License Plate Reader (LPR) Camera Policy

California ALPR Usage and Privacy Policy (Civil Code §§ 1798.90.51, 1798.90.53)
Adopted by Westwood Hills Camera Program LLC and the Participating Westwood Hills Neighbors

1. Purpose

Due to ongoing concerns about criminal activity in Westwood Hills, neighbors have collaborated with Flock Safety to install stationary license plate reader (LPR) cameras at various outdoor locations. This policy governs the use of these cameras, the handling of images they capture, and the governance of the neighbors who participate in the camera program.

This policy supersedes the version adopted in December 2023.

This Policy also serves as the ALPR usage and privacy policy required by California Civil Code Sections 1798.90.51 and 1798.90.53. The LLC will make it available to the public in writing and post it on any website maintained for the cameras.

2. Definitions

• “LPR Camera” — a stationary, one-directional camera installed outdoors on private property in Westwood Hills that reads license plates.
• “LLC” means Westwood Hills Camera Program LLC, a California limited liability company.
• “Flock Safety” — the vendor providing, installing, and maintaining the cameras and the software used to access captured footage. Flock operates the camera system and the LLC holds the account.
• “Participating Neighbor” — a Westwood Hills resident who qualifies under Section 3.1.
• “Designated Neighbors” — Participating Neighbors who serve as the primary points of contact for the LLC and hold access to review footage, as identified under Section 3.3. Designated Neighbors access the Flock system as Authorized End Users of the LLC.

3. Governance and Participation

3.1 Who May Participate

Participation in the camera program is limited to Westwood Hills residents who have (a) paid the applicable annual fee to the LLC or have a camera on their property and (b) signed this Policy. Payment of the annual fee or having a camera on their property alone does not confer Participating Neighbor status.

3.2 Contracting Entity and Shared Liability

(a) Role of the LLC. Flock requires a single legal entity as its customer. The LLC signs the Flock Master Services Agreement and Order Form(s) in its own name and for the benefit of the Participating Neighbors. The LLC does not operate for profit and holds no funds other than fees collected for the cameras. The LLC does not sign as an agent for the Participating Neighbors, and Participating Neighbors are not parties to the Flock agreements.

(b) Shared liability. All costs, obligations, and liabilities of the LLC arising out of the cameras (“LLC Liabilities”) are shared equally among the Participating Neighbors. LLC Liabilities include amounts owed to Flock, legal defense costs, settlements and judgments, insurance premiums and deductibles, and the LLC’s state and local taxes and filing fees. A Participating Neighbor’s total share for any one contract year will not exceed $250 (the “Annual Cap”), in addition to the annual fee, unless the liability results from that Participating Neighbor’s own Gross Negligence or Willful Misconduct. Shares are divided among the Participating Neighbors at the time the liability arose.

(c) Contribution. If LLC funds and insurance are not enough to cover an LLC Liability, each Participating Neighbor will pay their share (up to the Annual Cap) within 30 days of a written request from the LLC (email is sufficient). The LLC may recover any unpaid share from the Participating Neighbor who owes it, together with reasonable collection costs.

(d) Indemnification. Each Participating Neighbor, in proportion to their share and up to the Annual Cap, will indemnify, defend, and hold harmless the LLC, its members and managers, the Designated Neighbors, and any person who signs a document on the LLC’s behalf (together, the “LLC Representatives”) against LLC Liabilities, except to the extent caused by that LLC Representative’s Gross Negligence or Willful Misconduct, as defined in Section 3.2(h).

(e) No personal liability. No LLC Representative is personally liable for any obligation of the LLC. Any person who signs the Flock agreement or any other document for the LLC does so only in a representative capacity. Each Participating Neighbor releases the LLC Representatives from all claims arising out of the cameras, except claims arising from Gross Negligence or Willful Misconduct.

(f) Withdrawal. A Participating Neighbor who stops participating remains responsible for their share of LLC Liabilities arising from events that occurred while they participated, but their responsibility ends for any liability first asserted more than 12 months after they stop participating. Residents who have not signed this Policy are not Participating Neighbors and have no rights or obligations under it.

(g) Insurance. The LLC will carry general liability insurance and, where available, privacy or cyber liability insurance and directors and officers insurance covering the LLC, its managers, and the Designated Neighbors. Insurance and LLC funds are applied before any contribution is requested under (c).

(h) Definitions. “Gross Negligence” means a conscious and voluntary disregard of the need to use reasonable care, of a kind likely to cause foreseeable and serious harm to persons or property, and substantially more severe than ordinary negligence. “Willful Misconduct” means an intentional act or omission taken with knowledge that it would likely cause harm, or with reckless disregard of that likelihood.

3.3 Designated Neighbors — Identification and Changes

The LLC keeps the current list of Designated Neighbors. There is no fixed number of Designated Neighbors.

A Designated Neighbor is added or removed only by a majority of the Designated Neighbors, including in response to a written request from a Participating Neighbor, or by stepping down.

To reach the Designated Neighbors, including for questions, footage requests, or SafeList and opt-out registration, email help@westwoodhillsla.com.

3.4 LLC Administration

The LLC will keep LLC funds in its own bank account, separate from the personal funds of any Participating Neighbor or Designated Neighbor, and will keep records of fees collected and amounts paid. The annual fee will include each Participating Neighbor’s share of the LLC’s administrative costs, including the California annual LLC tax, state filing fees, and any insurance the LLC carries for the cameras.

3.5 Decisions, Manager, and Wind-Down

Decisions under this Policy are made by a majority of the Designated Neighbors. The LLC’s manager carries out those decisions and signs documents for the LLC on that basis. If the manager steps down, a majority of the Designated Neighbors will appoint a successor. If the LLC dissolves or no longer holds a Flock agreement, it will pay its remaining obligations, refund any remaining funds to the Participating Neighbors in proportion to the fees they paid for the current term, and notify all Participating Neighbors in writing.

4. Flock Safety Responsibilities

Flock encrypts data in transit and at rest, maintains secure storage with off-site backups, corrects license plate translation errors when identified, and notifies affected individuals by email in the event of a data breach.

5. Camera Operation and Monitoring

Cameras generally operate around the clock, but there is no guarantee cameras will always be operational, and no party can be held liable for a camera being non-operational at any given time or place.

Cameras and footage are not actively or continuously monitored by any party.

6. Data Collected, Retention, and Sharing Transparency

Information collected by the LPR system may include: license plate image; vehicle image; license plate number and state; date, time, and location; and vehicle characteristics (make, color, roof rack, etc.).

Footage remains in the Flock system for the contracted Retention Period (currently 30 days) and is then deleted. Recordings are not sold, and are not shared with or transferred to third parties except as described in Section 7.

6.1 Third-Party and Agency Sharing Review

The Westwood Hills network is not shared with any third party, including LAPD, so Flock Hotlist alerts do not go to any agency. No agency will be granted access unless this Policy is amended to allow it. No sharing setting will be changed without the written approval of a majority of the Designated Neighbors. Designated Neighbors will review the account's Network Sharing settings and the Flock search log at least twice a year.

6.2 Data Security

• Each Designated Neighbor uses an individual login, which is never shared.
• Designated Neighbors do not download or keep footage except to provide it under Section 7.
• Footage and search results are never posted to social media, neighborhood apps, group chats, or any public forum.
• Flock requires a reason for every search and logs the user, date, time, and search terms.
• Misuse of access, including a search for a purpose outside Section 7.1, ends a Designated Neighbor’s access and may end Participating Neighbor status.

7. Access to Footage

7.1 Designated Neighbor Access

The Designated Neighbors have access to footage via the Flock web application. Each Designated Neighbor must complete Flock’s user training before receiving access. Designated Neighbors may review footage only in response to a reported incident of suspected criminal activity affecting a Participating Neighbor or Westwood Hills, or to address a maintenance or serviceability issue. Only Designated Neighbors may search the system. Searching for any other purpose, including monitoring individuals, is prohibited.

7.2 Requests for Footage

A law enforcement agency or officer may request footage for review by submitting a written request to a Designated Neighbor that includes the date and time frame of the incident, a description of the incident and, where available, the vehicle, and a police report number if available.

If responsive footage exists, the Designated Neighbor may provide it to the requesting agency.

Requests from agencies outside California, and from any federal agency for immigration enforcement or any purpose other than a specific criminal investigation, will be declined, consistent with California law.

A Participating Neighbor may receive footage only for an incident at or involving their own property, on a written request that gives the date and time frame and a police report number or a statement that one has been or will be filed. The neighbor may use the footage only for that report and related legal proceedings. Footage will not be released to anyone else except as required by a subpoena, warrant, or court order.

7.3 Opt In / Opt Out

Any Westwood Hills resident, whether or not a Participating Neighbor, may register their vehicles on the SafeList, so that footage of them is marked “resident” but can still be shared with police in the event of a crime, or opt out entirely so that no footage of their vehicles is sent to cloud storage.

7.4 Official Custodian

For purposes of California Civil Code Sections 1798.90.51 and 1798.90.53, the official custodian of the LPR system and the information it collects is the LLC, acting through its Designated Neighbors.

8. Notice and Disclaimers

• The existence of LPR cameras should NOT be relied upon by any resident, tenant, invitee, or visitor as their sole means of safety or security.
• Participating Neighbors, the LLC, and Designated Neighbors are not law enforcement and do not undertake law enforcement activity. All crimes or suspicious activity should be reported directly to LAPD or the appropriate agency.
• Images are collected from areas visible to the public where there is no reasonable expectation of privacy. Although reasonable efforts will be made to restrict dissemination of footage as described in this Policy, no Participating Neighbor, Designated Neighbor, the LLC, or any other person assumes liability for footage distributed outside these procedures, except to the extent caused by a Designated Neighbor's gross negligence or willful misconduct.

9. Amendments

This Policy may be amended by a majority of the Designated Neighbors. Amendments take effect 30 days after written notice to all Participating Neighbors, and a Participating Neighbor who objects may withdraw under Section 3.2(f).

Originally written: November 2018; revised December 2023 and October 2026