Adopted October 8, 2026 · Civil Code §1798.90.51
The Automated License Plate Recognition (ALPR) Usage and Privacy Policy below was adopted by the Board of Directors at an open meeting held October 8, 2026, and is posted here as Civil Code sections 1798.90.5–1798.90.55 require. A copy is also provided on request to management.
1. Scope
The Association operates cameras and recording systems at the community’s vehicle entrances and in other Common Area locations. Some of this equipment reads vehicle license plates and stores the plate number, together with the date, time, location and an image of the vehicle, in searchable form (“ALPR information”). This Policy applies to every such system the Association operates, whatever the equipment, and governs the collection, use, access, retention and sharing of ALPR information. The Association is an ALPR operator and end-user under Civil Code sections 1798.90.5 through 1798.90.55, and this Policy is adopted and made available to the public as those sections require. Video recordings that are not converted into searchable plate data are not ALPR information.
The system is an access-control and parking-administration tool. The Association does not monitor it in real time and does not undertake to provide security or protection to any person or property.
2. Authorized purposes
ALPR information may be collected, accessed and used only to: (a) administer the Association’s parking Rules, including verifying vehicle and guest registrations and identifying vehicles parked in violation of the Rules; (b) control vehicle access to the community; (c) investigate or document an incident of theft, vandalism, damage to Common Area or Association property, trespass or threat to safety; and (d) respond to a lawful request or order of a court or law-enforcement agency. ALPR information may not be used for any other purpose, including any commercial purpose.
3. Authorized users and training
The following may use or access the ALPR system and ALPR information, for the purposes in Section 2 only: (a) the President of the Board or the President’s designee, who administers the system, and any other director the Board designates; (b) the community manager assigned to the Association by its managing agent and a designated backup at the managing agent; and (c) contractors engaged to install, maintain or support the system, for that work only. Before access is granted, each authorized user receives a copy of this Policy and instruction on the system from the system administrator.
4. Security, monitoring and access records
The Association maintains reasonable safeguards to protect ALPR information from unauthorized access, use or disclosure: access is limited to the authorized users in Section 3, each with their own credentials where the system supports them; the system is kept on the Association’s network or otherwise password-protected; and credentials are removed when a user leaves the relevant position. The system administrator monitors access to the system and reviews it periodically for compliance with this Policy, reporting any concern to the Board. When ALPR information is accessed or provided to another person, a record is kept of the date and time, the plate number or other data searched, the user, and the purpose, as Civil Code section 1798.90.52 requires; the system’s own logs satisfy this where available, and otherwise the user records the access in a log kept by management.
5. Sharing
The Association does not sell ALPR information. ALPR information is shared only: (a) with contractors as necessary to install, maintain or support the system; (b) with law enforcement to report or investigate an incident or in response to a subpoena, warrant, court order or lawful request; (c) with the Association’s legal counsel or insurer in connection with a claim, enforcement matter or dispute; (d) with a Resident, as to images of that Resident’s own vehicle in a matter involving that vehicle; or (e) as otherwise required by law.
6. Accuracy
Plate reads are machine-generated and may be inaccurate. Before any fine, tow or other enforcement action is based on ALPR information, an authorized user verifies the read against the vehicle image and the registration records. A Resident who believes a read was misattributed to their vehicle may ask management to review the record, and management will correct any error.
7. Retention
ALPR information is retained on the system for no more than ninety (90) days, after which it is deleted or overwritten automatically, except that information identified within that period as relevant to an incident, an enforcement matter or a lawful request may be exported and kept in the Association’s records for as long as that matter requires. Registration records (plate numbers associated with a Unit or guest registration) are not ALPR information and are kept under the Association’s vehicle registration procedures.
8. Custodian
The custodian of the ALPR system and of ALPR information, responsible for implementing this Policy, is the President of the Board or the President’s designee, as system administrator. The Board reviews this Policy when the system or applicable law changes.
9. Availability
This Policy is posted on the Association’s website and is provided on request.
Adopted by resolution of the Board of Directors at a duly noticed open meeting held October 8, 2026, under Civil Code section 1798.90.51.