TLO gives Lansing police
access to a lot of information
November 13, 2019
An alert reader - who wishes to remain anonymous - noticed something in my October 11
story Two civic organizations
lose City of Lansing recognition. There was a
police report
at the end of that story, and the last sentence in that report says
He noticed that the report
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mentioned that they used "TLO" to find
other people living at Michelle's address. This appears to be a
subscription service from TransUnion, at https://www.tlo.com/law-enforcement.
According to the website, among the many features of this
service, it grants Law Enforcement access to query our credit
histories through Transunion, access employment information, and
also lets them "Locate vehicles nationwide using license plate
recognition data". |
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(Transunion is one of the big three credit reporting
services: Transunion, Equifax and Experian.}
The reader wonders
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Did the City Council authorize LPD to
purchase and use such an invasive service? Does LPD have any
policies protecting citizen privacy rights related to this
private system? How long has LPD had access to this system?
How has LPD used this system in the past? What does it cost the
city? How much data is in the system related to citizens who are
not subject to active investigations? How long does this company
retain data on Lansing residents? Does a citizen have the option
to opt-out of having their data collected by the vendor, or from
being accessed by LPD? |
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He also wonders
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how use of this TLO system to query the
respondent's address for other citizens at that address was
relevant to the complaint; since the officer already had the
name address of the person accused of harassing the victim, and
stated that person could not be located at that address. Why
did they need to know who else lived at the house? Seems like
an invasion of the privacy of the other residents at that
address. (A better use of such a tool might be to find out who
the 800 number belonged to that was harassing the victim, to
confirm the validity of the complaint.) |
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This same reader is familiar with a technology called Automated License Plate
Recognition (ALPR) defined at
this site as
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[A] technology that uses optical character
recognition (OCR) to automatically read license plate characters. . .
Mobile ALPR software suites use multiple cameras mounted on a
vehicle. As the vehicle moves, it photographs license plates and
transmits plate data to a database. The database may be a national
database or it may be created at the local level and downloaded into the
vehicle's onboard computer at the beginning of each shift. If the system
detects a match, the officer receives an alert on his computer. A mobile
ALPR can read up to 1,000 plates per hour and cover two or more lanes of
traffic at once. |
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Several years ago, the Lansing police department
purchased ALPR equipment and software and gave the system a try. In
December 2014, our reader submitted a FOIA
request to the Lansing police department for an electronic extract of
all license plate data collected through the use of ALPR. The city
attorney denied the request "pursuant to the personal privacy exemption
found at MCL 15.243 (1)(a) of FOIA . . Disclosure of the
information would not advance the core purpose of FOIA, which is to
significantly contribute to the public understanding of government." But the reader also sent a list of questions to the police
department and got an answer from then-Police Chief Mike Yankowski.
Yankowski's answers are in bold:
Our reader says now that
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LPD has previously said that they have
stopped using in-car ALPR technology, and no longer has ALPR
devices or data from those devices. Even though LPD might not
have cameras capturing plate information directly anymore (and
they are no longer storing the information themselves),
this website suggests LPD now, thru the TLO service, may
have access to a network of private license plate location
databases (often obtained by using privately owned cameras and
GPS equipment installed on taxi cabs, toll roads, and tow
trucks, capturing and storing the location of every license
plate they pass) to search for all the places that a given
vehicle had been seen on public streets or private parking lots,
anywhere in the country. This could provide the City with a
significant amount of personal information about the activities
of the person who uses a given vehicle, as well as locations
that they go to regularly -- locations which the person may
believe and/or assume to have been private, confidential, and
unknown by others By using a
private nationwide service to perform the function that was
previously performed by several local governments in our region
(the collection of license plate location information within the
City of Lansing limits by LPD), the City has expanded their
ability to invade our privacy, and also removed the potential
for transparency because these records are no longer created by
the government entity (and no longer subject to FOIA). |
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