Brea-Olinda Master Community Association (“Association”) has installed at all four community entrances (Santa Fe Road at Valencia Avenue; Sandpiper Way at Valencia Avenue; Santa Fe Road at Carbon Canyon Road; Brea Hills Avenue at Carbon Canyon Road), subject to change and relocation, an Automated License Plate Recognition System (“ALPR System”). An 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 vehicle license plates and the characters they contain into computer-readable data. 
 
If the Association maintains a website, this Policy shall be posted on such website. 
 
A. Purpose 
 
The purpose of this Automated License Plate Recognition System Policy (“Policy”) is to provide requirements for the use, operation, storage of and access to the ALPR System. 
 
The Association will use the ALPR System to capture and store digital license plate data and images while recognizing the privacy rights of members and residents. The primary purposes and benefits of the ALPR System are to deter criminal activity and assist law enforcement officials should a crime occur in the community.  
 
The Association makes no representations or guarantees that the ALPR System will be monitored and/or operational at all times. Members and residents should not rely on the ALPR System or the Association for their own personal protection or safety, or that of their family members, tenants and guests, or for the protection or safety of their property. The Association makes no guarantees of safety and no representations that the community is safe or that the ALPR System will successfully deter criminal acts committed by third parties. Each member and/or resident should take measures they believe appropriate to protect themselves, their family members, tenants and guests, and their property. 
 
B. Access to ALPR System and Data 
 
All ALPR data is collected and stored for law enforcement purposes consistent with this Policy. 
 
1. Law Enforcement Access 
 
The Association has authorized the sharing of ALPR data with the Brea Police Department. 
 
Law enforcement agencies may access ALPR data directly through the vendor platform in connection with official investigations and in accordance with applicable law. 
 
Residents seeking information related to a criminal matter must file a police report with the Brea Police Department. The Association will not conduct searches on behalf of residents. 
 
2. Association Access-Audit and Compliance Only 
 
The Association does not access or use ALPR data for general investigative purposes. 
Operational access credentials for the ALPR System shall be limited to: 

• The Association’s designated ALPR System Custodian (typically the Community Manager); and 
• A two-member ALPR Subcommittee appointed by the Board of Directors. 

The members of the ALPR Subcommittee shall serve staggered Board terms to promote continuity and avoid simultaneous turnover of both members in the same year. 
 
Access to the ALPR System by the Custodian or Subcommittee shall be limited to: 

• Conducting periodic compliance audits; 
• Verifying data retention and deletion settings; 
• Confirming adherence to this Policy and applicable law; 
• Responding to lawful preservation requests, subpoenas, or court orders if required; 
• Responding to limited resident requests authorized under this Policy; and 
• Assisting law enforcement in connection with official investigations. 

All access and use of ALPR data shall occur only as permitted by applicable law and this Policy. 
 
No individual Board member outside the designated Subcommittee shall independently access or query ALPR data. 
 
3. Access Logging and Oversight 
 
All access to ALPR data, whether by law enforcement or the Association's Custodian, shall be logged in accordance with Civil Code §1798.90.52. 
 
The Board of Directors shall maintain oversight responsibility by reviewing periodic compliance reports but shall not access raw ALPR data. 
 
C. Training 
 
Each person having access to the ALPR System and data shall complete Association approved training before using or accessing the ALPR System and data, except that law enforcement and other governmental agencies may have their own training. Evidence of completion of such training shall be retained in the Association’s records. 
 
D. Administration 
 
The installation and maintenance of the ALPR System and equipment, as well as ALPR System data retention and access, shall be managed either by the Association or an operator as designated by the Board of Directors. 
 
E. Monitoring 
 
The Association, together with any operator, shall be responsible to monitor the ALPR System to ensure the security of the data accessed and used and to ensure compliance with all applicable privacy laws. 
 
On a regular basis, the Board of Directors, or its operator, if any, shall perform an audit to determine the persons and entities who have been provided with access to and have used the ALPR System to confirm the security of the data accessed and to confirm compliance with all applicable privacy laws. 
 
The Association and/or its operator, if any, shall not use or allow others to use the ALPR System and data for any purpose not authorized under this Policy. 
 
F. Sale, Sharing or Transfer of ALPR Data 
 
ALPR System data shall not be sold. ALPR System data shall not be shared or transferred except as may be provided herein. 
 
G. Responsible Party 
 
The Association is responsible for implementing this Policy. 
 
H. Accuracy of ALPR Data 
 
The Association shall take reasonable measures to ensure the accuracy of ALPR data and correct data errors. Upon discovering or being informed of any inaccuracy or data error of the ALPR System, Association and/or its operator shall promptly correct same if reasonably able to do so. 
 
I. Retention and Automatic Deletion of ALPR Data  

ALPR data shall be retained for no longer than thirty (30) days from the date of collection. 

The Association utilizes vendor system settings that automatically delete ALPR data after thirty (30) days without manual intervention. 

 

The Association shall not manually extend retention periods.  

 

Retention beyond thirty (30) days shall occur only if: 

• The data is subject to a documented preservation request from law enforcement; or 
• The data is subject to a subpoena, court order, or other legal obligation. 

Any preservation shall be limited to the specific data identified in the legal request and retained only for the duration required by law. Preserved data shall be deleted promptly once the preservation obligation ends. 

 

The ALPR System Custodian shall periodically verify that automatic deletion settings remain active and functioning properly.