The policies
Edgewater Police Department Policy 422 governs the plate readers, and the vendor’s transparency portal publishes its own summary of the rules. Here is what each says, checked against the Order Form and the Addendum, and where the documents disagree with one another.
Four numbers, with their dates
The plate-reader policy, section by section
Quoted where the wording matters, and tied to the section of Policy 422 that states it. The policy is the department’s own text, published with permission. The City’s public copy is linked from the Portal’s “Additional Info” section; see the City’s public ALPR policy page, linked from the portal’s “Additional Info” section.
The policy says this in its own words.
An obligation written as a recommendation.
Two documents in the set say different things. The conflict is left open.
The policy does not address it.
Purpose [422.1]. The policy says the ALPR “convert[s] data associated with vehicle license plates” for official law-enforcement purposes. The uses it lists are identifying stolen or wanted vehicles and stolen plates, missing persons, Amber Alerts, Medina Alerts (hit-and-run vehicles), Blue Alerts, officer safety, active warrants, suspect interdiction, and stolen-property recovery. It names a reduction in racial-profiling complaints as an “ancillary benefit,” “because the ALPR provides automated detection of all license plates captured by the camera(s).”[POL 422.1]
Administration [422.2]. The Chief of Police, or a designee, manages installation, maintenance, retention, and access.[POL 422.2]
Operation [422.3]. The operating rules, lettered as in the policy:
- (a) Official and legitimate law-enforcement business only.[POL 422.3(a)]
- (b) May be used with any patrol operation or investigation. See item 01 below.[POL 422.3(b)]
- (c) May be used to canvass plates around a crime scene. ALPR-equipped cars are to be used for homicides, shootings, and other major incidents.[POL 422.3(c)]
- (d) No one may operate the equipment or access the data without completing department-approved training.[POL 422.3(d)]
- (e) Before enforcement action based solely on an ALPR alert, the officer must verify the plate, including its state, through the Colorado Bureau of Investigation (CBI).[POL 422.3(e)]
- (f) No ALPR operator may access CBI data unless authorized.[POL 422.3(f)]
- (g) Officers “will not conduct a traffic stop based solely on an alert.” An alert “should be considered one element” contributing to reasonable suspicion. See item 05 below.[POL 422.3(g)]
Data collection and retention [422.4]. ALPR data “is not open to public review.” Information “may be used and shared with prosecutors or others only as permitted by law.” Data in patrol vehicles must be transferred to the server “not to exceed 30 days between transfers.” Data stored on the server “should be securely stored for 1 year after the creation of the data,” and may then be purged unless it becomes evidence or is subject to a records request.[POL 422.4]
Safeguards [422.5]. (a) Non-law-enforcement requests go to the records supervisor. (b) Access is by login and password, and the policy requires a log of who accessed what, by name, date, and time. (c) Access is limited to legitimate law-enforcement purposes tied to a specific investigation or department civil or administrative action. (d) Data may be released to other authorized and verified law-enforcement officials and agencies “at any time for legitimate law enforcement purposes.” (e) “ALPR system audits should be conducted on a regular basis.”[POL 422.5]
01Stated in policy
Reasonable suspicion or probable cause is not necessary before using an ALPR.
The sentence is in the operating section, Policy 422.3(b), and the policy places no threshold on collection. The limits it sets are on access, sharing, retention and enforcement, and those are covered below.[POL 422.3(b)]
02Documents conflict
Data stored on the server “should be securely stored for 1 year after the creation of the data.”
The Order Form and the Portal both state a 30-day retention period, and the policy states one year for server data. Each document is quoted below.[OF p.13][PORTAL][POL 422.4]
Policy 422.4
should be securely stored for 1 year after the creation of the data
Order Form and Portal
Retention Period: 30 Days
Portal: data retention, 30 days (as of the August 12, 2025 update)
Still openWhich figure governs which system. The documents may describe a vendor cloud and a department server, but they do not say which is which.
05Documents conflict
Officers “will not conduct a traffic stop based solely on an alert.”
The policy allows an alert to be “one element” of reasonable suspicion. The Portal lists traffic enforcement among the prohibited uses of the system.[POL 422.3(g)][PORTAL]
Policy 422.3(g)
An alert “should be considered one element” contributing to reasonable suspicion.
Portal, prohibited uses
traffic enforcement
Still openHow the two statements fit together in practice. The documents do not say whether, or how, an alert is used alongside other reasons in a traffic stop.
06Stated in policy
Before enforcement action based solely on an ALPR alert, the officer must verify the plate on the vehicle, including its state, through the Colorado Bureau of Investigation.
The Portal says the same thing in its own words: “Hotlist hits are required to be human verified prior to action.” The verification duty applies to action based solely on an alert. The policy does not say what happens when a hit is used alongside other information.[POL 422.3(e)][PORTAL]
07Should, not shall
ALPR system audits should be conducted on a regular basis.
“Should,” not “shall.” The policy states no audit schedule, does not say who conducts audits, and does not say who receives them. The Order Form’s Insights and Analytics page lists “user and network audits” among its reports, but the documents do not say whether those reports are run or shared with the City. The set contains no audit report.[POL 422.5(e)][OF p.17]
08Stated in policy
Data may be released to other authorized and verified law enforcement officials and agencies at any time for legitimate law enforcement purposes.
“Authorized and verified” is the only filter the policy states. It sets no limit by jurisdiction and requires no log of what was shared with whom. The policy does not mention the statewide or nationwide lookup networks listed in the Order Form, or the about 90 external organizations the Portal lists.[POL 422.5(d)][OF p.17][PORTAL]
09Not stated
All system access requires a valid reason and is stored indefinitely.
This sentence is the Portal’s, not the policy’s. Policy 422.5(c) limits access to legitimate law-enforcement purposes tied to a specific investigation or department civil or administrative action, and 422.5(b) requires a log by name, date, and time. Neither document says whether a reason is entered with each search.[PORTAL][POL 422.5(b)-(c)]
What the Portal publishes
The Portal is provided by Flock Safety and was last updated August 12, 2025. Its figures are the vendor’s summary as of that date.[PORTAL]
What it says is detected
License plates and vehicles. Facial recognition, people, gender, and race are listed as not detected.[PORTAL]
Acceptable use
“Data is used for law enforcement purposes only. Data is owned by The Edgewater (CO) Police Department and is never sold to 3rd parties.”[PORTAL]
Prohibited uses
Immigration enforcement; traffic enforcement; harassment or intimidation; usage based solely on a protected class (race, sex, religion); and personal use.[PORTAL]
Access and hotlists
“All system access requires a valid reason and is stored indefinitely.” “Hotlist hits are required to be human verified prior to action.” The hot lists it alerts on are NCIC, NCMEC Amber Alert, and the Colorado Crime Information Center.[PORTAL]
| Measure | Figure |
|---|---|
| Vehicles detected, last 30 days | 135,048 |
| Hotlist hits, last 30 days | 1,492 |
| Searches, last 30 days | 94 |
| Number of LPR and other cameras | 6 |
| Data retention | 30 days |
| External organizations with access | About 90, including the Edgewater PD itself, Denver CO PD, Lakewood CO PD, Colorado State Patrol, and Colorado Bureau of Investigation |
These numbers come from the vendor’s page, dated August 12, 2025, and cover one 30-day window. The documents do not show how the figures are calculated, and they do not show whether the 94 searches were run by Edgewater staff or by outside agencies. The portal does not say.[PORTAL]
Things a resident would expect and the documents do not show
The document set does not include state statutes beyond those the documents cite, news coverage, council minutes, or CORA responses. This page does not assess them.
- Camera locations. No installation list, deployment plan, or map appears in the set.[T&C ยง10.2][OF p.17]
- Sharing settings. Which agencies and networks can search Edgewater’s cameras, and whether statewide or nationwide lookup is on.[OF p.17]
- Audit reports or an audit schedule. Policy 422.5(e) says “should,” and the set contains no report.[POL 422.5(e)]
- A search log. Policy 422.5(b) requires one, but the set contains no log entries.[POL 422.5(b)]
- A list of prohibited uses in Policy 422. The operating rules in 422.3(a) to (g) set none. The only prohibited-use list in the set is the Portal’s.[POL 422.3][PORTAL]
- Discipline for misuse. The policy states no consequence for misuse.[POL 422]
Requests that name records which already exist
Each request below names a record or setting the policy or contract says exists. A request for something that already exists is easier to answer than one that asks for a new analysis.
- The Flock sharing configuration as currently set: every agency and network able to search Edgewater’s cameras, and the status of state and nationwide lookup.
- Any ALPR audit conducted under Policy 422.5(e), or confirmation that none has been.
- The search log described in Policy 422.5(b), for a stated period.
- The invoices and payment records under the December 12, 2023 Order Form, including the discount line.
- The transfer and purge records under Policy 422.4 for the server data.
- The installation date and Deployment Plan: the camera locations.
- Any City Council action approving the contract.
Sources for this page
- Edgewater Police Department Policy Manual, Policy 422, “Automated License Plate Readers (ALPR)” (PDF pp. 9-10), Lexipol copyright 2025/07/15, published with permission by the Edgewater Police Department. Cited as [POL].
- “Edgewater CO PD, Transparency Portal,” provided by Flock Safety (PDF pp. 7-8), “Last Updated: Tue Aug 12 2025.” Thirty-day figures are as of that update. Cited as [PORTAL].
- Exhibit A, Order Form (PDF pp. 11-19), Flock Group Inc. and “CO - City of Edgewater,” customer signature dated December 12, 2023. Cited as [OF].
- Flock Safety Terms and Conditions (PDF pp. 21-38), printed from flocksafety.com on 4/28/2025; “Last Updated: October 4, 2024.” Cited as [T&C].
- Addendum to Flock Group Inc. Services Agreement Order Form with the City of Edgewater, Colorado (PDF pp. 1, 3, 5), signed 12/12/2023. Cited as [ADD].