If you have heard of CIPA, BIPA, GIPA, or TCPA litigation, you may have an idea of where this post is headed. These acronyms reference federal and state laws that permit a private right of action for certain privacy-related claims, affording successful plaintiffs with statutory remedies. In a recent case, Bartholomew v. Parking Concepts, Inc., an appellate court in California may have opened the door to a new line of similar litigation stemming from a state law regulating automated license plate recognition (“ALPR”) technology.
What is ALPR?
Automated license plate recognition (ALPR) technology uses fixed or mobile cameras paired with computer algorithms to capture license plate images and convert them into searchable, computer-readable data.
Why is ALPR used?
Common uses include locating stolen vehicles, identifying wanted individuals, managing parking access and payment, supporting toll collection, investigating crimes, and monitoring access to secured facilities. For example, Flock, an AI startup that leverages ALPR technology, has been cited for helping to solve crime, albeit not without some controversy.
Is ALPR use becoming more common?
Yes. ALPR systems are often used in the public sector, usually by law enforcement, but private sector use cases have been increasing with parking operators, repossession companies, insurers, HOAs, retail/commercial property owners, and others, as noted in a recent Car and Driver article.
Are there federal requirements for ALPR?
No comprehensive federal ALPR statute exists, although some legislative efforts have been made to limit their use nationally. Regulation is primarily state-by-state, though federal privacy and surveillance law (e.g., Fourth Amendment case law limiting warrantless, prolonged tracking) can inform how ALPR data may be collected, retained, and shared, particularly by government users.
What states regulate ALPR?
At least 16 states have ALPR-specific statutes, including California, Arkansas, Colorado, Florida, Georgia, Maryland, Minnesota, Montana, Nebraska, and New Hampshire, among others. Roughly six of those states restrict private-sector or government use outright, about eight impose data retention limits, and several exempt ALPR data from public records disclosure.
What does California’s ALPR law require?
California’s ALPR statute (Civil Code §§ 1798.90.5–1798.90.55) applies to both government and private-sector “ALPR operators” and “ALPR end-users.” It requires:
- Reasonable security safeguards (administrative, technical, physical) to protect ALPR information from unauthorized access, use, or disclosure.
- A written, publicly available usage and privacy policy; if the entity has a website, posted conspicuously on that site.
- The policy must address: authorized purposes for collecting/using ALPR data; job titles of personnel with authority to use and access the ALPR system; monitoring and audit procedures; rules on sale, sharing, or transfer of data; the custodian responsible for compliance; accuracy safeguards; and data retention/destruction timelines.
- Public agencies generally may not sell, share, or transfer ALPR data except to another public agency.
Note also that California’s data breach notification law (Cal. Civ. Code Sec. 1798.82) provides that information or data collected through an ALPR system, if breached, could trigger a notification requirement.
Does failing to post an ALPR policy online create liability, even without a data breach?
Potentially yes, at least in California. In the Bartholomew v. Parking Concepts, Inc. case noted above, the court held that a parking garage’s camera system qualified as an ALPR system, and that operating it without a publicly posted usage and privacy policy violates an individual’s statutory “right to know,” which alone is sufficient to allege cognizable harm under Civil Code § 1798.90.54, although not every violation of the law will trigger relief for a plaintiff. The court reasoned:
“In other words, while the ALPR Law does not impose specific restrictions on the use of ALPR information, it grants individuals the right to know which entities are collecting their ALPR data and how it is being used and maintained. Collecting and maintaining individuals’ ALPR information without implementing and making public the statutorily required policy harms these individuals by violating this right to know… If an ALPR operator has failed to implement and make public the statutorily required policy establishing authorized uses, it is much more difficult to hold them accountable for unauthorized uses, even though this is an example of a harm-causing violation expressly stated in the ALPR Law. This further underscores the significance of the publicly available policy to the ALPR Law’s statutory scheme”
What can a plaintiff recover under California’s ALPR law?
Section 1798.90.54 allows an individual “harmed” by a violation to sue any person who knowingly caused the harm, and recover: actual damages (or liquidated damages of at least $2,500 per violation), punitive damages for willful or reckless violations, attorney’s fees and litigation costs, and equitable relief.
Do any other states offer a private right of action or statutory damages like California?
Some do. For example, an Arkansas law (Ark. Code § 12-12-1807) permits a person injured in business, person, or reputation by a violation may sue for actual damages or liquidated damages of $1,000, whichever is greater, plus litigation costs. Nebraska (Neb. Rev. Stat. § 60-3208) allows a private suit for damages that proximately cause injury to business, person, or reputation, but sets no liquidated-damages floor. Washington’s new Driver Privacy Act (SB 6002) creates a civil remedy for an injured person and, for certain government contractors, treats violations as per se unfair/deceptive acts under the state Consumer Protection Act, which carries its own private right of action, treble damages up to $25,000, and attorney’s fees.
What steps should businesses take to comply with the California ALPR law?
- Determine whether any camera/software system used (including third-party parking, security, or access-control vendors) meets the statutory definition of an ALPR system.
- Draft a written usage and privacy policy covering all statutory elements (purpose, authorized personnel, monitoring/audit process, sharing restrictions, custodian, accuracy measures, retention/destruction schedule).
- Post the policy conspicuously on the company website, not merely buried in an internal manual.
- Implement reasonable administrative, technical, and physical security safeguards for ALPR data.
- Update incident response plans to include ALPR system data.
- Restrict data sharing and sale consistent with the policy and applicable law.
- Audit vendor contracts (parking operators, repossession firms, security vendors) to confirm their ALPR practices align with the business’s own compliance obligations.
- Monitor other states where the business operates, since requirements vary significantly by jurisdiction.