LPR Camera Usage and Privacy Policy

This policy governs the Automated License Plate Recognition System (“ALPR system” or “system”) operated by the Silverhawk Ridge Community Association (“Association”), and applies to our managers, directors, committee members, and/or security professionals who have access to our system. Our ALPR system is a searchable computerized database resulting from the operation of one or more mobile or fixed cameras combined with computer algorithms to read and convert images of registration plates and the characters they contain into computer-readable data. The information contained in the system (“LPR data”) includes images of license plates, plus the date, time and location when the images were collected, and the license plate characters and numbers associated with the image. The images stored in the system are collected from areas visible to the public where there is no reasonable expectation of privacy. The collection and dissemination of the information contained in the system is protected activity under the First Amendment to the US Constitution. Moreover, LPR data stored in our system does not include any personally identifying information (PII), or information which relates the license plate image to the driver or registered owner of a vehicle. PII contained in vehicle registration information is protected by federal law (Driver’s Privacy Protection Act, Title 18, US Code, Section 2721 et seq.) and state laws. Law enforcement and other users may have access to vehicle registration information, and other sources of PII, which they may correlate with LPR data stored in the system to create vehicle hotlists in accordance with the above referenced federal law.

(A) Use and Collection of LPR Data

The Association authorizes collection of LPR data for the use of by the Association consistent with this policy. The authorized uses of the ALPR system are:

By the Association to identify or ascertain the location of a specific vehicle under circumstances when there is a legitimate security, safety, or rule or guideline compliance interest.
By law enforcement agencies for law enforcement purposes.
By the Association to make LPR data available to Association personnel and law enforcement agencies for the purposes above, and to provide market research information to customers based on aggregated LPR data.

The company does NOT make the ALPR system or data it contains available to individuals for personal, non-commercial purposes.

(B) Users and Training

All approved Association personnel are authorized to use the ALPR system to effectuate legitimate security, safety, and rule or guideline compliance interests.

All independent contractors of the company are authorized to use the ALPR system for purposes consistent with their underlying contract with the company and this policy. All authorized employees and independent contractors that collect ALPR Information are required to read and understand any documents (e.g. the operational manual for the specific camera type) necessary to successfully operate a camera. Additionally, all authorized employees and independent contractors that collect ALPR Information are required to read and understand “Know Your Rights: Photographers” published by the American Civil Liberties Union (ACLU) located at: https://www.aclu.org/know-your-rights-photographers (July 2014).

(C) Monitoring and Compliance

The Association is not aware of any individual privacy interest applicable to the anonymous LPR data contained in the system, however, because the Association considers LPR data a valuable asset of the company, we maintain usage logs, and periodically audit such logs, to ensure the security of our data assets and compliance with this policy. The usage logs include the following information:

The date and time LPR data is accessed.
The IP address from which the LPR data is accessed.
The license plate number or other data elements used to query the system.
The username of the person who accessed the information and, as applicable, the organization or entity with whom the person is affiliated.
The purpose for accessing the information.

(D) Sale, Sharing or Transfer of LPR Data

The Association collects data for security purposes and does not collect data on behalf of law enforcement agencies. The company does not share data with any third parties except to the Association’s contractors as necessary to enforce security interests as well as other rules and regulations of the Association. The Association may also share information with law enforcement in the event it is reasonably related to legitimate security or safety interests.

(E) Custodian or Owner of the ALPR System

The Association is the custodian and owner of the ALPR system and is responsible for implementing this policy.

(F) Accuracy of LPR Data

The collection of LPR data is automated so that the license plate images, and the details of when they are collected, are included in the system without review, along with the computer translation of the license plate number. Although very infrequent, the license plate translation is sometimes inaccurate or incomplete. To avoid mistaken use of LPR data, the company recommends users of the data confirm the computer translation before taking any action as a result of LPR data. The Association corrects mistaken translation and other database errors when identified.

(G) Retention

The Association retains LPR data until it is written over to provide space for new recordings (which is currently less than thirty days).

(H) Revisions of Usage and Privacy Policy

The Association reserves the right to revise this policy at any point in the future and such changes will be retroactively applicable to data collected prior to any revision of this policy.