22 To get another agency's data, Benicia signed up to 60-day audits. It has produced none.new

The archive has only ever seen this from one side

Findings 6, 8 and 12 all describe the same instrument: the one-page ALPR Data Sharing Acknowledgment Letter that an agency receiving Benicia’s data signs for itself. It has no term. It gives Benicia no audit right. It requires the recipient to do nothing that anyone checks, and nothing at all runs back toward Benicia.

That is Benicia as the agency handing data out. This finding is Benicia as the agency asking for data, and the document it signed to get it looks nothing like its own.

November 2024: the ask

On 2024-11-20 at 7:50 AM, Wendy Stratton Monahan, Senior Management Analyst and PIO at Benicia Police Department, wrote to Amanda Jones, Crime Analysis/RTCC Supervisor at Roseville Police Department:

“Hi Amanda. Can you send me the form needed to gain access to view your FLOCK cameras? Thanks so much!”

Jones replied the next day at 1:33 PM with the Department’s LPR Agency Sharing Agreement attached:

“I’ve attached our sharing agreement. Let me know if you have any questions.”

Monahan returned it signed at 4:31 PM the same day:

“Please see the attached signed form. Have a great weekend.”

Five days later, on 2024-11-26 at 8:37 AM, Jones confirmed:

“I have shared our network with Benecia PD in Flock.”

Request, form, signature and access, in six days.

What Benicia agreed to

Roseville’s ALPR Data Sharing Request and Agreement is three pages. Paragraph 3 sets out what the receiving agency accepts, and four terms are worth reading against Benicia’s own one-page letter.

An accountable administrator. Paragraph 3.b requires the Agency to have

“an ALPR administrator that is responsible for developing, implementing, and overseeing guidelines and procedures for use of ALPR data, including compliance with the requirements of Civil Code §§ 1798.90.51 and 1798.90.53, and this Agreement.”

A named user and a case number on every search. Paragraph 3.d requires that when an Agency employee accesses Department data, the search record carry

“The name of the employee accessing or using the data; and … A related case number, incident number, or call for service (CFS) number.”

and, where none exists, “a detailed reason for the search.”

An audit every sixty days. The same paragraph continues:

“The Agency’s ALPR administrator or other appropriately designated individual shall conduct audits of Agency’s searches at least every sixty (60) days to ensure compliance with this requirement.”

No onward sharing. Paragraph 3.e:

“Department data shall not be shared with other agencies, including law enforcement agencies, without the express written consent of the Roseville Police Department.”

Paragraph 4 then reserves to Roseville what Benicia’s own letter never reserved to Benicia: the right, “in its sole discretion, and for any or no reason at all,” to “revoke, rescind, or otherwise terminate Agency’s access … without notice.”

Who signed, and as what

The signature page carries Edward Criado, Deputy Chief, dated 11/21/24, under “Agency Signatures.”

Page three carries his signature a second time, under a different line. The printed caption reads:

“Printed Name, Agency’s LPR Manager”

and beneath it, in his hand, “Edward Criado, Deputy Police Chief.”

So the sixty-day audit obligation in paragraph 3.d is not an abstraction attached to an institution. It attaches to the officer who signed as the Agency’s LPR Manager, by name.

The audits

Benicia’s own Policy 470 has required a quarterly audit of ALPR inquiries since August 2021, with the section absent from the versions dated January and September 2024 and returning in September 2025. Asked for those audits under PR-2026-180, the City produced seven versions of the policy that requires them and not a single audit conducted under it.

The Roseville agreement adds a second obligation, accepted in writing, on a shorter cycle. Nothing produced by the City shows an audit under it either.

There is now also a public account of what happens instead. Councilmember Terry Scott, answering a candidate questionnaire on 2026-09-05:

“Our Deputy Police Chief already conducts quarterly reviews, pulling random samples of Flock search requests and checking them against policy.”

Quarterly is a longer cycle than sixty days, and a random sample is a different thing from the compliance check paragraph 3.d describes, which is specifically whether each search carries a name and a case number. Whether those reviews generate any record has been asked and not yet answered.

What is not established here

Roseville shared its network with Benicia on 2024-11-26. The Shared Networks export Roseville produced, dated 2026-09-02, lists Benicia as sharing to Roseville with the “Networks Shared With Me” column empty. Something about the arrangement changed between those dates, and no record produced by either agency explains it. Paragraph 4 would let Roseville end it without notice and without reason, but no revocation record was produced, and the column semantics of a two-party export are not a safe basis for a conclusion. That is a question for Roseville, not a finding.

Roseville has also withheld the Flock Network Audit showing Benicia’s searches against its network, saying it “does not generally produce” those records and undertaking to release the non-exempt portions by 2026-09-30. That export, if it arrives, is what would show whether the searches Benicia ran carried the name and case number paragraph 3.d requires.

In fairness to the City, its own instrument did improve. The letter rewritten by counsel in August 2026 requires a receiving agency to hold an ALPR policy “which includes a process for periodic system audits” and lets Benicia revoke access for non-compliance. Twenty-five agencies signed that version between 4 and 12 August 2026. It arrived twenty-one months after Benicia signed Roseville’s.

A note on the source

The three Roseville PDFs are not alike, and the difference matters to anyone checking the quotations.

The agreement carries its own text. Benecia.pdf has a real text layer, so every quoted term above comes from the document’s own text, extracted with pdftotext -layout, not from OCR. The phrases “sixty (60) days”, “express written consent of the Roseville Police Department”, “in its sole discretion, and for any or no reason at all” and the Civil Code citations are all verifiable against it directly.

The two email chains do not. Both are image-only scans and have been through the archive’s OCR pass, rapidocr at 200 dpi. Artifacts remain and have not been tidied, because the archive is never edited to fix OCR: Monahan’s email reads “FLoCK” for “FLOCK”, and Jones’s reply loses its spacing, appearing as “IhavesharedournetworkwithBeneciaPDinFlock.” The wording is unchanged.

The signatures are in neither. Both signature blocks are handwritten, and no extraction reads them. The printed captions are present, including “Printed Name, Agency’s LPR Manager”, but the name written beneath that caption on page three is not. So the fact that Edward Criado signed as the Agency’s LPR Manager, which is what attaches the sixty-day audit duty to a named officer, rests on reading the page image. Anyone checking it should look at page 3 of the PDF itself rather than the transcript.