Public Policy vs. Private Sharing: California Rebuilds the National Network

When a Flock user performs a search, that search is logged in accounts belonging to the agencies that originally funded the cameras.^[1] It ends up in “Network Audit” logs, some of which are published on this website. This is true whether it is a “TALON” (nationwide or statewide) lookup, or a “1:1” search. As states have tightened laws, the “1:1” numbers have been increasing, suggesting that a shadow network is being created to evade privacy laws and public oversight.

The screenshot is from a Flock training video which shows a Flock user interface for automatic data sharing. The video was posted by ACLU of Massachusetts in October 2025, but various dates in the video suggest it was recorded in May 2024.

California’s Workaround

After Flock disabled the “nationwide network” for its California customers “1:1” sharing exploded. Rather than—or more likely, in addition to—switching to the statewide network, agencies in California increased the number of partner networks they added—from fewer than 7 new partnerships per week on average to more than 40.

When searches are done through a 1:1 sharing connection they are only logged in the originating agency’s “Organization Audit” and in the receiving agency’s “Network Audit.” This is unlike national searches, which are broadcast to the world and will almost certainly make their way into someone’s open records request. Agencies aren’t limited to actually performing 1:1 searches. They can trawl through data from all of their 1:1 connections seamlessly.

This leads to situations like those in Pittsboro, IN, where the agency entered into 3,968 partner agreements for a system it only used 17 times in the last 30 days.^[2] A slightly-outdated visualization of the 1:1 sharing network is available.

The data for this is hard to come by. Uncertainties persist due to what are presumably major data issues in Flock’s log files, as well as seemingly arbitrary redaction of the total_devices_searched and/or total_networks_searched columns both by Flock and agencies.

The available data does, however, support the idea that Flock and police have been building a shadow network, and that some restricted agencies, like those in California, have been using it.

The trend is not explained by Flock growing its customer base, or the overall number of networks. In fact, nationally the number of networks appears to be stagnating.^[3]

The Data Problem

The data must be interpreted with the caveat that Flock’s audit logs appear to be extremely unreliable.

We’ve seen the search inversion in August 2025 and the accompanying drop in log entries. Examining counts more broadly shows even more bizarre outliers, and inexplicable patterns.

The chart above shows the most popular (approximate) network pool size for “search” queries in three populous states. While Illinois and California at least appear plausible, the same can’t be said for Texas’ odd saw-pattern; I can see no plausible reason why agencies would suddenly search 50% fewer networks for a week.

There is no evidence that these anomalies have bothered auditors in any way, or that any questions have been asked. Flock certainly has not addressed it in a blog post or customer update.

The Telltale Ratios

Another piece of the puzzle that suggests this workaround is in active use is usage patterns.

The chart shows the proportion of queries made through 1:1 search connections versus TALON (the nationwide network). California agencies use 1:1 searches for 31% of their queries—three times the rate of unrestricted states like Texas (11%) or Arizona (3%). Minnesota and Virginia, which have also enacted restrictions on ALPR, show similarly elevated rates. This pattern is consistent with restricted agencies routing queries through 1:1 partnerships to bypass network limitations.

The scale of some agencies’ 1:1 networks is staggering. We have seen 358 agencies in California do searches on (a median of) 449 networks. These numbers seem realistic in the context of a national estimate of ~5,000–6,000 agencies.

Yet El Cajon PD searches 3,584 networks through 1:1 connections—ten times the number of in-state agencies. The California Highway Patrol searches 2,181, and the Riverside County District Attorney searches 2,896.

These outliers use a shadow network reaching 60–95% of TALON’s nationwide coverage, all while technically using “bilateral” sharing agreements.

Secrets and Silence

It’s important to note at this stage that although these 1:1 agreements are often understood to be reciprocal in nature, it is unclear whether they in fact are. Washington University research notes that the “shifting and sometimes inaccurate statements made by Flock about its product’s sharing features” contribute to this confusion.

To further frustrate analysis, Flock does not make its product documentation available to the public, and agencies do not generally release it responsive to public records requests. It is therefore unclear if the restrictions seen in the (presumptive) May 2024 video still apply, or if, in 2026, agencies can automatically accept requests from anyone, anywhere.

Still, while the exact scope and mechanism remain unknown, the available information does demonstrate the existence of a shadow network, powered by some form of “auto-accept” or similar feature.

California agencies are not, on average, hammering out between six and forty new agreements in any given week. Going by recent public records responses, agencies are not exchanging emails about these partnerships, let alone validating policies are in place. It has all the hallmarks of a checkbox.

That checkbox appears to be a “set and forget.” Nothing suggests that administrators are notified when a request is auto-accepted. The Washington University report highlights that many police chiefs were entirely unaware that third parties had access until notified by the researchers, who reviewed the logs.

Flock’s CEO Langley told us that “it is a local decision. Not my decision, and not Flock’s decision.”

What he built, buoyed by the FBI’s unsubtle threat of retaliation for complying with public records requests, does create local decision-makers—ones who’ve decided that laws are optional and silence is policy.