PC”) and seize the vehicle anyway. That outcome (“Do not release vehicle”) is predetermined in the hotlist entry. Once the vehicle is seized, civil forfeiture requires only a “preponderance of the evidence” that the vehicle is connected to criminal activity.

The vehicle, which is at least twelve years old, won’t be returned to the registered owner. Instead, it will be sold at auction and the proceeds will go to Dancer’s department and the Harris County district attorney. The Institute for Justice has previously filed a class-action suit for exactly this type of abuse of the civil asset forfeiture process in Houston.

Dancer’s entry also contains an instruction that appears 47 times across the 800 entries: “Find PC and stop/identify all occupants.” In 31 of those, the instruction was created by Kayla Cohan (formerly Fesperman) using a near-identical template: “BMV Susp Vehicle- BLK FORD BRONCO-Develop PC, Stop and ID Occupants.” Burglary of a Motor Vehicle (BMV) is typically a misdemeanor. These entries instruct officers to first locate a vehicle through Flock’s automated surveillance, then find or develop a legal pretext for the stop afterward — inverting the Fourth Amendment’s requirement that probable cause precede the seizure.

There is no reason to believe that the “occupants” of these vehicles, who are entirely unknown at the time the entry is created, are involved in the crime the driver is suspected of committing. That crime is equally unknown until someone “finds PC.”

Similarly, another one of Dancer’s entries for a vehicle that could be related to shoplifting at Bath and Body Works contains a slightly more detailed instruction:

Bath and Body Works Shoplifting Suspect Vehicle/ Find PC, Stop and Identify all Occupants. if any arrests are made, contact Investigator James Dancer (5I10), will most likely make scene. Contact Pct. 5 Dispatch (281) 463-6666. Send all questions/ information to James.Dancer@cn5.hctx.net

The investigator email addresses and direct phone numbers embedded in these reason fields serve a secondary purpose: when hotlists are shared between agencies, the receiving agency also receives internal contact information for the creating agency’s investigators — an informal contact-sharing network piggybacking on the surveillance system.

Another vehicle is put under indefinite surveillance by Andrea Trevino. No case number given: “SURVEILLANCE ONLY//DO NOT MAKE CONTACT.”

Jose Ramos added 6 vehicles for “Tolls” — five with no case numbers, one with case number “N/A”, all set to never expire.

Mental health crises can land you on the watchlist: “SUICIDAL GUY” (one month), “WARRANT AND SUICIDAL GUY” (no expiration), “SUICIDAL ARMED” (one month), “Welfare Check” (one month). None had case numbers.

You can also earn a permanent watchlist spot for how your car sounds: “Engine does not sound stock;” or for cryptic reasons like “300 has a badge”, “Memorial Mall”, or simply because the sergeant said so (“Sgt request”, case number: “theft warrant”).

Other entries include “SUS”, “sus veh”, “susp”, and “fug”.

A dashboard from an Iowa agency shows that even where reasons are entered, they indicate problems; there is a hotlist for “Sex Offender” — a conviction is not justification for indefinite surveillance — as well as a hotlist for “Protection Order.”

That latter category’s existence is surprising, given that Arkansas and Wisconsin police failed to act when a person with an ankle-monitor passed at least one Flock camera, as he went to the home of a 16-year-old who had a protective order in place. The pair then disappeared for two months, until someone spotted them at a truck stop in Nebraska.

Sharing Without Scrutiny

When hotlists are shared, the receiving agency receives an automated email from Flock. That email considers the data sharing to be “Great News!” and provides instructions on how to start using the shared hotlist.

What it does not provide is information about what is on the list — including whether the hotlist contains any information sourced from NCIC, which would be restricted by law. It also does not provide information about the policies in place for maintaining and populating the list.

Flock sent the email above to a Minnesota agency. The email does not mention that Minnesota law^[6] says ALPR data “may only be matched with data in the Minnesota license plate data file” or when related to an active criminal investigation. Instead, Flock cheerfully directs its agency customer to accept the mystery hotlist from Florida — in a way that more likely than not violates Minnesota law — and thanks them “for being part of the Flock.”

Although Transparency Portals include a “Hotlists Alerted On” column, Transparency Portals don’t appear to show custom hotlists.^[7] Flock’s transparency portal configuration tool, however, shows that “This value will be automatically generated according to your Flock settings.”

Flock Won’t Say How Often It’s Wrong

A common concern surrounding the use of automated enforcement is accuracy — we know that misreads happen, but we don’t know how often. And Flock won’t say.

Flock monitors and collects misread rates; it declined to provide Business Insider with specifics about the data. When customers flag misreads, that data is pulled into the company’s training set to improve its model, and the company works with local law enforcement to understand the cause of the incident, a spokesperson said. — ‘Flock Flocked up’, Business Insider, March 9, 2026.

What Flock has said, in its undated^[8] blog post “Assessing the Accuracy of Computer Vision Methods for Traffic Data Collection,” is that “Flock Safety cameras correctly identified 92.3% of vehicles by classifying them across six vehicle categories via computer vision, in accordance with the FHWA’s 13-bin classification system.”

The FHWA 13-bin system uses broad categories like “Motorcycle” or “Five-axle single-trailer trucks.” It has several categories for tractor-trailer combinations with differing numbers of axles. Flock doesn’t specify, but most likely reduced the number of bins to six by collapsing several vehicle classes into a single “truck” classification.

That 92.3% figure measures vehicle type classification — whether the system can tell a motorcycle from a tractor-trailer — not plate-reading accuracy. If Flock’s cameras fail to correctly classify vehicle type in nearly 8% of cases using these broad categories, their accuracy at reading individual plate characters or matching the more granular attributes in its FreeForm search — clothing, dents, and other vehicle and person characteristics — is anyone’s guess. Flock’s refusal to disclose plate-read accuracy or submit to independent auditing leaves that question unanswered.

Even NCIC Gets It Wrong 77% of the Time

But even when accuracy is discounted, an overview of Axon data from the Story County, Iowa sheriff’s office^[9], shows that matches are often a bust. In Story County’s “Erroneous hotlist hits” report, which covers approximately a month, hits were only sourced from NCIC.

In that month, the sheriff’s office reported 214 incorrect hits. 165 (77%) were flagged “Wrong state,” 10 were “correct” but “No action taken,” “No Associated Party in Vehicle” or “Parked - Unoccupied,” 7 were “Dismissed,” and 3 were “incorrect.” The report does not include information about the total number of scans, or the number of accurate hits.

77% of vehicles from NCIC being matched to vehicles from the wrong state is an issue. The issue is further compounded by NCIC not distinguishing between characters like “O” and “0” or “I” and “1”. And that’s NCIC, which has policies on accuracy and review of information.^[10] For Flock’s “Custom Hot Lists,” all it takes for someone in Minnesota to get pulled over is for Brittany Smith from Florida to enter an incorrect digit.

Even if the technology were 100% accurate, which it isn’t, it is still subject to the principle of “Garbage in, garbage out.”

Who Else Gets the Data

After an entry is created or copied into a custom hotlist, users can opt to receive notifications through Flock’s mobile app. If the entry is criminal justice information (CJI) copied from NCIC, it may only be accessed through a secure workstation.

Instead, Flock encourages use of its mobile app, which offers simple on/off toggles for receiving alerts. It also offers notifications based on a user’s location, suggesting Flock mobile app users’ locations are being recorded and tracked.

The risks of inaccurate or poorly-maintained hotlists to the public are well-documented. In Sherwood, Arkansas, a Flock ALPR misread a plate obscured by a loose plate holder. Police ordered a couple out of their car at gunpoint and handcuffed the woman in front of her children. In Morristown, Tennessee, a Flock camera misread an “O” as a “0,” and the Herron family — with their 3-year-old granddaughter in the car — was pulled over at gunpoint. In Toledo, Ohio, a misread “7” became a “2,” and Brandon Upchurch was mauled by a police dog and jailed. And in Aurora Colorado, an unidentified system flagged an SUV as a stolen motorcycle from another state — the plate number was the same, but it was the wrong state, like in 77% of Story County, Iowa’s erroneous hits.

But members of the general public are not the only ones at risk — police officers are too.

The hotlist data itself is federally regulated under the CJIS Security Policy:

[W]hether it’s bring your own device (BYOD) or a agency-issued phone, [law enforcement] must follow the protocols set out by the FBI’s Criminal Justice Information Services (CJIS) compliance for mobile device security and adhere to the CJIS MFA requirements that go into effect October 1, 2024 — Essential guide to agency-issued phones and BYOD policies, Verizon Business, September 13, 2024.

But those rules don’t extend to the data Flock collects through the app — like location data. It can collect or resell that data, or use it in its other products. There is no requirement for Flock to safeguard that data, or to screen the people — employees and contractors — with access to that data.

How much of the data Flock transmits is unclear, but the mobile app has a direct integration with FullStory^[11], a “Behavioral Data & Digital Analytics Platform.” It is equally unclear where the data goes from there.

We have already seen the predictable outcome when Flock failed to secure an API key and leaked live location data, including this exact “Officer mobile app location data (phone, smartwatch).”

With no functional safeguards in place, a history of leaks, and no consequences imposed by the Department of Justice or state agencies, it is left for individual officers to decide if they want Flock to enter their realtime locations — potentially both on-duty and off-duty — into its database, and whether all of Flock’s employees, contractors, and partners should have access to that data.

No Recourse, No Oversight, No End Date

There is no mechanism to discover which agencies are using what custom hotlists, or for a person to discover whether they are on a custom hotlist, to challenge their inclusion, or to request removal. There is no judicial review, no expiration requirement, and no independent audit.

The entries examined here — 73% set to never expire, half with no case number, many with reasons no more specific than “SUS” — are not aberrations in an otherwise functional system. They are the system functioning as designed.

Flock’s marketing promises transparency and accountability. Its logs consistently tell a different story: indefinite surveillance authorized by a single officer’s keystroke, shared across jurisdictions without review, immune from public records requests, and enforced through pretextual stops that its own users are instructed to manufacture.

The question is not whether the technology works. The question is whether anyone is watching the people who use it.

The answer, to date, is “No.”

After writing yesterday’s feature announcement about the new cost estimate feature, as an afterthought I did a quick query to see how many agencies used “FreeForm” and how often it’s used. The result: 6,736 “FreeForm” searches in 2025 across 121 agencies. At a $50,000 annual subscription MSRP, that works out to roughly $900 per search.

Naturally, I wanted to know what, if anything, makes these searches so valuable.

Flock’s FreeForm

Flock writes that “Flock’s ALPR system cannot be used to search for human characteristics, like race or gender” on its ethics page. In another recent blog post, recently discussed here, Flock takes it a step further:

Flock products do not identify race. They do not target neighborhoods based on demographics. They do not rely on subjective descriptions. They do not expand broad discretionary stops.

Instead, they narrow law enforcement action to vehicles that have been objectively linked to reported crimes.

The FreeForm product page even promises that “[m]oderation tools help prevent biased or inappropriate searches and support responsible, community-trusted policing.”

That narrative is echoed throughout Flock’s website, and aggressively carried out by its 200 sales staff.

In Q2 of 2025, Flock launched a new feature that “is all about one thing: speed. Speed to leads.”

In a move that will transform the largest network of LPR cameras in the nation, Flock announced that every existing Flock LPR camera can soon become video-enabled at no cost to the customer.

FreeForm, Flock’s AI-powered search tool, now works not only on owned LPR cameras but also on shared ones. It also supports video searches—meaning you can now search for characteristics on people* (e.g., “man in blue hoodie with backpack”) just like you would search for vehicles. You can even set alerts on these searches: think “green ATV on a trailer” or “person in orange vest,” so you’re notified in real time when there’s a match.

Plus, FreeForm is now compatible with third-party video feeds (e.g., Genetec, Milestone), so agencies can leverage its power without needing to switch platforms.

It notes that “people characteristics cannot be searched on LPR feeds, only video feeds”.

The FreeForm report (was “Moderation Report”) has been online for a while, but with few search entries and no documentation I never paid much attention it.

Now, almost a year after Flock’s Q2 2025 product announcement, we have a collection of searches from network logs provided by Flock LPR-system users — searches that show lookups for “objectClass:person” and “objectClass:people.”

The Constitution

The 2020 memo to Congress “Racial Profiling: Constitutional and Statutory Considerations for Congress,” written after the death of George Floyd, gives an overview of the boundaries of permissible searches.

The Equal Protection Clause “bars most law-enforcement decisions based on race,” and this prohibition holds “even if members of a given race are responsible for more crimes in a particular neighborhood.”

Courts have also held that “an officer cannot meet the Fourth Amendment standard by relying on a person’s racial appearance, alone, as grounds for reasonable suspicion.” But an officer may include race when “searching for a person matching a suspect’s description and part of that description is the suspect’s race.”

The Searches: Dragnets and Military Personnel

After analyzing 3,217 searches from 124 agencies — 3,184 of which Flock’s moderation allowed, 19 it blocked, and 14 it warned about — it’s clear that the “FreeForm” system that’s implemented is not the one that Flock describes, or the one the Constitution requires. Instead, it is a digital free-for-all where cops go on fishing expeditions based on protected characteristics. Flock even blocks the most obviously constitutional searches.

Houston PD searched 53,017 devices across 3,734 networks for “white car with black front bumper” (reason: murder investigation). That is a description so generic and a dragnet so wide that it would match tens of thousands of vehicles nationally.

Houston PD also searched that same 53,000-device scope for “Marine Corps” and “volkswagen jetta U.S. marine corps” — the first of which is a bare military affiliation search with no vehicle descriptor at all.

“Marine Corps” as a standalone search term, run across the entire Flock network, is functionally a request to identify every vehicle in America displaying USMC insignia — which would include many active service members and their families.

Since December 2025, Flock redacts its network logs before providing them to its customers whose data is being searched. Those customers can’t see who ran the search. Flock, and many of its customers on the nationwide network, maintain no policies requiring background checks or prohibiting account sharing. That’s a “local decision,” says Flock.

We can’t say, or even begin to speculate, who searched the country for “Marine Corps” and for what purpose. All we know is that someone did, and that Flock’s AI-moderator approved it.

Louisville Metro PD regularly searched 39,000–42,000 devices across 2,600–2,800 networks. One search: “overloaded waste hauler” — a code enforcement query — hit 39,751 devices across 2,672 networks. Louisville is using Flock’s AI-powered search to run municipal waste-hauling compliance checks through a nationwide surveillance apparatus.

O’Fallon, Missouri PD — a city of about 90,000 people — searched 41,054 devices across 2,707 networks for the person descriptor “jeans.” No case number. Reason: “inv.” That search hit cameras in thousands of jurisdictions across the country, looking for Americans in blue jeans.

Corona, California PD consistently searched 11,400+ devices across 370+ networks for person searches including “a person,” “police badge,” and “fire” — the first of which is literally searching for the existence of a human being.

All of these are overbroad fishing expeditions using a mass surveillance system. There is no valid investigative purpose in looking up “a person” or “jeans.” Retrieving the location history of every US Marine in the nation does not prevent crime, it hurts national security.

The Moderation System: No on “white male” — Yes on “tweaker”

The most constitutionally defensible person search in the entire dataset was the California Highway Patrol’s prompt:

Looking for a white male about 6ft 1in tall, longer brown hair almost to his shoulders, slender build, will have been wearing blue jeans, boots with white paint stains on the toes and possibly carrying a black helmet

This was a search across only 91 devices and 3 networks. It is a textbook individualized suspect description: race as one of many physical identifiers, exactly as Fourth Amendment jurisprudence permits. It was run in a narrow area where this suspect was likely to be found.

Flock rejected the search. The most probable explanation, based on other searches, is that it saw “white male.”

Meanwhile, Florence, South Carolina PD searched for “all” (objectClass:people, reason: Robbery) — a search that matches literally every person on camera. Also allowed from Florence: “people,” “hoodie,” “jacket,” “jeans,” “Red.” These were searched across only 1 device and 1 network, suggesting Florence was early in deployment or testing, but the moderation system approved them regardless.

O’Fallon MO PD’s “jeans” search hit 41,054 devices. If Florence’s identical search was allowed on 1 device, there’s no scale-based restriction either.

Hemet, California PD searched for “tweaker on bike” across 1,581 devices and 30 networks. No reason given. No case number. “Tweaker” is a slang pejorative for methamphetamine users. This is the definition of a “subjective and invasive search” — targeting people by perceived social status and assumed drug use.

Unlike the search for a highly specific white male, the moderation system allowed this search for any tweaker.

The First Amendment

An objection that’s often raised is Flock’s (admitted) ability to search for bumper stickers and other characteristics. Flock regularly claims that it is only the existence of a bumper sticker that can be queried, not its content. That is not what the logs indicate.

Spokane County WA SO searched for “american flag,” “coexist sticker,” and “trump flag” on vehicles. All three triggered a warn status. The reason fields — “freeform suspicious search test” — indicate Spokane was deliberately testing the moderation boundaries.

What happens when Flock’s AI-moderator issues a warning is not entirely clear. From earlier analysis of frontend code, it is a dialog that can be clicked through. It’s possible that someone gets a notification or an email. We don’t know.

Flock’s system knew these searches were problematic, and it flagged them, but it did not block them, as its product pages promised.

Corona CA PD searched for “american flag” on people and got blocked. The same agency searched for “american flag” on vehicles and got warned.

O’Fallon MO PD searched for “vehicle with flag” across 40,235 devices and 2,642 networks. Allowed. No warning. The generic “flag” search is arguably broader and more concerning than the specific “american flag” or “trump flag” searches that triggered warnings.

CHP searched for “Hells Angels” as a vehicle descriptor nine times (8 allowed, 1 warned from San Jose PD). The allowed searches used reasons like “Investigative Follow-up” and “Traffic Collision.” Searching for vehicles displaying Hells Angels insignia — rather than a specific vehicle involved in a specific incident — targets organizational membership.

If CHP wanted a specific motorcycle involved in a traffic collision, the search would describe the motorcycle, not the association. Seven of the nine Hells Angels searches hit only 190 devices and 1 network, suggesting a narrow local scope — but the moderation principle is the same regardless of scale.

Audit Logs and Objectivity

Of course, the majority of these searches do not have case numbers. We know by now that the claim that “every search made within the Flock platform is logged and auditable, creating a tamper-proof trail of accountability” is completely false. The sensitivity of the data being searched here — like “Marine Corps” — highlights how important it is to be able to audit a search’s full context.

Only 85 of 3,217 searches — 2.6% — had a plate field that could have contained a value. None of the problematic searches discussed above were among them.

The “objective criteria” Flock allows include a descriptor like “tweaker” but not a detailed description of a white male. It allows searching for every white car, or every military member in the nation, and only lightly wags its finger at you when searching for protected political speech.

Flock’s AI-based moderation appears inconsistent and insufficient. It certainly won’t lead to “responsible, community-trusted policing.”

This is an insecure, unaccountable, and unrestricted dragnet that can be — and is — used to mass surveill Americans based on their political, professional, and religious affiliations, their protected personal characteristics, and their expression of speech. It is exactly what the Constitution prohibits.

For each of those searches, lawful or not, Flock collects $900.

Don’t confuse it with the other proposed ALPR bill, House File 2161, a bill that was amended to give the insurance industry access to surveillance data.

H.F. 2701 doesn’t do that. At least not out loud. Its central accomplishment is eliminating oversight.

Virginia, but less transparent

H.F. 2701 closely tracks Virginia’s HB2724 law, which came into effect in July, 2025. Much of the language in Iowa’s bill was lifted verbatim from Virginia’s.

The Richmond Times Dispatch published an article today, titled to tell Iowans in no uncertain turns what the proposed bill really holds: “State won’t say which law enforcement agencies are breaking surveillance camera laws.”

Under the new laws, agencies can’t share their databases with other states or federal agencies. But at least nine self-reported that they were still allowing federal agencies continuous access to their databases, and another 20 were still allowing out-of-state agencies that same access, the crime commission said in it’s*[sic]* January report.

The commission won’t, however, identify which agencies are violating state law – and it is not required to release records to the public due to a longstanding exemption from public records law.

Iowa’s proposed bill does not restrict sharing with out of state agencies, but Virginia’s outcome for finding violations is better than the one Iowa can expect; the Iowa bill is significantly worse for transparency.

Like Virginia, it would remove ALPR system audit trails, which provide information on what the system is being used for, from oversight. Virginia requires that agencies record data about when the system is being used for stops, and demographic data on who is being stopped. Iowa does not. Iowa requires annual reporting too, but only of self-reported aggregates nobody can verify.

Where some might find it shocking that Virginia’s commission won’t answer the question “who abused the system?”, Iowa took that same bill and surgically removed any possibility of that question being asked.

The only report goes to the Department of Public Safety. This is problematic, given DPS’ history of inaction on surveillance, and its readily-apparent conflict of interest when it comes to oversight of local police.

Any reports would contain aggregates of data that isn’t required to be collected according to any standard, or at all — like the number of stops. But even if the numbers were there, nobody could verify them: the underlying log files are completely inaccessible to anyone except the agency reporting, including DPS.

Make no mistake: Iowa police don’t want you to know about ALPRs. The ACLU of Iowa/University of Iowa’s report showed widespread violations of existing open records law;^[1] the Iowa Public Information Board unlawfully refused to look into non-disclosure of ALPR contracts; and the Wapello County Sheriff and Altoona Police Department adopted policies on concealing ALPR use.

This bill allows them to hide everything. And they will.

The Warrant Red Herring

The Iowa bill also does away with Virginia’s “reasonable suspicion” standard, in favor of a warrant requirement. That warrant requirement, however, is a red herring for two main reasons.

First, it only applies to data older than 24 hours. The first 24 hours are a free-for-all, requiring only self-certification (in a secret log) of a vague approved purpose. During this period, data can be accessed and copied without a warrant. If the data is copied to a location outside the ALPR system, the bill’s protections evaporate. Agencies across the country already use this mechanism to bypass existing retention requirements.

Second, the bill sets no bounds on who can issue a warrant. Any magistrate can. The magistrate does not have to be in the same county, nor does he need to have jurisdiction over the alleged offense. Magistrates appointed before 2009 are not even required to be lawyers—there’s no incentive to push back on a warrant 200 miles away when you’ve been doing the same part time job for 17+ years. The setup enables the worst kinds of forum shopping.

The electronic warrants system compounds the problem—it creates a system where search warrants are, or at least can be, handled similarly to your Amazon Shopping customer service complaints.

The judiciary’s oversight of magistrates is voluntary. That means that unless the chief judge in the county where the warrant was granted — which can differ from the county where it was requested — is actively monitoring the search warrants granted in the county there is no oversight.

Who can complain when the use of ALPR remains hidden? Who can even find warrants when it takes visiting all 99 county courthouses?^[2] And, critically, who could ever find out if the system was queried without a warrant?

Police don’t Police Police

As the outcome in more-transparent Virginia shows, these aren’t hypothetical concerns. We can’t trust police to “do the right thing” when it comes to oversight.

This bill does not aim to solve any problems, it aims to hide them. Virtually all abuses of ALPR systems that have been uncovered have been found by journalists and members of the public; immigration searches in Illinois uncovered by a community group, stalking in Joplin, MO, discovered by DeFlock Joplin, a Kansas police chief was only found to be stalking after admitting it, KCUR in Lenexa found police investigating a column author, and just two weeks ago in Milwaukee, a stalking victim found out by looking up their plate on haveibeenflocked.com.

Because nobody actively monitors how these systems are being used, these abuses are not discovered in real-time. It takes drawn-out open records processes, complex analyses, and lengthy investigations. The bill requires logs to be destroyed within two years — or sooner, at the agency’s discretion.

Of course, whether the existence of evidence in a locked filing cabinet in the basement of the police station actually matters is another question.

Iowa’s bill would sweep this type of evidence of abuse under the rug. It undermines Iowa’s public records law and tacitly blesses the current complete non-enforcement of Iowa’s existing laws on surveillance.

The ACLU/UI report revealed that over a third of Iowa agencies grant access to non-sworn support staff, like administrative staff and clerks. The bill doesn’t address this, nor does it set minimum security standards in statute — it delegates them to the same agency policies nobody audits.

The bill is silent on how Iowa enforces its restrictions on out-of-state agencies that access the data — or on what happens when out-of-state agencies don’t comply with, for example, the requirement to send annual audit reports to DPS.

If this bill passes, some will claim it as a victory. Neither the ACLU, nor the legislature, nor DPS will have any way to verify if it was.

The ACLU of Iowa, Institute for Justice, and Americans for Prosperity should withdraw their support for H.F. 2701. Virginia has proven that it places incident screens where guardrails are needed. Let’s learn from their mistake.

I recently received a copy of Flock’s response to a CDPA request. The response was predictable: obfuscate, misdirect, and deny.

In this article, we’ll pick Flock’s response apart, because the Attorney General hasn’t. Yet.

CDPA 101: It’s GDPR Lite

The CDPAs adopted by the various states broadly follow a pattern inspired by Europe’s General Data Protection Regulation (GDPR). What they protect varies a little from state to state, but the general idea is “information that is linked, or linkable, to persons.”

In equally broad terms, whenever a “person” (government, business, natural person, etc.) collects or maintains protected data, they are a “controller” and someone merely handling the data is a “processor.”

In states with a CDPA, you typically can do things like request your data from the controller, opt out of certain data collection, find out how it’s being shared, and correct incorrect information.

Corporations in general, but mass surveillance corporations in particular, enjoy existing in liminal spaces. Even though various state laws require the separation to be clearly defined in contracts, the terms are often purposely left out, or, if included, left ambiguous.

That problem is compounded for government-funded corporate surveillance because the surveillance devices (cameras, microphones, what have you) and software are often said to be private, while the funding and operational infrastructure (permits, land use, and so on) is provided by the government.

A fun fact — and we’ll get to why it’s “fun” in a minute — is that the government itself is exempt from the CDPA.

A Response, Annotated

With respect to any systems over which Flock is a controller, we did not locate any data in such systems that matched the information provided in your request

It is unclear what systems Flock refers to, but clearly it admits it is a controller of some systems.

But let’s gloss over that really, really quickly.

With respect to any data which may temporarily be stored on Flock Safety devices, such data is consistently written over on a rolling basis due to limited memory space on the devices and is not stored or maintained on such devices in a manner that allows Flock Safety to directly identify, link, or associate the data with an identifiable person. This can only be done via the Flock Safety software systems, where, as described further below, all data is owned and managed by Flock Safety’s customers.

This sounds sort of meaningful, but isn’t. At least not in the way Flock would like you to believe. Ownership and management are not factors, nor is whether Flock “identifies, links, or associates” the data with an identifiable person. Whether the data is stored “temporarily” or whether it’s overwritten on a rolling basis are all technical implementation detail that neither the CDPA, nor the requester cares about.

What they do care about is the admission in the middle of the technobabble: Flock stores or maintains “such data.”

With respect to any systems where Flock Safety processes data on behalf of our customers, please note that Flock Safety’s customers are owners and controllers of the data Flock Safety processes on their behalf. Flock Safety is a service provider and processor for our customers and as a result, we are unable to directly fulfill your request. We recommend contacting the organization that engaged Flock Safety’s services to submit your request, as they are responsible for assessing and responding to it.

This paragraph is Flock’s key assertion. It is boilerplate crafted to dismiss requests under many states’ CDPAs, which share the “processor” language. But it’s lazy boilerplate, because it also uses “service provider” from California’s CCPA/CPRA.

If it’s too much work to craft a form letter specific to California — the most populous state in the nation — it’s probably a safe assumption that it’s too much work to actually look for the data requested.

Here are a few additional points about Flock Safety’s data collection and privacy practices:

Okay, let’s hear 'em.

Customer Contracts: Flock Safety’s processing activity as a service provider and processor is governed by the contract we have with our customers, which captures their instructions and the limitations on how Flock Safety may process their data. Flock Safety’s customers own the data and make all decisions around how such data is used and shared.

The same boilerplate “California-plus” language: “service provider and processor.”

The paragraph itself — its activity is governed by the contract it has with its customers — is meaningful. Hang on to that tidbit, we’ll come back to it.

No Sale of Data: Because Flock Safety’s customers own the data, Flock Safety may only process the data in accordance with our customer’s instructions, as outlined in our contracts with customers. Flock Safety is not permitted to sell, publish, or exchange such data for our own commercial purposes.

Again, the causal link Flock suggests here does not exist. The CDPA places restrictions on the sale of data, but it does not consider “ownership.” That’s deliberate, because it’s not how data sales work in practice: people rarely sell data, they license it.

And while “for our own commercial purposes” is technically correct, it is misleading. As a processor, Flock would not be permitted to “sell, publish, or exchange such data” for any reason. It can follow the express instructions of the controller. That’s it.

Instead, its business model requires it to schlep around buckets full of data between customers, and between its own systems to offer a Surveillance-as-a-Service product.

Information Collected: Where Flock Safety’s customers leverage License Plate Reader (LPR) technology, the LPRs do not process sensitive information like names or addresses. Instead, LPRs only capture images taken in the public view of publicly available and visible vehicle characteristics

Flock’s response focuses on “LPR” cameras. Which is the most well-known of its products, but still only a subset. Its other products, like Condor PTZ cameras, Raven microphones, and even Nova (which “combin[es] CAD, RMS, video footage, LPR data, and even open-source intelligence [which includes things like consumer credit reports, and, according to independent security research, SSNs and other dark web data] in one unified experience”) go unmentioned.

That its roadside cameras don’t process “sensitive information” is false. That term is defined by the CDPA; in Delaware, it includes “precise geolocation data”, in Minnesota it includes “specific geolocation data.” Both are statutorily defined terms describing a type of data captured by Flock’s roadside cameras.

To make the claim true, Flock attempts to substitute its own definition of “sensitive data” for the one provided by the statute.

But what matters more for the response is not whether a specific Flock product handles a specific type of information, but whether Flock, as a company, has protected data.

The answer to that is “yes.”

Purpose: Flock Safety customers use data for security purposes, including managing public safety or responding to safety concerns and reports. Additionally, such data may be used to help solve crimes and provide objective evidence.

Close, but not quite. Flock’s standard contract says: “‘Permitted Purpose’ means a legitimate public safety and/or business purpose, including the awareness, prevention, and prosecution of crime; investigations; and prevention of commercial harm, to the extent permitted by law.”

The purpose itself is mostly irrelevant. The point is that the “Permitted purpose” is defined by Flock, in its standard terms and conditions, which it can unilaterally modify. Determining the purpose makes Flock the controller.

Retention: By default, Flock Safety’s systems only retain data for 30 days, which means that any data collected on behalf of customers is permanently hard deleted on a rolling 30-day basis. Flock Safety customers may shorten or lengthen this retention period based on their local laws or policies.

This is an equally relevant admission: Flock sets the default retention period, and it determines that it “permanently hard deletes” the data. Its customers can influence those terms later, but it is, again, Flock making controller decisions.

Processors vs. Controllers

From Flock’s lazy boilerplate, it’s already sufficiently clear that the company (a) has the data requested, and (b) is the controller of that data. Its response does not survive. But let’s double-tap.

All the States, None of the Work

The response above was from Minnesota, but we’ll use the CDPA from Flock’s state of incorporation — the Delaware’s Personal Data Privacy Act (DPDPA) — to walk through it. DPDPA is not only the most fun to say, it is also functionally identical to Minnesota’s MCDPA in every way that matters here.

If Flock gets to write a California-plus denial, I get to write a Minnesota-plus indictment of it.

Flock’s California-plus language is telling in its laziness. If Flock were a processor, it would have an obligation, under the MCDPA or DPDPA, or some other CDPA, to assist the controller with the request. If it were a service provider, it would have that same obligation, but to the business.

What Flock does instead is punt, without even identifying who it claims the controller is or are — presumably all of its Minnesota clients.

Minnesota gives consumers the right to a list of every third party who received their data. Flock’s response does not even mention it. As a processor, Flock has the duty to assist the controller to locate the list and provide it as a response.

That Flock’s response is lazy is unsurprising when the contact information listed on its CDPA form is “Generitech Privacy 123 Main Street Capital City, ST, USA 10001 +1-800-000-0000 emailprivacy@generitech.com”

The laziness shows that it does not even attempt the bare minimum to fulfill the role it claims for itself. The only thing it does is send out form letters as generic as 123 Main Street.

The Missing Contract

Remember the relevant contract claim. Flock claims there is one, which is good. But the DPDPA and MCDPA (and others) not only require that there be a contract between a controller and a processor, they require it to have specific content.

Flock’s contracts, as we have reviewed them, do not contemplate this. Here is an example of such a missing requirement — you can look for it in the terms Flock publishes on its website:

A contract between a controller and a processor must govern the processor’s data processing procedures with respect to processing performed on behalf of the controller. . . . The contract must also require that the processor to do all of the following: . . . Allow, and cooperate with, reasonable assessments by the controller or the controller’s designated assessor, or the processor may arrange for a qualified and independent assessor to conduct an assessment

Flock’s contracts do not contemplate this at all. Not even close.

The DPDPA requires that the division of labor between a controller and processor is laid out in the contract to avoid exactly the type of shell game Flock attempts to play.

That requirement is not without teeth — the law spells out the consequence of omission:

Determining whether a person is acting as a controller or processor with respect to a specific processing of data is a fact-based determination that depends upon the context in which personal data is to be processed. A person who is not limited in such person’s processing of personal data pursuant to a controller’s instructions, or who fails to adhere to such instructions, is a controller and not a processor with respect to a specific processing of data.

Flock’s prize for failing to have an adequate contract in place is that it becomes the controller.

The Government as Controller

Even if Flock’s contracts were perfect, its position would still fail. As stated earlier, the CDPA does not apply to the government. That doesn’t mean that it is optional for the government, it means that the statute, as a whole, does not apply to the government.

This chapter does not apply to any of the following entities: Any regulatory, administrative, advisory, executive, appointive, legislative, or judicial body of the State or a political subdivision of the State, including any board, bureau, commission, agency of the State or a political subdivision of the State, but excluding any institution of higher education.

Even if a police department were to want to assume the role of the controller, which it doesn’t, it could not. That’s why the language is not in the contract.

“A person who is not limited in such person’s processing of personal data pursuant to a controller’s instructions . . . is a controller and not a processor”.

Someone who is not the controller can’t provide “a controller’s instructions.” Without those instructions, Flock is not “limited” by them.

And because Flock is not limited, it is the controller, as a matter of fact as well as law.

Minnesota’s cure period expired January 31, 2026.

File your requests. Collect your California-plus denial. Encourage your AG to act.

Cross-posted from Footnote 4A, where I cover Flock, privacy, and public-private surveillance infrastructure more broadly. Flock-specific posts live on haveibeenflocked.com.