Editor’s note: This article is part of ALPRs in Focus, a Police1 editorial series examining how agencies use automated license plate reader technology, the investigative value it can provide, and current concerns surrounding privacy, data access, retention and misuse.
Law enforcement agencies are adopting technology at a remarkable pace.
Automated license plate readers can help locate stolen vehicles and identify vehicles associated with criminal investigations. Drones can provide situational awareness during critical incidents, searches and major events. Artificial intelligence is beginning to assist with everything from report writing to data analysis. Facial recognition and other investigative technologies provide capabilities that would have been difficult to imagine a generation ago.
These technologies can make law enforcement more effective. They can also generate significant questions from employees and the communities we serve.
What information is being collected? Who can access it? How long is it retained? Can the technology be used to track someone? What prevents an employee from using it for personal reasons? Is information being shared with other agencies? Who ensures that the policies governing its use are followed?
Those are not simply technology or policy questions. They are communication questions. Public information officers should be involved in answering them.
Recent allegations involving misuse of automated license plate reader data provide a good example of why.
In July, five former Albany, Georgia, police officers were arrested following an investigation into alleged misuse of the department’s license plate reader system. According to the Georgia Bureau of Investigation, an internal audit found that the officers had accessed retained license plate data on multiple occasions for non-law enforcement purposes. The officers were charged with misuse of license plate data and violating the oath of office.
The case raises questions about policy, supervision and accountability. For PIOs, it should raise another question: What did we communicate before something went wrong?
The PIO belongs in the technology conversation
PIOs are often brought into an issue when someone decides the public needs to know about it. The agency purchases new technology. Policies are developed. Employees receive training. The technology is deployed. Then a reporter calls.
Suddenly, communications is asked to explain what the agency purchased, why it is being used, what information it collects and what safeguards are in place to protect the public. That is too late to begin the communications process.
When an agency is preparing to deploy technology that collects information, increases surveillance capabilities or raises legitimate privacy concerns, communications should be part of the implementation conversation.
That does not mean the PIO decides which technology the agency purchases or writes the operational policy. It means the PIO should be asking questions from two perspectives:
- What do our employees need to understand?
- What does our community deserve to know?
Those conversations should occur before deployment, not after controversy.
Internal communication goes beyond teaching employees how it works
When agencies introduce new technology, training understandably focuses on operation:
- How do I log in?
- How do I search?
- What information can I retrieve?
- How do I operate the drone?
- How do I access the system?
Employees need those answers.
But knowing how to use technology is different from understanding the responsibilities that come with access to it.
Employees should also understand why the agency acquired the technology, what constitutes appropriate and inappropriate use, what privacy concerns accompany it, how activity is monitored and what consequences may follow misuse.
Training is where internal communication becomes part of risk management.
A policy may clearly prohibit an officer from conducting an ALPR search for personal reasons. Employees may even electronically acknowledge that policy.
That does not necessarily mean the organization has effectively communicated the expectation. There is a difference between distributing a policy and creating organizational understanding.
Consider the difference between simply providing access to an ALPR system and communicating something like this to employees:
You are being given access to information for legitimate law enforcement purposes. Searches are associated with individual users and may be audited. Using the system to search for a spouse, former partner, neighbor, friend, coworker or anyone else without a legitimate law enforcement purpose may result in serious disciplinary consequences and potentially a criminal investigation.
That message takes very little time to communicate. But it eliminates ambiguity.
Vendor training is not organizational communication
A technology company can demonstrate how its product works. It can explain available features, security controls and safeguards built into the system. It cannot communicate an agency’s values. It cannot explain what the chief expects from employees. It cannot put the technology into the context of the agency’s relationship with its community. And it cannot explain how misuse could damage public trust that may have taken years to build.
That responsibility remains with the agency.
PIOs can help translate policies, technical requirements and privacy safeguards into language employees understand. That communication should not happen once.
Expectations can be reinforced through roll calls, supervisor meetings, periodic training, internal communications and policy updates. When technology changes or new capabilities are added, employees should understand what changed and whether their responsibilities changed with it.
The first time employees hear a detailed explanation of the risks associated with a technology should not be after someone abuses it.
The public needs an explanation too
Internal communication is only half of the responsibility. The second audience is the community.
Residents may notice automated license plate readers appearing along roadways, see a police drone flying over their neighborhood or learn that their department is using artificial intelligence, facial recognition or another technology capable of analyzing large amounts of information.
The agency understands why it acquired the technology. The public may not.
From the agency’s perspective, an ALPR may be an investigative tool that helps locate stolen vehicles, identify vehicles linked to serious crimes or find missing people.
A resident may see a government camera recording license plates and ask: Are you tracking me?
That is a reasonable question. The response should not be dismissive, defensive or buried in technical language. It should be answered.
Explain what it does and what it does not do
Public communication about technology should begin with the reason the agency is using it. What problem are we trying to solve? How does this technology help us accomplish that? Then explain what the technology will do to address the problem.
With an ALPR system, residents may want to know what information is captured, whether photographs of drivers or passengers are collected, how long information is retained, who can conduct searches and under what circumstances.
Drone programs raise different questions. When can drones be deployed? Are they recording continuously? Can they look into someone’s backyard or home? How long is video retained? Can the agency use a drone without a warrant? Are there restrictions on where or when it can operate?
Artificial intelligence raises new questions. What decisions are being assisted by AI? Is AI making decisions about people? Is personally identifiable information being entered into an outside system? Is a human reviewing AI-generated information before action is taken?
The exact questions will change with the technology. The communications principle does not. Explain the capability. Explain the purpose. Explain the limitations.
Privacy cannot be an afterthought
Law enforcement communicators are accustomed to explaining what technology allows an agency to do. We also need to explain what the agency is doing to prevent that technology from being abused. That is particularly important when technology involves information about members of the public.
If searches are audited, say so. If access controls are in place, explain who has access. If information is automatically deleted after a specified period, explain the retention period. If searches require a legitimate law enforcement purpose or case number, explain that requirement. If agency policy prohibits certain uses, make that policy available when appropriate. If information can be shared with other agencies, explain when that can occur.
These details may seem operational from inside the organization. From outside the organization, they are evidence of accountability. Sometimes preparing those explanations also reveals questions the agency itself has not adequately answered.
A PIO preparing public information about a new technology may ask:
- How long do we retain this data?
- Who can access it?
- Who audits its use?
- Can another agency search our information?
- What happens if an employee conducts an improper search?
If nobody can provide a clear answer, that is valuable information for the organization to discover before the public asks the same question.
Communications can become an early warning system.
Do not make transparency sound like a sales pitch
There is another trap agencies should avoid. When announcing new technology, it can be tempting to focus exclusively on benefits.
The new software system will help solve crimes. The drone program will improve officer safety and help locate missing people. The automated license plate reader cameras will help locate suspects. These may all be true.
But if the agency talks only about benefits while ignoring privacy concerns, communication can sound more like marketing than transparency. PIOs should acknowledge the questions reasonable people may have about government technology and explain what the department is doing to protect privacy.
That does not mean apologizing for using legitimate law enforcement tools. It means recognizing that the public has an interest in understanding how government collects and uses information.
An agency can explain the investigative value of ALPR technology while also explaining safeguards against misuse. It can explain how drones improve situational awareness and address when and where they may be used. It can discuss the potential benefits of artificial intelligence while acknowledging the need for human oversight, security and appropriate use.
Transparency becomes more credible when we are willing to discuss both capability and responsibility.
What happens when something goes wrong?
No communication strategy can guarantee that technology will never be misused. Employees can violate policy. Systems can fail. Technology can be used in ways an agency never anticipated. But what an agency communicated before the incident matters when something does go wrong.
Consider two agencies facing nearly identical allegations of technology misuse.
The first agency publicly explained the technology, shared its policy and described the safeguards intended to prevent misuse. It also discussed its auditing procedures and the training provided to employees.
The second agency said little or nothing about the technology.
Both may face difficult questions. But they begin those conversations from very different positions.
The first agency can point to established expectations and safeguards and then explain where they may have failed.
The second may find itself explaining the technology, policy, safeguards and alleged misconduct for the first time during a controversy.
That is a difficult time to begin building understanding.
A technology communications checklist for PIOs
When an agency introduces technology that affects the public or provides employees with access to sensitive information, communicators should address multiple audiences.
For employees:
- What is the technology intended to accomplish?
- What constitutes appropriate use?
- What uses are prohibited?
- What privacy or ethical concerns accompany the technology?
- Is employee activity monitored or audited?
- What consequences can result from misuse?
- Where can employees go with questions?
For the community:
- Why is the agency using the technology?
- What information does it collect?
- What does it not collect?
- Who has access to the information?
- How long is the information retained?
- What is the policy on sharing information with other agencies?
- What safeguards exist against misuse?
- What policies govern its use?
- How does the agency monitor compliance?
- Where can residents find additional information or raise concerns?
PIOs may not have every answer. But we should know who does.
The first time we explain a new technology should not be after an employee misuses it, a reporter questions it or the community challenges it.
Before we deploy the technology, we should be prepared to explain both what it can do and how we will use it responsibly.
